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Citizenship: East, west or global? • Bryan S. Turner

Citizenship: East, west or global? • Bryan S. Turner

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Bryan S. Turner

I want to break out of the East–West paradigm that has haunted the history of the concept of

citizenship and to look, in a period of globalization, at common rather than different problems.

My contention is that with the political impact of globalization, there is a common set of problems associated with citizenship that is shared across the globe. While cultural anthropology and

political sociology are inclined to stress significant differences between societies, in this chapter

I examine a cluster of related issues that confront societies with shared problems of participation

and resource allocation. The common cause of many difficulties challenging citizenship is a

demographic shift from high to low fertility and from youthful to ageing populations.

In questioning the idea that ancient Greece was the seedbed of modern democracies, it

makes more sense historically to see the rise of citizenship in the nineteenth century with the

rise of an urban working class that presented a growing challenge to bourgeois civil society.

Insofar as theories of citizenship were developed in Victorian Britain, it was from liberals like

John Stuart Mill on the one hand and from radicals like Karl Marx on the other. One would

have to say that, on the surface, neither the liberal Mill nor the radical Marx had much time for

citizenship. Mill, having read the second volume of Alexis de Tocqueville (1969) on Democracy

in America, which appeared in 1840, concluded that expanding the franchise to the uneducated

working class would result in a ‘stationary society’ which he compared to ‘Chinese stationariness’ (Turner, 1974). Mill was not as such a friend of democracy and, while he championed

the freedom of the individual from social conformity, he wanted social pressures to limit large

families in order to avoid overpopulation. In On Liberty Mill (1962 [1859]: 163) felt that the

‘laws which, in many countries on the Continent, forbid marriage unless the parties can show

that they have the means of supporting a family, do not exceed the legitimate powers of the

State’. Mill’s view of the legitimate role of the state contradicts his own defence of individual

liberty and his view of overpopulation and large families could be said to have anticipated what

was to become the Chinese one child per family policy.

Modern theories of citizenship by contrast have embraced the idea of a right to reproduce

which is regarded as a component of ‘sexual citizenship’, partly because reproduction is seen to

be an important aspect of women’s health. Changing attitudes towards sexuality, sexual orientation, and gender are perhaps nowhere more strikingly illustrated than in the acceptance, at least

in the US Supreme Court, of same-sex marriage in the last decade. Despite strong opposition

from fundamentalist religious groups, legislation in support of same-sex marriage has been supported on the argument that opposition to its acceptance involves sex classification which is

parallel to race classification (Klarman, 2013). I shall return to this issue in my conclusion.

Marx was also hostile to Thomas Malthus’s population theory, but in most other respects he

was a critic of Mill’s version of individualism and rights to personal liberty. In the so-called Jewish

Question, he had argued that political rights without social rights and the redistribution of wealth

would be a hollow victory for the workers. He was critical of ‘bourgeois’ citizenship precisely

because of its underlying assumptions about the prominence of individual rights over social rights.

While Mill and Marx would appear to stand at opposite ends of a continuum in terms of political

theory, they agreed on one crucial point. They drew a deep contrast between the dynamic capitalism of the West and the stationary societies of Asia, especially India and China. In this respect

Marx probably never departed far from Hegel for whom the East had no history.

While the American and French Revolutions, drawing heavily on their interpretation

of classical authors and Enlightenment rationalism, were definite points of departure for the

modern theory of rights in general and of citizenship in particular, contemporary citizenship

studies has been driven mainly by sociology with its concern for the public sphere and social

rights. The modern debate about citizenship in the social sciences has centred on the reception

of T. H. Marshall’s Citizenship and social class and other essays (1950). Although this work was


Citizenship: east, west, or global?

published in the immediate aftermath of World War II, its influence was mostly experienced in

the 1980s and onwards, when the policies of Thatcherism were beginning to take effect in the

United Kingdom. Marshall wrote in the context of the Beveridge Report (1942) and Keynesian

economics. While John Maynard Keynes was no enemy of capitalism, we might call Marshall’s

sociology of the welfare state an example of social Keynesianism. It took for granted the expansion of the state as a necessary consequence of increasing social security and generous welfare

provisions. In fact, national insurance and pension schemes for the workers went back to the

Liberal government of Herbert Asquith, but it was mass mobilization for war that was the real

driving force behind the expansion of social citizenship in the 1950s and 1960s.

In retrospect, therefore, the Thatcher years in the United Kingdom and the Reagan administration in the United States were significant turning points in the history of modern citizenship, the outcomes of which are perhaps only finally and fully appreciated in the economic and

financial crisis of 2008 that continues to unfold. Between 1979 and 1990, Thatcher did much to

roll back the state, to destroy the political power of the trade unions, to deindustrialize Britain,

and to promote the rise of finance capitalism and the dominance of the City over traditional

manufacturing industries (Campbell, 2009). She had little tolerance for the social provision of

welfare and Norman Tebbit, as Employment Secretary, had said that the unemployed man

should, like his own father, get ‘on his bike’ in search of work rather than seeking support from

the government. I shall argue later that the decade approximately from 1974 to 1984 laid the

foundation for what was to become ‘consumer citizenship’.

In considering the history of citizenship, we must keep in mind that America was the exception. There is the well-known argument from S. M. Lipset (1963) onwards that America, unlike

Europe, never had a powerful or successful socialist movement or socialist party. There are many

dimensions to this argument: the greater role played by religion in public life; the foundations

of slavery and its enduring impact on American politics and culture; the frontier experience and

the genocide of native Americans; the unbridled nature of capitalism; the dominance of liberalism in approaches to individual rights; and its unmatched global power in the second half of the

twentieth century; and finally its denial of any significant imperial history. Here however I am

only concerned with the issue of citizenship and civil rights.

Although notions of ‘individual rights’ and ‘civil liberties’ play a major role in American

political philosophy, ‘citizenship’ does not appear prominently in the vocabulary of either political science or sociology. The War of Independence, the history of slavery, the Civil War, and

the civil rights movement have shaped how Americans think about the relationship between the

individual and the state. Judith Shklar (1991: 147), in recognizing the protection of minorities as

being fundamental to American democracy, claimed that civil liberties occupy ‘the very heart of

American political values’. In short, what comes first in American political culture is the protection

of the individual from arbitrary state interference rather than collective provision against the

negative effects of economic instability. In Britain, post-war reconstruction and the legacy of the

welfare state implied the responsibility of the state in protecting vulnerable individuals from

the unpredictable exigencies of everyday life. In the United States, private provision and voluntary associations have been more significant in offering some degree of security for workers.

When American sociologists do in fact turn to the analysis of citizenship, they are typically

concerned with questions about race and immigration. Given the history of migration in the

United States, these two foci are hardly surprising. One example can be located in Talcott

Parsons’s American Society (2007), in which social solidarity is preserved through the institutions

of citizenship. The other important components of solidarity for Parsons are the law, religion,

and shared values. He argues that the American societal community has been largely successful

in coping with cultural pluralism and he employs the idea of citizenship to consider the tensions


Bryan S. Turner

between solidarity and conflicts over interests. The main example of successful integration (the

‘adaptive upgrading’ of the system) has been the transition from early slavery through emancipation to the emergence of the Afro-American community as simply one component of an

ethnically diverse social order. The discussion of citizenship and race reflects his earlier work on

the social rights of the black community (Clark and Parsons, 1966). The growth of social and

political rights not only explains the success of ethnic minorities in integrating into American

society but also the resilience of social solidarity against the strains of authoritarianism, racism,

and class conflict.

Whereas the British debate about social rights has concentrated on the tensions between the

market, social class, and the welfare state, British sociologists invariably pay no attention to religion and ethnicity, which have been dominant themes in the United States. The parameters

of the debate about civil society, democracy, and the state were originally defined by Alexis de

Tocqueville in Democracy in America (1969) of 1835 and 1840, in which the churches as primary

examples of voluntary associations were seen to be the principal providers of major social services

in the absence of a centralized state. This connection between churches, welfare, and voluntarism

has come to define a continuing characteristic of American democracy in which local community

action is favoured over an interventionist state. Political opposition to Washington has often taken

a populist form, including the recent protests of the Tea Party (Amery and Kibbe, 2010).

In concluding this opening discussion, we can simply note that there are different versions of

citizenship in the West. In the century between 1850 and 1950, Western states experimented

with a variety of authoritarian, liberal, and social-democratic strategies to provide some degree

of security against economic volatility (Mann, 1987). Britain in 1919 and France in 1920 created

ministries of health to address the chronic illness and disability suffered by troops during the

Great War. The common theme in this development was the emergence of an urban working

class that represented a potential threat to bourgeois culture and political authority.

I shall treat Judith Shklar as the exemplary theorist of citizenship in America. Issues relating

to injustice and inequality were taken up in her American Citizenship (1991), where she argued

that most interpretations of citizenship in political philosophy had ignored the importance of

employment and earning in the foundation of notions of citizenship in colonial America. What

the Founding Fathers feared most were the twin issues of slavery and aristocracy. Slavery quite

clearly involves a loss of human status and dignity, while the role of an aristocracy was associated with luxury and idleness. In short: ‘We are citizens only if we “earn”’ (Shklar, 1991: 67).

Given the connection between right and duty, earning an income is important if citizens are to

fulfil their proper obligations such as paying their taxes, maintaining a household, and supporting their children.

Different trajectories/common problems: demography1

Clearly there are therefore specific conditions and different histories that explain differences in

the historical development of citizenship in different national settings. I have already recognized

the major differences in the West between citizenship in Northern Europe with welfare-state

provision and the United States with its emphasis on individual responsibility and the market as

an efficient economic mechanism. At the same time I am struck by the commonality of issues

that face citizenship on a global scale. To understand these common issues, we need to abandon the Orientalist language of West versus East and focus on common issues within a global

framework. These common problems sit at the intersection between demographic changes,

economic developments in capitalism, and the political framework of representative democracy.

Let us start with demography.


Citizenship: east, west, or global?

Modern societies from Germany to China are faced by a paradoxical combination of demographic changes, especially declining total fertility rates (TFRs) and corresponding rapid ageing

of populations. There is an urgent political question: how to provide for the dependency of an

ageing population? The causes of declining fertility rates are well documented in demographic

history: urban living, the decline of agricultural employment, the availability of family planning

and contraception, and the growth of literacy and education, especially for women. These demographic developments have been especially important in East Asian societies, where fertility rates

are remarkably low. The majority of developed societies now have TFRs around or below 2.0.

However, I want to argue that these developments are more or less universal, apart from some

developing societies – such as Afghanistan and Mali, where the TFRs are 6.2 and 6.0 respectively.

A replacement fertility of the population in the developed world is around 2.1 births per

woman and globally it is approximately 2.33. The TFR for the United States in 2011 was 2.01,

or below replacement, but its population continues to grow because of legal and illegal inward

migration. In South Central Asia, the TFR is 3.3, in Southeast Asia 2.7, and in East Asia 1.7.

Some four decades ago, the average TFR in East Asia was around 6. Thus, the replacement

rate in East Asia is defined as suboptimal. According to the CIA World Factbook, in 2012 the

TFRs for East Asia are as follows: Singapore 0.78; Hong Kong 1.09; Taiwan 1.1; Japan 1.39;

and China 1.55 (Central Intelligence Agency, 2013). South Korea offers yet another interesting

example of these developments. As a result of rapid economic development and urbanization,

Korean women were drawn into formal employment and out of the agricultural economy. In

the 1950s the TFR was over 5, but this had declined to 1.29 in the period 2005–10. South

Korea has an ageing population. In 1955 only 3.3 per cent of the population was 65 and over,

but now it is close to 11.0 per cent. Social change has consequently been dramatic, especially

in terms of urbanization. The population of South Korean is around 50 million people and the

capital Seoul has a population of 10 million. However, within the Seoul Capital Area it is 25.6

million. With the traditional Confucian respect for education and the changing hierarchy of

occupational status, there has been growing household expenditure on education. As a result,

the costs of large families cannot easily be sustained, especially because Korean parents place

a heavy emphasis on the material success and social mobility of their children (Kwon, 1993).

These developments pose important questions for economic growth and for the standard of

living of the working population.

It is well known that Japan’s demographic transition has been dramatic, and its consequences

are highly problematic. In 2012, Japan had a population of 127,368,088 people, but its population growth is negative (or –0.077 per cent). It has a rapidly ageing population in which 23.9

per cent is 65 and over. Consequently the ‘burden of dependency’ (the ratio of those in the

age range of employment to the elderly and children) is extreme. The average life expectancy

of Japanese women is now 87.4 years, but it is predicted that it will rise to 97 years by 2050.

The Japanese TFR in 2010 was 1.39, which represented a slight improvement from 1.32 in the

period 2001–5. Societies with a low TFR can still enjoy population stability or indeed growth if

they have policies that encourage immigration. Japan, however, is an exception. Its net migration is

zero, and while there are 2.2 million foreign immigrants in Japan, these are primarily of Japanese

descent from South America.

Other Asian countries are also experiencing an ageing problem. For example China’s economic ‘miracle’ has been associated with its so-called ‘demographic dividend’, but Chinese

policymakers are currently worried by the decline in the working-age population, which shrank

in 2012 by around 3.4 million persons. As the Chinese middle class has grown, its TFR has

declined, but China’s one-child-family policy of the 1970s has been the major factor in its

fertility decline (Greenhalgh and Winckler, 2005). Efforts to increase fertility in the region, for


Bryan S. Turner

example in Singapore, through policy initiatives have not been successful (Thang, 2005). A report

for the Singaporean government in 2013 from the National Population and Talent Division

provides a range of policy options designed to increase fertility, such as faster access to housing to

support young couples and providing affordable childcare options. Why are these demographic

changes consequential and how do they relate to questions about citizenship in Asia?

These developments – declining fertility and ageing populations – are obviously not confined

to East Asia. Russia has acute population problems. It is difficult to obtain precise demographic

data for Russia, but basically its population suffered from the collapse of the Soviet Union in

1991, which was followed by two decades of decline. The death rate increased, as the standard

of living declined, and the health status of the male population decreased as a consequence of

alcoholism and high rates of HIV infection. By the end of the century, life expectancy for men

was 63 years of age, and the birth rate fell from 17/1000 in the 1980s to 10/1000 in the 1990s.

As a consequence of government strategies to improve population growth and structure, the

TFR of 1.25 in 2000 rose slightly to 1.41 in 2010.

Citizenship can be understood as a bundle of ‘contributory rights’ in which citizens receive

entitlements in return for duties undertaken to the community, including payment of taxes, family

formation and reproduction, and military service (Turner, 2008). Population decline has significant consequences for military defence, especially for societies with disputed, problematic borders.

Russia and Singapore, which depend on conscription, are both confronted by population decline,

ageing populations, and popular resistance to conscription. Demography has obvious implications

for the capacity of societies to defend their borders, especially when they are confronted by hostile

neighbours. The classic example is Israel, which has ongoing military conflicts with neighbouring

states and which also has a declining population and considerable internal political uncertainty

(Ben-Porat and Turner, 2011). Israel has enjoyed a population growth rate in recent years of

1.5 per cent and a large influx of Russian Jews after the collapse of the Soviet regime. The Israeli

population is composed of 6,042,000 Jews, 1,658,000 Arabs, and 318,000 others. There is some

evidence that Israel is following a global trend in ageing. The life expectancy of women is

83.6 years and 10.3 per cent of the population is 65 and over.

The important feature of the Israeli population is its internal variation. In the period 1995–

2000 the TFR for secular Israelis was around 2.0 to 2.2, for Christian Arabs, 2.6, and for Arab

Muslims and Druze, 4.0. However for the Haredi (the ultra-Orthodox Jews) it was 6.0–7.0.

These ultra-Orthodox Jews are not recruited into the military, have very low employment rates,

high levels of poverty, and their Torah study and isolation from the formal labour market are

funded by the state. With proportional representation, the religious, mainly through lobbying

by the Shas Party, have considerable leverage over state resources. It is estimated that the ultraOrthodox by 2030 would have a million members, most of whom will be children. At the same

time, Israel is confronted by a Palestinian population with a high birth rate. While the figures for

the Palestinian population are unsurprisingly contested, there are some 10.7 million Palestinians

in the Palestinian Territories, Israel, neighbouring Arab countries and other parts of the world.

The Palestinian TFR in the 1950s was over 7, in the 1960s over 8, and in this century it has been

around 5.05 to 4.65. Some observers believe that Israel as a viable society cannot be sustained on

this basis unless there is further inward migration, unless the Haredi can be persuaded to engage in

secular occupations and support the military, and unless the Palestinian TFR declines significantly.

There is no such thing as ‘the universal demographic transition’ in global terms, but demographic changes are playing a significant part in the more general features of social change.

These developments include the changing status and nature of masculinity, the rising status of

women in the civil sphere, the growing dependence on foreign workers, the growth in international marriages, the development of international brides, the erosion of filial piety, the rise


Citizenship: east, west, or global?

in single-person homes, and so forth. In global terms, the status of women has risen as their

fertility rates drop, primarily as a consequence of a dramatic improvement in education. As a

result, their employment in the formal labour market is also rising. To take one example almost

at random: women in modern-day Kuwait represent 70 per cent of the university population

(Gonzalez, 2013). Of course, the progress of women towards educational and employment

equality is never a smooth road. There can be an erosion of such rights and hence an evolutionary model of advances in citizen rights, which was implicit in Marshall’s theory, should be

resisted. Changes in policies to contraception in Egypt under the influence of Salafiyya Muslims

in former President Morsi’s government resulted in an increase in fertility rates which will in

the long term have negative consequences for women’s social advancement. How exactly do

these demographic developments relate to questions about entitlements and duties within the

framework of social citizenship? More specifically, how do they relate to the issue of ‘contributory rights’? The connection between democracy and demography might be expressed through

the idea of sexual citizenship, namely the bundle of rights and obligations relating to entitlements

to marriage, procreation, abortion, and divorce or the rights that allow people opportunities to

control their own sexuality. However in this chapter I argue that the implications of demographic change go much further into issues relating to youth employment, retirement benefits,

pensions, and ultimately to personal identity, especially masculine identity.

While educated women are moving into the formal labour market (especially in the service

sector), where they are challenging the traditional dominance of men, women are also especially

vulnerable to exploitation. There has been an important feminization of the migrant workforce

globally and ample evidence of the economic exploitation of women in the developing world,

where women from rural backgrounds find themselves at the mercy of ‘new masters’ in factories

with unregulated work conditions (Hairong, 2008).

Alongside these changes, as we have noted, is the greying of populations. This development

is dramatic in the West, as the Baby Boomers born in 1946 are rapidly approaching retirement and Western governments are obviously concerned about the rising costs of pensions and

medical care for the elderly and, given the economic climate, many governments are seeking

to privatize pensions or to opt out of their obligations to the elderly. There are various solutions to this problem, all of which have implications for citizenship rights – extend the period

of employment for workers by removing compulsory retirement, invest in technology to make

labour more efficient or to replace it, increase inward migration, especially of skilled workers

through a points system, promote same-sex marriage on the assumption that this would improve

adoption rates and in the case of lesbian couples increase the TFR through donor insemination,

and relocate elderly populations to societies with low labour costs through the creation of retirement villages. Most governments are trying to implement all of these options, but what must

be borne in mind is that the pressure to privatize erstwhile universal and public arrangements is

global (Blackburn, 2002).

One unintended consequence of migration is growing social diversity, which poses a general

question for governments: how to manage growing cultural diversity with migration and globalization, especially religious and ethnic diversity? The global demand for (young) labour inevitably produces diversity through labour migration. One important change in the modern world

is that Islam, which until the middle of the twentieth century existed as a majority religion in

most Middle Eastern societies, now exists as a minority religion in many, if not most, Western

societies. The majority of Muslims live outside the Middle East and in many societies Muslim

communities now enjoy a successful existence alongside other religions in multifaith and multicultural societies (Bilici, 2012). However, there has also been widespread opposition to the

presence of veiling in public spaces and to the alleged spread of the Shari’a.


Bryan S. Turner

My principal argument is that, given a significant decline in fertility, political leaders look,

other things being equal, to migration to sustain the workforce. Importing ‘fresh’ labour is a

quick solution to low fertility, but it comes with a price. The unintended consequence is cultural

diversity, and governments need to embrace positive policies to multiculturalism in order to avoid

social conflict. Conflicts with Muslim diasporas in Denmark, Norway, France, and Germany are

not encouraging in terms of successful multiculturalism. In many European countries right-wing

extremism – the English Defence League, the Norwegian Defence League, Golden Dawn, and

so forth – may yet prove to be problematic. In the past it was assumed that right-wing parties

could not have significant electoral success, because there is a tendency for consensus to build up

around centre-left or centre-right parties. The impact of the UK Independence Party (UKIP)

under the leadership of Nigel Farage on the Conservative Government of David Cameron

suggests that this particular assumption about an electoral consensus may be mistaken. Populist

politics – such as Beppe Grillo’s Five Star Movement in Italy or the Tea Party in the United

States – appears to have the capacity to change the electoral landscape. In Asia, ethno-religious

tensions are widespread, but they are intensified by migration: Buddhists and Muslims in Sri

Lanka and Thailand, Christians and Muslims in the Maluku Islands, and Muslims and Hindus

in India. In Japan, in the Shin-Okubo area of Tokyo, police have been involved in quelling

right-wing protests against foreigners. In June 2013, members of a movement called Zaitokukai

(Citizens against Special Privileges of Zainichi), which is opposed to what it sees as unfair

privileges given to Koreans (Zainichi), clashed with police and an anti-racist group (‘Shitback

Crew’). The leader of the protests Takada Makoto (alias Sakurai Makoto) was arrested, which

gave rise to further complaints that Koreans and anti-racists were not arrested. In Singapore in

2013, there has also been peaceful opposition on the streets against the government’s plans to

increase foreign migration into the city state. Although these are small incidents in societies that

are politically stable, they are indicative of underlying opposition to migration which is often

expressed as concern over jobs. However, the protests also exhibit xenophobic fears about social


The second range of common issues concerns the problem of long-term employment prospects

for young generations. This employment issue is another paradox. On the one hand, in countries with low fertility, governments are expressing serious concern about the shrinking of their

future workforce and hence their capacity for economic growth. This problem is acute in Russia,

Germany, and Japan. High fertility rates imply future patterns of consumption to drive the economy,

simply because young people need to consume housing, transport, domestic goods, and education.

To take one example, while employment was recovering in the United States by the early part of

2013, many of the jobs are in the low-wage, low-skill sector of the labour market, where employment does not offer the prospect of employment continuity with pension provisions and savings for

the future. In addition in most developed societies in the West (from Germany to the United States)

some 20 per cent of the labour market falls below the minimum wage. The problem for the future

of citizenship is how to absorb young educated people into the occupational system and at the same

time how to provide a satisfactory wage level for the unskilled and the semi-skilled. While economists often argue that immigration is good for the economy – not least because it raises taxes for the

state – it is difficult to promote the idea to the electorate. The struggle over the immigration bill in

the United States between Republicans and Democrats is an example of these conflicting interests

between the needs of the economy and the political constraints in Congress over the idea that illegal

migrants would be given amnesty. At the time of writing it is unclear whether Congress can forge

an agreement on migration that will offer some legal status to its illegal migrant population.

There is one final aspect of this problem worthy of attention. In most developed societies,

women have been far more successful in completing their education in terms of graduating


Citizenship: east, west, or global?

from college with recognized qualifications. The result of these developments lays the foundation for two forms of inequality that may be important for political alignments – generational

and gender resentment. In the United States this resentment from declining social strata was

manifest in the rise of the Tea Party, which recruited people both fearful of social change and

angry about the forces bringing it about. Their anger was directed at what they think are the

undeserving poor, the welfare freeloaders, and generally people who do not share their strong

sense of the Protestant Ethic. There was also a clear element of racism in their vocabulary for

President Obama who was often seen to be an outsider, if not a Muslim. They were also fearful

of what they saw as the unstoppable spread of the Shari’a as evidence of Muslims taking over

the country. Tea Party activists were typically elderly, white Protestants. Thus forty per cent

of Tea Party supporters describe themselves as evangelical Christians. The social conservatism of

their rank and file is also illustrated by their stand on a range of social issues such as gay marriage,

homosexuality, and migration. Illegal immigrants were seen to be freeloaders who were accessing

benefits to which they had no entitlement (Skocpol and Williamson, 2012: 69–70).

However, these issues also illustrate how much modern societies have diverged from the

model of citizenship in T. H. Marshall’s famous account of the British history of citizenship.

Marshall’s model described a set of contributory rights in which effective citizenship entitlement

was associated with gainful employment, public service (such as the military), and family formation through marriage and divorce. In my article ‘The erosion of citizenship’ (Turner, 2001),

I suggested that all three bases of citizenship were in decline. As we have seen with the decline

of traditional agriculture and heavy industry with deindustrialization, the pattern of work has

changed. Lifelong employment with secure benefits has disappeared for most of the working

class. Military service in defence of the nation has also been transformed with the growing

dependence on privatized services from security companies. Many societies in the West, in the

absence of conscription, are forced to offer significant inducements for young men to join the

military and hence the quality of the average recruit has declined. The heroic citizen-soldier has

often been replaced by recruits of dubious social and personal attributes (Kennard, 2011). But

the most significant post-Marshall development concerns the family.

Marriage as an institution has been much debated by feminist sociologists. On the one hand,

no-fault divorce, which allows couples to terminate their marriages without for example having

to prove infidelity, has weakened traditional family ties and, on the other hand, serial monogamy

suggests that marriage is still highly desirable. In the West, the acceptance of same-sex marriage

is perhaps the most controversial development. In the United States, there are some twelve states

in which same-sex marriages have been approved by legal decisions of the courts, and homosexuality is now accepted among military personnel. Against considerable religious opposition,

gay marriage has become legal across the world from the USA to New Zealand.While many gay

marriages will result in families insofar as children are adopted, these legal developments imply an

important change in the foundations of citizenship. One can expect these developments in the

West to also have an impact in Asian countries. For example in Singapore, there is a gay lobby

seeking recognition of homosexuality, and sexual experimentation is significant in Japan (Kong,

2011). In terms of sexual orientation, there are clearly differences between homosexuality in Asia

and in the West, but with globalization these cultural differences are becoming less significant

(Peletz, 2009). The underlying assumptions behind the Marshallian citizen – the white, male,

fully employed, heterosexual father – are increasingly globally irrelevant.

The third set of common problems relates to the environment. The idea of environmental

or green citizenship is a relatively recent development. The underlying assumption is that, with

pollution and the degradation of the environment, it is important to build a set of enforceable

rights that will offer citizens a right to clean water, fresh air, and reliable food (Dobson, 2003).


Bryan S. Turner

We need effective institutions to create environmental rights to protect vulnerable communities

from a variety of disasters – tsunamis, earthquakes, droughts, food crises, and so forth in a context

of global warming. Environmental citizenship is probably our best example that any discussion

of East and West is irrelevant, because risk society is global (Beck, 2009).

In any discussion of environmental rights it is difficult to distinguish between citizens’ rights

to a sustainable environment and human rights relating to the environment. Theoretical developments in sociology have found some parallel in the field of international law in the work of

Jonathan Charney, Louis Henkin and Christian Tomuschat. In this field of legal studies, scholars have recognized the emergence of legal provisions that bind nation-states to international

agreements that enforce behaviour with respect to certain key issues, where there are common

interests. For example these interests can be connected to rejecting slavery, serfdom, and genocide, or protecting scarce resources (such as water). Perhaps the most significant features of this

global juridical framework are described as erga omnes obligations, which are of serious concern

to all states, and these shared obligations are created by a common recognition of a set of fundamental human rights relating to human ills such as war, genocide and slavery. Historically legal

relationships between autonomous nation-states were framed in treaties that had only a limited

provenance, but international legal codes now recognize that the autonomy of nation-states is

often limited by multilateral treaties that address issues of common concern. Early legal regulation of common interests included laws to regulate access to the sea, international trade, and

the treatment of prisoners. The United Nations Convention on the Law of the Sea in 1982 was

a significant step in the recognition of mutual interests that were embedded in law (Charney,

1993). The development of legally binding relations within the European community has also

been seen as an important example of legal internationalism, and another example is the creation

of the European Court of Human Rights in 1959. These international legal relations have multiplied with juridical globalization in clear recognition of the need to develop a set of universal

standards to address concerns relating to major issues, especially the environment.

Many of these legal arrangements concern a mutual interest in protecting the environment

and they have serious implications for the autonomy of the nation-state. Charney (1993: 530)

notes that ‘the enormous destructive potential of some activities and the precarious condition of

some objects of international concern make full autonomy undesirable, if not potentially catastrophic’. Where there is recognition that a common good is threatened, there are compelling

reasons for legally enforced cooperation between states. So-called jus cogens or ‘compelling law’

is a pre-emptory legal principle that recognizes binding arrangements on states, irrespective of

their consent. Where there is an obvious need for common action over a shared problem (for

example the dumping of nuclear waste), it is possible to argue that there exists a ‘community

necessity’ over which there should be binding agreements. Unsurprisingly political contestation

typically takes place over whether there is a ‘community necessity’, and the alternative is to

accept a realist view of international politics as a competitive field of nation-states operating in

terms of their geopolitical interests. Nevertheless there is some agreement that the globalization

of law is already recognition of some common interests that transcend East–West differences

(Teubner, 1997).

The debate about environmentalism and natural disasters raises an interesting question about

whether ‘natural disasters’ are in fact always ‘social and political disasters’. Margaret Somers’s

Genealogies of citizenship (2008) has had an important impact on modern citizenship studies. In

her study of the Katrina hurricane disaster in the United States, she argues that the causes of the

crisis and its aftermath had more to do with political failures (for example the failure to manage

the levees) than with natural causes such as the severe weather. Similar arguments emerged in

the United States after the flooding of New Jersey and New York after Storm Sandy in 2012.


Citizenship: east, west, or global?

The same perspective on ‘natural’ catastrophe would apply to earthquakes in China, where

inadequate building construction and political corruption may have more significant consequences than actual earthquakes. Other examples might include the Japanese tsunami, where it

is claimed that there were faulty design problems with its nuclear plants and that the crisis was

worsened by inadequate planning. Failure to anticipate and manage disasters is obviously not

confined to any particular society. Global warming clearly undermines any notion that climatic

catastrophe can be categorized in an East–West binary.

To conclude this section of my discussion, we can say that the underlying issue in the changing nature of citizenship is related to globalization and specifically to the question of the sovereignty of the state.The emergence of citizenship in the West was closely tied to the consolidation

of the nation-state on the one hand and to the rise of the working class on the other through

the nineteenth and early twentieth centuries (Bendix, 1964). Similar nation-building processes

behind the construction of citizenship were taking place in Japan after the Meiji Restoration and

in Turkey with Kemal Atatürk’s secularizing nationalist strategies in the 1920s. There is now a

widespread view that the modern state is far more porous with ambiguous boundaries. Evidence

for this perspective can be drawn from the growth of legal pluralism, in which legal sovereignty

gives way to the influence of human rights, international law, commercial law, and in some cases

the revival or recognition of customary law. Recognition of legal pluralism through the continuity of customary law was championed by sociologists like Eugen Ehrlich in Fundamental principles

of the sociology of law (2002) which was first published in 1936. In documenting the continuity of

customary law courts for dealing with the affairs of the peasantry in the Ukraine, Ehrlich offered

an alternative to state-dominated views of law in the work of Max Weber and Hans Kelsen. In

jurisprudence, Kelsen was famous for his ‘Pure Theory of Law’ in which he argued, against both

reductionism and relativism, that law was a deductive, autonomous system of legal norms whose

authority was guaranteed not by religion, morality, or the state but simply by other legal norms.

Consequently Ehrlich’s sociological views are still contested by legal scholars who argue that

laws without state backing are in fact merely customs, but the growth of international human

rights does nevertheless suggest an erosion of state sovereignty, which in turn has consequences

for citizenship.

The legal assumptions of both Weber and Kelsen are challenged by the apparent erosion of

state sovereignty, which is illustrated, for example, by the problem of controlling illegal migration. The porous nature of national borders is therefore illustrated by the problem of documenting both legal and illegal migration. For example Kamal Sadiq (2009) in Paper citizens provides

an insight into how illegal migration in India, Pakistan, and Malaysia often leads incrementally

and imperceptibly through de facto denizen status to actual legal citizenship. Criticizing what he

calls the ‘distinguishability assumption’ in conventional citizenship studies, that host societies have

well documented populations, he shows that traditional views of citizenship have failed to grasp

the important role played by a variety of documents in the informal pathways to ‘documentary

citizenship’. In Asia and Africa, these illegal flows of migration have caused significant social and

political disruption in receiving or host societies. Nation-states which begin with a clear and

exclusive constitutional definition of formal and legal citizenship often over time acquire migrant

populations that manage to accumulate documents resulting in the acquisition of citizenship that

consequently dilutes constitutional commitments to exclusive national citizenship. Casual denizens

over time can become bona fide citizens.

What Kamal Sadiq calls ‘documentary citizen’ – the challenge to register citizens through

birth certificates, social security numbers, and a credit history – typically results from the fact

that nation-states often to fail to provide basic registration of their citizens. In the first instance,

the provision of birth certificates to infants is a crucial step towards ultimate recognition of


Bryan S. Turner

citizenship, but in Indonesia only four out of ten children receive a birth certificate, and in

Bangladesh birth registration rates are as low as seven per cent. Inadequate registration is often

caused by lack of access to registration offices, expensive fees, and lack of understanding of the

basic legal requirements. In addition, marriage registration is not common in many traditional

Muslim communities in South and Southeast Asia. Absence of registration among ‘rural and

poor people creates an environment of corruption and manipulation, where illegal migration,

trafficking, and human smuggling become possible’ (Sadiq 2009: 97). For instance, traffickers

can falsify the birth dates of underage girls to allow them to enter the modern world of prostitution and slavery. This registration vacuum is filled by ‘paper citizenship’, in which migrants

acquire a documented, if falsified, identity. Illegal or quasi-citizenship is characteristically a

function of informal immigrant networks which subvert the formal gate-keeping activities of

the state bureaucracy, the existence of blurred or fuzzy membership, and the complicity of state

functionaries (civil servants, border guards, registration officers, local police, and others) who

are willing to conspire with the illegal acquisition of documents. Diverse corrupt practices and

faulty institutions allow illegal migrants fraudulently to acquire real or fake driving licences,

bank accounts, birth certificates, land deeds, utility bills, state identity cards, passports, electoral roll certificates, vendors’ permits, school diplomas, and so forth. Adequate documentation,

especially birth certificates, is obviously not confined to Third World societies. The United

States is basically unable to seal off its borders with Mexico despite massive investment in policing and surveillance. In the search for security, many societies are building walls and fences

around their borders – Saudi Arabia, Israel, the United States, Paraguay, and others – to create

‘enclave societies’ to exclude the unwanted, but in most cases such measures are only symbolic

(Turner, 2008).

Conclusion: mapping the future

Societies may have very different legacies and resources by which to respond to common challenges, but the problems of modern societies look remarkably similar and increasingly interrelated.

Given the challenge of the twenty-first century, how will the legacies of citizenship survive? Does

citizenship have a future?

The neoliberal economic revolution since the late 1970s had a worldwide impact on the relationship between effort and entitlement, in which there was a new emphasis on the contractual

nature of the relationship between citizen and state. What we can call ‘market’ or ‘consumer

citizenship’ gained in significance against both ethno-nationalist and social-welfare models.

In response to a general profit crisis of the late twentieth century, welfare entitlements were

curbed, personal and corporate taxation was reduced, and pension provisions were privatized

or eroded (Clarke et al. 2007). The new economic regime also promoted bank deregulation,

currency speculation, and high-risk financial instruments. These changes are often attributed

primarily to the strategies adopted by Ronald Reagan and Margaret Thatcher in the late 1970s

and after. Reagan had come to office on the back of disillusionment with Democratic liberalism

and managed to revitalize Republican fortunes by promoting ‘an outgoing, energizing, even

sensuous ideal of a beautiful, limitless American future’ (Wilentz, 2005: 137). Likewise Thatcher

was able to transform traditional, stuffy, land-owning conservatism into a radical commitment

to entrepreneurship. The problem for the British Labour Party was its ‘failure to keep abreast

with the concerns and aspirations of a new middle class, without whose support it could never

again be elected to office’ (Judt, 2005: 546). In retrospect it is clear that through her radical

policies ‘Margaret Thatcher may have destroyed the Conservative Party but she must be credited with the salvation and re-birth of Labour’ (Judt, 2005: 545). This fact was borne out by


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