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SAWITRI SAHARSO AND
DOUTJE LETTINGA
Contentious Citizenship:
Policies and Debates on the
Veil in the Netherlands
Abstract
In this contribution, we present an analysis of the regulations and
public debates regarding the veil in the Netherlands between 1999
and 2006, thereby exploring the idea that the framing and regulat-
ing of veiling reflect national traditions of citizenship. In line with
our hypothesis that the legacy of pillarization makes religious iden-
tity claims highly legitimate in the Netherlands, we found regu-
lations to be accommodating. In the Dutch legal debate, the veil
was mainly discussed in terms of neutrality. Sustaining our hypoth-
esis was also the relatively large presence of Muslim(a)s in the
public debate and public opinion being in favor of accommo-
dation. Yet, when the claim for recognition concerned headscarves
in the police force and judiciary or the Islamic face-cover (niqab
and burqa) the Dutch reacted more divided. A shift has occurred
over the years, in that gender equality frames have come to res-
onate more successfully in the public debate, and with a stronger
association of the veil with concerns about social cohesion, inte-
gration, and the moral limits of public behavior. Our findings
suggest that the Dutch multicultural citizenship tradition is under
pressure and contingent on power relations between political
Winter 2008 Pages 455–480 doi:10.1093/sp/jxn020
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parties and political events on a national and international level.
To account for this gradual shift over time we suggest a historiciz-
ing theory of citizenship models.
Introduction
Since the early 1990s, in the Netherlands and other
European countries heated debates have emerged about head and
body covering of Muslim women in the public sphere, particularly
in institutions such as schools, the civil service, and in courts, and
different countries have found different ways of regulating the veil.
1
In this paper, we present an analysis of the regulations and public
debates regarding the veil in the Netherlands between 1999 and
2006. We have chosen this context and period to test the premise
whether the Netherlands’ multicultural tradition of citizenship is
able to explain Dutch rules and debates on the veil.
How can the veil as a manifestation of Islamic religious culture
evoke such different policy reactions among countries that all consider
themselves as liberal democracies? In a liberal democracy as Bellamy
aptly summarized it: “Equal rights to liberty are secured through uni-
versal, general laws produced by a constitutional framework, demo-
cratic institutions and an economic market embodying the requisite
balance between freedom and equality” (Bellamy 1999, 1). Liberal
principles, however are generic, and therefore there is a range within
which they can be interpreted (see Carens 2000), from which follows
that different liberal states can have different understandings of the
liberal tradition leading up to different institutional arrangements for
dealing with diversity. This is indeed what happened as European
countries have responded differently to the presence of migrants. In
order to account for these national differences various authors (e.g.,
Castles 1995; Entzinger 2005; Koopmans et al. 2005; Rex 1997) have
developed typologies to group countries according to the degree they
grant migrants access to equal citizenship and the degree they accom-
modate cultural group difference. While the typologies vary somewhat
in the terms they use and the way they classify countries as belonging
to a certain type, they share the assumption that there exist nation-
specific models of integrating migrants into the national community.
As this research has convincingly shown that claim-making by
migrants and the societal reaction to these claims is neither similar
across countries, nor does it randomly vary, we expect that the idea of
a nation-bound tradition of citizenship may also be helpful in account-
ing for the regulation and framing of the veil in the Netherlands.
Our expectation therefore is that countries have national political
traditions that determine how liberal democratic principles are
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institutionalized in regulations on the veil. Moreover, we also expect
these traditions to steer the content of the public debate and deter-
mine which voices get access to the debate. At the same time we
realize that national traditions may change over time, especially in
the light of wider processes of globalization (and the related spread
of images and narratives across borders), EU-integration (and the
expected convergence of national policies), and migration itself.
After first sketching, the theoretical ideas that have informed the
paper, we will present our findings on the Dutch framing and regu-
lating of the veil. In the concluding section, we will take up again
the question of the usefulness of citizenship models and offer some
tentative explanations for the shifts over time that we detected.
Theoretical Approach: National Models of Interpreting the
Liberal Tradition
The literature on citizenship models commonly differentiates
between three ideal–typical models, in our terms a civic assimila-
tionist, an ethno-cultural, and a multicultural model. While France
is considered as the prototypical example of a civic-assimilationist
citizenship model, Germany is believed to represent an ethno-
cultural model and the Netherlands can be characterized as a multi-
cultural model. Both France and the Netherlands uphold the ius soli
principle for acquiring citizenship (on grounds of birth in the
national territory rather than merely on grounds of ethnic descent)
(Koopmans et al. 2005). But France’s strong egalitarian notion of
citizenship implies that citizens should exist in public life as individ-
ual members of the Republic only, instead of as members of various
communities. It therefore expects its citizens to assimilate in one
uniform nation, speaking the same language, and subscribing to
underlying common republican notions. “Laicite
´,” the French
notion of secularism, is also in line with this Republican uniform
concept of citizenship, because it aims to refer religion to the private
sphere. Although the state does meet with various centralized reli-
gious councils, including an Islamic council, it does not offer official
state support for religious institutions, because this would be incom-
patible with its aim not to differentiate on grounds of religion or
other particularities (Laurence and Vaisse 2006). The Netherlands,
on the other hand, has an elaborate system of representation of del-
egates of ethnic and religious organizations and lavishly subsidizes
organizations of migrant and religious communities. Under the
system of pillarization, religious communities (and the socialists and
liberals) had, and to a large extent still have, the right to set up their
own institutions, such as schools, hospitals, and broadcasting
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companies. Its corporatist (pillarized) model of secularism also
means that the state finances schools, social welfare activities, or
broadcasting agencies of religious communities, without interfering
with the religious life of the adherents (Bijsterveld 2005). Its pluralist
conception of citizenship thus grants a large range to live according
to (and to be recognized on grounds of) particular identities and tra-
ditions of groups in the public sphere. Germany, lastly, had until
2000 high barriers for non-Germans to acquire German citizenship
and required that they proved commitment to the German cultural
realm. And although Germany resembles the Netherlands in that
both countries have a corporatist model in which responsibility over
central state tasks, such as education, is shared with religious bodies,
there is a large difference in that Germany with its ethno-cultural
tradition of citizenship denies Islam the prerogatives that
Christianity and Judaism receive, because Islam is not granted the
status of recognized religion (Duyvene de Wit and Koopmans 2001).
Pillarization, on the other hand, is a model in which religion is
highly visible in public life, yet combined with evenhandedness
between religions. In the heydays of pillarization, the different
pillars developed into strong power blocs. Evenhandedness between
the religions was necessary to keep peace between them.
Following the theory on citizenship and migration, one would
expect more tolerance toward the veil in the Netherlands than in
either Germany or France. The regulations in the three countries
indeed seem to confirm this. In France, the public reaction by and
large has been prohibitive, resulting in the March 2004 law that
forbids students in schools to wear any “signs or clothing, which
conspicuously manifest students’ religious affiliations” (Article 1 of
the law quoted in Scott 2007). In Germany, some eight states forbid
the wearing of the Islamic headscarf for teachers, whereas in the
Netherlands it is allowed both for teachers and students to wear a
headscarf. Yet, the context of these cases is more complex than is
represented. Consider Germany, for example: while five states ban
the headscarf but allow the crucifix, justifying this by arguing that
Christianity is constitutive for German national culture, thereby con-
firming the ethno-cultural tradition of citizenship, three other states
governed by leftist cabinets ban all religious symbols from public
office, with arguments resembling French laicism.
2
Also, regulation
in the Netherlands is not only accommodative.
Regulations on the Veil in the Netherlands
In the Netherlands, conflicts about the veil are usually brought
before the Commission on Equal Treatment. In nearly all the cases,
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most of them concerning the headscarf, the Commission ruled that
it was not justified to prohibit veiling, because it contravenes Dutch
anti-discrimination law. The Commission considers veiling as an
expression of a Muslim woman’s religious conviction and as such
protected by the right to freedom of religion. The Commission
argues that freedom of religion is a fundamental right that can be
restricted only if it is demonstrated that the aim to restrict the exer-
cise of this right is legitimate, and that a ban meets the requirements
of proportionality and subsidiarity. “Legitimate” means that that
the aim (of a ban) must be weighty and nondiscriminating, while the
latter two requirements mean that the same goal cannot be reached
with another measure that is less discriminating (as a restrictive
measure is always, yet not necessarily unlawfully, discriminating)
and that the measure is proportional to its aim. As these conditions
are usually not met, the Commission generally rules in favor of the
Islamic woman concerned (Judgment 2003-40 Section 5.9 cited in
Saharso 2007, 519).
Yet, it is relevant, first, to differentiate between institutional con-
texts. We will discuss some exemplary cases to demonstrate that it
matters for the regulation whether it concerns headscarves in the
public school, the police, or the courtroom.
In 1998, a conflict was brought before the Commission between a
public primary school and a trainee who refused to take off her
headscarf in the classroom. The school brought forward several
arguments for its policy on headscarves, among them public neu-
trality, but also the argument that it wanted to protect Islamic girls
from liberal homes against the pressure from their more stringent
fellow-believers. This gender argument was not taken into consider-
ation by the Commission, but the argument that a headscarf contra-
venes the neutrality of the public school was. Due to pillarization,
the Netherlands has a system of public and faith schools. The public
school is open to all, believers and nonbelievers. Not allowing a
teacher to wear a headscarf would oblige her to seek employment in
Islamic schools only. This would unfairly restrict her job opportu-
nities, as adherents of other religions could work on both denomina-
tional and public schools. This would amount to discrimination on
the basis of religion unless it could be shown that taking off her
headscarf was a necessary job requirement. The Commission judged
that the fact that the trainee “believes in a religion and expresses this
by wearing a headscarf does not preclude her having an open atti-
tude and being capable of teaching in accordance with the character
of the school as a public educational institution” (Judgment 99-18:
3–4,cited in Saharso 2003, 15). Pillarization permits the presence of
religion in public institutions. This includes Islam as all religions
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must be treated equally. Therefore the headscarf was not considered
as infringing on the neutrality of the public school. Therefore also, it
was not a job requirement that the trainee take off her headscarf
and consequently the Commission ruled in favor of the trainee.
3
In 2000, a conflict arose which concerned Islamic headscarves for
court officers. The cause was a local court’s refusal to hire a vice
assistant-court clerk who refused to take off her headscarf during
public court sessions. The court argued that headscarves threaten
people’s trust in the neutrality of the courts (see NRC Handelsblad,
April 28, 2001). The clerk brought her case before the Commission
on Equal Treatment, which recognized that in this specific function
it is more important that any appearance of partiality be avoided,
yet judged that in a multicultural society to appear neutral court-
clerks need not hide all expressions of personal belief (CGB
2001-53). This time, however, the Justice Minister intervened declar-
ing that he believed court personnel should not actively manifest
their beliefs in the courtroom. The National Board for Jurisdiction
agreed almost unanimously that religious symbols should not be
allowed in the courts (see Verhaar and Saharso 2004).
Also in 2000, the national board of chief commissioners of police
launched a plan to accommodate religious headgear for uniformed
police officers, but dropped it again because of the public protest it
evoked (see Saharso and Verhaar 2006). A few years later this same
board of chief commissioners issued an advice that all police staff
having public contacts should strive for “lifestyle neutral” appear-
ance.
4
Two years later it sent its advice to the Minister of Interior
Affairs,
5
asking him to impose a uniform policy for the whole police
force in the Netherlands. When consulted by the Minister, the
Commission on Equal Treatment opined that the police office (like
courts) differs from regular public office jobs and therefore clothing
rules can be more legitimate to be recognizable and to appear impar-
tial. It argued, however, like in the court case, that this does not
necessarily require abstaining from expressing any personal belief
and it advised that the Minister carefully consider the consequence
of indirect discrimination that a requirement of lifestyle neutrality
would have for Muslim women (CGB 2007). The Minister’s
decision is still pending, yet the majority of the parliament has
expressed that it wants to forbid religious symbols in the police
force.
6
Hence, in institutional contexts such as the police or the
court, accommodation of headscarves is more restricted than in the
public school.
Second, another difference that should be taken into account is
the way of veiling. In 2003, the debate about religious symbols in
schools flared up again, when two students of a public secondary
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school in Amsterdam insisted on wearing niqabs this time, a
garment that covers the face. They said they wore the niqab for
avoiding the male gaze, but they were willing as they were being
educated to become school teachers at kindergartens to remove their
niqabs in class or when working with women and children. But the
school objected and the two girls brought their case to the Equal
Treatment Commission. The Commission decided that a general
dress code that forbids face-covers disproportionately harms one
particular group in society and is thus a form of indirect discrimi-
nation. But this time, the nine experts agreed that the school had
objective grounds for justifying the dress code: niqabs hamper effec-
tive communication between teacher and pupils; hinder identifi-
cation of people in and around the school necessary for
guaranteeing public safety; and jeopardize the school’s duty to
prepare pupils for jobs that fulfill a social need. Therefore, the
school girls lost their case. In two other niqab cases, however, the
Commission on Equal Treatment ruled in favor of the veiled woman
(see Loenen 2006).
7
On October 10, 2005, during a parliamentary debate on the pre-
vention of terrorism, the right-wing politician Geert Wilders
8
sub-
mitted a motion to ban the burqa in public.
9
The minister of
integration, Rita Verdonk, subsequently installed an expert commis-
sion to study the legal possibilities and social consequences of such a
general ban. This Commission launched its findings one year later in
a report (Vermeulen et al. 2006), in which it argued that such a ban
infringed upon the nondiscrimination principle and the right to
freedom of religion and freedom of choice that liberal democracies
should foster. The Commission members considered the arguments
that burqas are women-unfriendly and may scare people, yet opined
that these were insufficient grounds to curtail these liberties. The
Commission also advised against the introduction of a more gener-
ally formulated ban on all face-covers in the public sphere, because it
would still indirectly discriminate a particular group (of orthodox
Muslim women). Only in semipublic domains (such as public trans-
portation where citizens cannot avoid meeting others) could a ban be
legally acceptable for reasons of maintaining public safety and limit-
ing the risks of attacks.
10
Although the parliament had not received
the Commission’s report, it accepted on December 20, 2005 with a
majority of votes the proposal for a general public ban on burqas
(TK36, and in a second round on October 24, 2006, TK16).
We see that conflicts over the veil in the Netherlands are generally
decided in favor of the Islamic woman, and even in the case of the
burqa the legal experts advised against a ban. Another characteristic
of the legal debate is that it centers on the neutrality and
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nondiscrimination principle. How these principles are interpreted
seems to be informed by the Dutch pillarized history of organizing
state– church relations. In the Netherlands, therefore, educational
neutrality does not require that teachers take off their headscarf,
except for certain institutional contexts, and a ban on headscarves is
considered as discrimination on the basis of religion. Another
remarkable feature of the legal debate is that gender equality argu-
ments do not play a role in the legal debate, not even in the niqab
case, where the two pupils explicitly explained their reasons for
wearing niqabs in gendered terms. Also in the burqa case, the legal
commission rejected the argument that burqas are woman-
unfriendly as not weighty enough (see also a response by Verhaar
2006). We will account for this unresponsiveness to gender equality
arguments later in the paper. For now, we confine ourselves to the
conclusion that the way claims to veil are dealt with legally reflect
the ideal–typical model of multiculturalism and secularism as elabo-
rated in the introduction. Yet, we also observed contestation among
legal and political actors and saw that the extensiveness of the right
to cover is dependant on the type of covering and on the insti-
tutional context.
Public Debates Concerning the Veil
The public debate about integration issues in the Netherlands has
dramatically intensified since 1995. Dutch policies and practices of
multiculturalism have increasingly been contested, which went hand
in hand with a problematization of Islam as hampering integration
(Roggeband and Vliegenthart 2007; Sniderman and Hagendoorn
2007). Muslim women take a central place in this debate, in which
multiculturalism is being played out against women’s rights (Prins
and Saharso 2008; Roggeband and Verloo 2007). One would expect
therefore to see this change also reflected in the debate on the veil.
What does ten years of public debate on the veil reveal?
The aim of our newspaper analysis was to find out who entered
the public debate about veiling as represented in the newspapers
(mainstream or minority actors? men or women?); which type of
Islamic clothing in what particular domain caused conflict; how was
veiling framed as a social problem; which counter-frames were
employed to construct political alternatives; and whether this differs
over time. In this way, we tried to reconstruct the dominant and
alternative frames that have been used in the Dutch veil debate and
that may have influenced policy making with regard to female
Islamic clothing. We also tried to detect whether different types of
framing were used with regard to the burqa (and the niqab) or to
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the headscarf and how this may have influenced the representation
of Islam as a singular religious culture.
Frame analysis is a systematic approach of discourse analysis that
has been applied to study social movements (Snow and Benford
1992), media documents (Ferree et al. 2002), policy texts (Bacchi
2005), and to do gender impact assessment (Verloo and Roggeband
1996). A frame is a specific problem-representation. We have con-
structed different frames by coding the articles according to the defi-
nition of the problem (diagnosis), the proposed solution to the
problem (prognosis), and the call for action (who is responsible for
solving the problem) (Snow and Benford 1992), while also using
Stone’s (Stone 1989) idea of causality (who is to blame for causing
the problem).
Our media analysis ranges from 1998 (when the first controversial
conflict took place about the teacher – trainee wearing a headscarf )
until 2007. We scanned for articles on the veil issue in five main
national newspapers in the Netherlands. These newspapers were in
the order of size: De Telegraaf with a reach of 16.2 percent of all
people aged thirteen years and older in the Netherlands; Algemeen
Dagblad (AD) with a reach of 11.5 percent; de Volkskrant with a
reach of 6.2 percent; NRC Handelsblad with a reach of 4.2 percent;
and Trouw with a reach of 2.5 percent.
11
While all have a nation-
wide scope of coverage and readership, the first two are more
tabloid newspapers, whereas the latter three are known as quality
newspapers. We searched with keywords like “headscarf,” “veil,”
“burqa,” “niqab,” and “chador” (and derivations thereof) in the
online search-engine LexisNexis.
12
This search yielded 2250 articles
that contained at least two times one of those keywords for the
period from 1998 until 2007 (see appendix, Table A1).
13
We chose
this search criteria of a minimum number of keywords to seize those
articles that had enough relevant content to qualify. A total of 1676
of those articles concerned the headscarf and 749 (also) the face-
cover (niqab, chador, and burqa). We see that particularly since
2003, the year in which the niqab-case in the public school was
brought forward to the Dutch Equal Treatment Commission, face-
covers enter the debate as new public concerns. We considered only
articles that contained a clear and elaborated opinion about the veil
issue in the Netherlands (a claim). Most claims were expressed in an
interview, editorial, or opinion letter, but we also took into account
extensive quotes about the issue in a reportage about a related topic.
Articles, however, that only mentioned veiling in a descriptive way
(e.g., in a reportage about Afghanistan) were discarded. Hence, on
the one hand not all articles that our search yielded contained
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claims, while on the other hand one article could contain more than
one claim when more opinions were voiced.
In a first round of content analysis, we used a customized data-
base program (Access) in which we entered and coded all claims
made between 1999 and 2005, according to the speaker (in terms of
organization, party, gender, ethnicity/religion, and clothes) and the
ideas that their claims concerned. In a second round, we clustered
those ideas into three categories of frames, each of which contained
subframes that indicate a direction and/or a stance regarding the
veil issue (pro/contra accommodation).
To make this extensive content analysis feasible, we limited our
research to one national newspaper, NRC Handelsblad. Its readers
are mainly older (79.9 percent aged thirty-five years or older), highly
educated (66.8 percent have had higher vocational training or uni-
versity), and well to do (62.2 percent have an above-average
income).
14
We selected NRC Handelsblad not only because a sub-
stantial part of the debate took place in this newspaper (see appen-
dix), but also because as a quality newspaper it allows for more
diversity than tabloids (Vliegenthart 2007, 50).
We selected four years in which relevant conflicts took place: (a)
1999: headscarf conflict between trainee and public school; (b)
2001: police plans to design uniforms with headscarf and court-clerk
wants to wear headscarf; (c) 2005 and 2006: several cases concern-
ing the niqab and the motion to ban the burqa in public space. In
addition, we zeroed in on the public debate about the burqa and
other face-covers which spanned the period from October 10, 2005,
when Geert Wilders submitted his controversial motion to ban the
burqa until July 1, 2007. As the burqa debate spanned a relatively
short time period, we were able to analyze four national newspa-
pers.
15
Before we present our findings, a word of caution: the media
cannot be considered as themselves not exerting influence on pat-
terns of claim-making. We do not know the extent to which
measured patterns of claim-making are the effect of selection pro-
cesses in the media and it is with this undetermined relationship in
mind, for which we at this stage cannot account further, that our
findings should be read.
Who gets a Voice?
In total, we found twenty-four relevant claims for 1999, thirty-
seven claims in 2001, twenty-six claims in 2005, and twenty-seven
claims in 2006 in NRC Handelsblad about veiling in general.
Seventeen claims specifically concerned Islamic face-covers. On the
burqa, we found in the other three newspapers another twenty-five
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claims. In 2001, the public debate focused on headscarves in the
police force and the court. The main participants in the debate were
Dutch majority men, with more than 40 percent of the claims. At 20
percent, approximately as many Muslim women
16
participated in
the debate as Dutch majority women. Other actors in the debate
were human rights and anti-discrimination bodies, organizations
speaking on behalf of migrants, and some Muslim men (see appen-
dix, Table A2). Remarkably, we see that in 1999 only two Muslim
women were given voice in the debate, whereas in 2001 this number
doubled five times. Hence, the increasing politicization of the issue
went together with an increase in Muslim women’s voices.
However, whereas non-Muslim men and women participate
actively in the debate (by writing letters to the editor or pencilling
an opinion piece), most Muslim voices only entered the public
debate by being quoted in a press statement or street-interview. This
reveals that Muslim voices were not represented through opinion
pieces and letters but rather were referenced within articles in news-
papers. This raises the question on which voices the media wanted
to be heard (cf. Ferree et al. 2002; Hobson 2003, on recognition
struggles and media selection). It was apparently the pro-headscarf
Muslim voices as more than 80 percent of the Muslim women who
were interviewed or quoted in the printed media defended the right
to cover.
In NRC Handelsblad, non-Muslim actors in the debate had more
diversified positions. In general, a slight majority of all non-Muslim
actors were against accommodating the practice of veiling (57
percent). But looking at the specific domains that the claims con-
cerned, we see that more people defended the right to cover in the
educational realm (54 percent), whereas in the judiciary and police
force, we see more majority actors speaking out against headscarves
(also 54 percent). In particular, men with an ethnic Dutch back-
ground were against accommodating headscarves in the latter two
domains (all nine of them spoke out against this right). Non-Muslim
women were divided in their reactions: about as many letters to the
newspaper were published from women who were in favor of head-
scarves (regardless of the domain) as from women who were against
it. When taking all actors together, both Muslim and non-Muslim
Dutch, a slight majority of 57.7 percent defended the (unspecified)
right to cover.
In the burqa debate, as it was covered by our four newspapers,
we also found Muslim voices to be relatively well represented for the
designated period: 30 percent of all actors had an Islamic back-
ground (see appendix, Table A3).
17
It should be noted, however,
that among the Muslim women participating in the debate, not a
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single one wore a burqa herself (at least, this did not become clear
from the articles analyzed). And again, non-Muslim men dominated
the discussion. A great majority of all actors were against a general
ban on burqas (80 percent in NRC Handelsblad and 75 percent for
all newspapers), but most particularly those with an Islamic back-
ground. Some actors, however, defended a middle ground position
by arguing that face-covers (so not only burqas, but also other gar-
ments that conceal the face) could be forbidden in specific domains
and in specific situations.
Nevertheless, as we will discuss below, it is clear that despite the
growing visibility of Muslim voices in the debate their discursive
opportunities to influence its tone and direction has become more
limited due to a shift in frames.
Which Issues were Discussed and How were they Framed?
Using a similar frame analysis sheet for each article, and compar-
ing those afterwards, we were able to construct three clusters of
frames: two different state – church frames; three integration frames,
and two different gender frames. In 1999 and 2001, the debate
focused mostly on the neutrality principle, making the two frames of
the first cluster most dominant. From 2001, gender started playing
an increasing role in the debate, and resonated most successfully in
2005 and 2006, together with the integration frames.
State– church frames Integration frames Gender frames
Strict secularism Participation and nondifferentialism Victimization
Open neutrality and
freedom of religion
Participation and nondiscrimination Autonomy
Islam as a threat
In 1999 and 2001, the debate focused on the question whether
headscarves should be accommodated in, respectively, the school
and the police force and judiciary. The debate was about the
meaning and content of neutrality in a Dutch context. Those using a
open neutrality and freedom of religion frame argued that the right
to cover is about religious freedom and does not conflict with the
principle of neutrality. This was occasionally sustained with a par-
ticipation and nondiscrimination frame. In this frame, the diagnosis
was that Muslim women wearing headscarves are discriminated
against by dominant society and the state, or mainstream society, is
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called upon to create space for diversity so that Muslim women
can participate in society. With regard to the educational realm,
most Dutch argued in favor of accommodation and used the open
neutrality and the participation frames to support their claim. They
said, for example, that a public school should reflect the plurality of
Dutch society and create space for diversity by allowing teachers and
pupils to wear a headscarf, which was not thought to jeopardize the
impartiality of the teacher. One actor, Liesbeth Mulder of the
Humanistic Union, wrote that it is not the headscarf, but someone’s
attitude that should count whether she is unfit for the function of
a teacher.
18
The same frames of open neutrality and nondiscrimination were
used in the 2001 debate to plead for the right to wear a headscarf in
the police force and the judiciary. Again, those using these frames
did not think that the impartiality of these civil functions would be
jeopardized by the headscarf: “the intended objectivity of the court
will, on the contrary, be illustrated by the extent to which it reflects
the multicultural society.”
19
Two rather famous Dutch opinion-
makers with an immigrant background (Anil Ramdas and
Abdelkader Benali) wrote a letter to the newspaper in which they
questioned the idea that civil servants should not show their particu-
lar beliefs in order to uphold the neutrality of the state: “the civil
culture prescribes a tie and suit for men and a robe for women with
a suit-jacket. But is that civil norm really ‘neutral’ (...) or an impo-
sition of the power of petty bourgeoisie?.” According to them, a par-
ticular posh accent, like white male Dutch judges are assumed to
have, is also to a cultural identity. Using the open neutrality frame
in combination with the participation and nondiscrimination frame,
they argued that the idea of strict secularism only serves to maintain
an unequal and unfair power-balance between majorities and min-
orities and hence that headscarves should be allowed to enhance the
equal participation of Muslims in Dutch society.
20
Against this, opponents of headscarves predominantly brought in
the strict secularism frame and a participation and nondifferentialism
frame. People arguing from the strict secularism frame maintained
that headscarves (or religious symbols) are ostentatious symbols that
conflict with the separation between church and state. They also
recognized the integration of Muslim women in Dutch society as a
problem, but located its cause not in Dutch society but in Muslim
women’s choice to veil. In the participation and nondifferentialism
frame, the headscarf is a symbol of difference and segregation that
the state cannot allow, let alone institutionalize, if it wants to main-
tain an egalitarian and cohesive society. The opponents argued that
all public officers, regardless of their background, need to step back
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from their religious ideas in order to protect the neutrality and
impartiality of the state.
As already mentioned, most participants in the newspaper debate
did not object to headscarves for pupils. Those who did (including a
teacher of Turkish-secular background) often used what we called an
Islam as a threat frame that sees veiling as a symbol of radicalism and
of a cultural threat to Western or Dutch values and sometimes a victi-
mization frame in which veiling is seen as a symbol of patriarchy and
Muslim women are believed to be forced to veil by their community
or husbands. These actors said that (parents of) pupils or teachers
who refuse to remove headscarves were displaying fundamentalism,
by insisting on propagating their beliefs and related values of gender
inequality. By framing this as conflicting with Dutch constitutional
rights and freedoms, actors argued for assimilation of Muslim citizens
not to a dominant ethnic culture but to supposedly universal norms
and values.
21
Also, secularism was framed as a constitutional duty
that Muslim women needed to respect if they wanted to be citizens of
“our” country or if they wanted to become civil servants.
22
Hence,
they would use the Islam as a threat frame in their diagnosis (by
representing the veil as a cultural threat), and the nondifferentialism
frame in their prognosis (by pleading for a ban on all religious
symbols and not only headscarves, arguing that a neutral appearance
is a duty that holds for all Dutch equally).
From 2001 onwards, the victimization frame appeared more fre-
quently in the debate. Opponents of veiling stressed the importance
of “drawing a line” to multiculturalism by claiming that headscarves
are symbols of oppression that are incompatible with the Western
value system. Paul Cliteur, for instance, a philosopher of law, wrote
three separate letters to the newspaper in which he indicated that
multiculturalism is bad for women, referring to a famous essay by
Susan Moller Okin to support his claim.
23
Often such claimants
made references to gender-unequal practices in countries such as
Iran and Afghanistan to support their stance that multicultural rela-
tivism would eventually give leeway to fundamentalists undermining
secular democracy, thus combining the victimization frame with an
Islam as a threat frame.
However, various actors of the majority population and Muslim
women contested this frame by using an autonomy frame. In this
frame, it is claimed that veiling should be regarded as a matter of
individual choice, and that as long as Muslim women are not forced
to cover, veiling is compatible with gender equality and with Dutch
society. Several Muslim women claimed that their headscarf or
face-veil actually provided them a sense of freedom and strength,
while some non-Muslims claimed that it could be regarded as a
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symbol of emancipation rather than of oppression, because it
enabled Muslim women to participate in Dutch society without
betraying their own community.
24
Fatima Elatik, a local councilor
for the Social-Democrat party in Amsterdam, who herself wears a
headscarf, emphasized her free choice to cover and argued that the
idea amongst majority Dutch people that Muslim women are
oppressed is a sign of discrimination.
25
Like other Muslim women
in the debate, she insisted on the compatibility of Western society
and Islam and on their right as Dutch citizens to claim space for
their identity.
26
In 2005 and 2006, the debate was no longer tied to veiling in a
specific realm and, second, the church– state frames had moved to
the background. The headscarf was now more often referred to in
the context of larger debates on integration and emancipation.
Veiling, in whatever form, was increasingly seen as a rejection of
Western values (including secularism) and the growing phenomenon
of girls wearing headscarves (and particularly niqabs or burqas) was
framed as proof of an increasing alienation of the Muslim popu-
lation from Dutch society. This usually went together with a request
for stricter guidelines for veiling in public functions, necessary to
protect the secular state from Islamic fundamentalists.
Multiculturalist politicians were blamed for neglecting the desires of
“normal” citizens who were worried about the place of Islam in
Dutch society and veiled women were blamed for isolating them-
selves from society. For example, in Charlois, a district in the muni-
cipality of Rotterdam, the outcome of a debate among politicians
and citizens was that they wanted a ban on headscarves in the civil
service; they regarded toleration as a sign of weakness that gave
leeway to more excessive forms of veiling.
27
Others considered this way of reasoning as an expression of
Islamophobia and countered it with a participation and nondiscrimi-
nation frame. Gerhard Burger, a former Rotterdam integration pol-
icies officer, said: “I fear for a fragmentation of society ...(...)In
the public debate the importance of religion for the self-esteem of
people is grossly underestimated, in particular for immigrants.”
28
The demand to assimilate is thought to have counterproductive
effects by pushing Muslims into the hands of extremists; mainstream
society should be more sensitive to the struggle of Muslim girls with
headscarves to participate in Dutch society.
The Islam as a threat,participation and victimization frames, and
their counter-frames, occasionally had the headscarf as their object,
but were particularly resonant in the debate about burqas. Public
safety, it was argued, required that people are identifiable and there-
fore the face should not be covered. Or it was stressed that
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integration in our society includes face-to-face communication. Or
burqas were experienced as plainly an offence of the values we
cherish: “The ostentatious nature of (the burqa) can be understood
as a hostile rejection of our open Western societies that one day wel-
comed those people as guests” (W. B. Schuller, NRC Handelsblad,
December 30, 2005).
Hence, the burqa debate did not produce new frames. The differ-
ence was rather a shift in which frames were dominant and that
with regard to burqas the participation and nondiscrimination frame
completely disappeared, as no one argued that nonacceptance of
burqas was discriminating and excluding Muslim women. Instead,
people expressed that a full ban on burqas was not necessary; a
partial, domain-specific, ban was sufficient. They more often used a
nondifferentialist frame by claiming that all citizens, regardless of
their background, should adhere to some common norms of
face-to-face visibility for interests of public safety or morals, sub-
sequently ignoring the indirect discrimination such a generally for-
mulated obligation would have for Muslim women.
There were also people opposing any legislation. They argued that
the debate was not about public safety, but about politicians playing
into existing sentiments of Islamophobia to win votes. Some refuted
the argument that face-to-face visibility was necessary for fruitful
communication, giving examples of conversations they had with
niqab-wearing women in Islamic countries,
29
whereas others wanted
the government to pay attention to “real” feminist questions like
domestic violence.
30
And Muslim women expressed their fear of a slippery slope and
that soon the right to wear a headscarf would be curtailed as well.
We see, hence, that people in favor of the right to wear headscarves,
and Muslim women in particular, no longer express a positive ideal,
but are forced to take a defensive position.
In our analysis of the media, we found that in the earlier years the
open neutrality and freedom of religion frame was most salient.
Later, this frame had to make room for the Islam as a threat frame
in combination with an integration frame. Veiling came to be seen
as a rejection of Western values and as proof of the alienation of the
Muslim population from Dutch society. The gender frame was
initially not central to the debate on the veil. This suggests that the
veil is not strongly perceived as a gender issue in the Netherlands.
One reason is probably that in the Netherlands the Christian parties
have nearly always been in the center of power due to pillarization.
The recent installation of a ministry of family affairs and youth
(currently headed by the leader of the orthodox-protestant party
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Christen Unie) is an illustration that the traditional family still is
considered the cornerstone of Dutch society.
Conclusion and Debate
What do the Dutch regulations and debates on the veil tell us
about the state of the Netherlands? Dutch regulations are largely
accommodative and have stayed so over time. This seems to confirm
our thesis that the heritage of pillarization makes religious identity
claims highly legitimate in the Dutch context. This seems particu-
larly plausible if we compare the Dutch regulations to the German
ones. Similar to the Netherlands, the German state also has a tra-
dition of open neutrality with the state financing religious schools
and courses, social welfare activities of churches, and institutionaliz-
ing priests in universities (Berghahn and Rostock 2007). Yet, unlike
in the Netherlands, the freedom for Muslim women to wear head-
scarves in public institutions is restricted in half of all German
states.
Still, Dutch regulations are more diversified than they look at first
sight. In the institutional contexts of the judiciary and the police
force, the right to wear a headscarf is more restricted than in the
public school. The extent of the right to cover is also dependant on
the type of covering; in addition, there is contestation over Dutch
legal rules also among and between the executive and legislative
powers and the judiciary. From the above, we infer that faced with
the challenge to find a balance between national unity and cultural
and religious diversity, the Netherlands does have its own national
institutional tradition of dealing with diversity. Yet, our findings
also suggest national history is more internally contested than the
theory on citizenship models suggests.
While institutional contexts and type of clothing is relevant for
understanding regulation, this is more so for the public debate.
Niqabs and, in particular, the burqa meet with more resistance than
the headscarf. In the Dutch media-debate as reconstructed mainly
from NRC Handelsblad, most Muslims, together with part of
majority Dutch women, defended the right to veil against
non-Muslim Dutch men who claimed that the veil conflicted with
“Dutch” norms or values.
Analyzing the shift in framing over time, we found that in later
years the veil was no longer linked to concerns about religious
freedom versus public neutrality, but more associated with concerns
about social cohesion and national identity. Both proponents and
opponents of veiling began to see the veil as a symbol of increasing
polarization and segregation. But while the former saw the increasing
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contestation over the veil as caused by a growing Islamophobia, the
latter saw in it an unwillingness of Muslims to assimilate. This shift
is, as we have shown, is only partially explained by the fact that the
object of the debate shifted from headscarves to niqabs and burqas,
as the headscarf itself came to more and more frequently framed as
signifier that stood for a lack of identification with the nation.
Remarkably, the increasing politicization of the veil went hand in
hand with an increase in Muslim voices claiming the right to cover.
Our analysis of the debate in NRC Handelsblad showed that
Muslim actors, Muslim women in particular, do have a voice in the
media, but not burqa-wearing women, although the law change
would have the gravest consequences for them. Their presence may
indicate that Muslim women are relatively successful in participating
in the media debate and suggest that the Dutch multicultural model
of citizenship grants normative and material opportunities for min-
orities who claim recognition of their cultural identity to participate
in the public debate on veiling. We noticed that Muslim actors were
given voice by the newspaper. It is possible that the media are an
independent intervening variable or, as citizenship models are a
certain way of conceptualizing the bond between the nation and its
(diverse or not so diverse) citizens, that the media are also influenced
by this narrative and so is their selection of news facts.
But despite the visibility of Muslim voices in the Dutch debate,
the discourse in which the veil is a symbol of alienation, which
became stronger in later years, forced Muslims into a defensive posi-
tion. They tried to show that Islam is compatible with Western
democracy or with gender equality; the fact that they found them-
selves responding to a discourse that places Muslims outside the
liberal democratic community due to their supposed difference
suggests that the Dutch “model” of multiculturalism no longer has
the same legitimacy as before.
While the veil is often interpreted as signifying traditional gender
roles in some countries, this is not a much contested issue in the
Netherlands and thus the gender equality frame has less resonance
in the Dutch debate. By contrast John Bowen (2007) found that in
France gender equality is a very important frame in public debate
and feminists are very present in the debate. Of the Muslim actors
on the other hand only the bareheaded women, “extremist” imams
and the secularist men were given voice (244–5). This is what we
would expect given that the French civic-assimilationist model aims
to incorporate women on grounds of their universal status as citi-
zens, making such frames more legitimate. Interestingly, however,
we also saw the victimization frame increasingly becoming visible in
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the Dutch debate, often combined with an Islam as a threat frame,
instrumentally employed in an anti-Islam discourse.
Hence, while Dutch policies on the veil still display a multicul-
tural tolerant tradition of citizenship, the shifts in the public debate
suggest this tradition is under pressure, giving leeway to other
frames in the debate on veiling. This may be related to and indicate
a change of a Dutch multicultural citizenship model towards a
civic-assimilationist type of citizenship (see also Entzinger 2005): in
the last decade, the Netherlands made a great departure in politics
regarding citizenship, demanding stricter criteria to apply for
asylum
31
and to acquire Dutch citizenship.
32
The reinvention of the
Dutch canon, but also the massive antivote against the European
Constitution all illustrate this reconceptualization of Dutch national
identity. This happened concurrently with a change in the Dutch
political scene that witnessed the emergence of several new
right-wing populists parties, one of them (the List Pim Fortuyn)
winning a major victory in the 2002 elections. Yet only a cross-
national analysis of various debates on the veil can confirm whether
this change is an illustration of a dramatic departure of Dutch multi-
cultural citizenship idioms and practices, or only a marginal move
toward assimilationism within a hegemonic framework of
multiculturalism.
On the one hand, our analysis suggests the theory of citizenship
models is useful in explaining national framings and regulation of
the veil. Yet on the other hand, our findings also lead us toward a
critique of this theory. The typologies tend to reduce citizenship to
the incorporation of immigrants, but our findings suggest that with
regard to the social and political inclusion of women there also exist
national traditions. In the Netherlands, traditional gender roles are
not strongly contested, and the veil therefore is not strongly per-
ceived, not even by feminists, as contravening gender equality. What
we see as useful in the study of citizenship and nation is the histori-
cizing tradition (Brubaker 1992; Gellner 1983) by which countries
have responded differently to the claims of immigrants for recog-
nition of their religious culture, because nations have different tra-
ditions of how the unity of the nation is understood and should be
secured. These traditions, or national imaginaries, of how equal
citizenship and group difference should be balanced, we want to
suggest, relate to the social inclusion not only of immigrants, but of
groups of citizens more generally (men/women, citizens with differ-
ent religious identities). This is what links pillarization to citizenship
and this is also how we would account for the (limited) role of
feminists and feminist arguments in the Dutch debate on the veil.
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Appendix
Table A1. Articles about Veiling in Five Dutch Newspapers.
NRC Volkskrant Trouw
AD
(from
2005)
Telegraaf
(from
1999) Total Face-cover
2006–07 116 98 112 59 37 422 187
2005–06 97 100 114 35 50 396 150
2004–05 150 114 150 0 39 453 90
2003–04 128 91 93 0 35 347 147
2002–03 54 55 44 0 12 165 67
2001–02 71 54 74 0 13 212 55
2000–01 24 26 27 0 12 89 17
1999–2000 38 22 28 0 5 93 18
1998–99 24 22 27 0 0 73 18
Table A2. Actors in the Debate about Headscarves in NRC Handelsblad
(1998–2006).
Headscarves (NRC) Pupil Teacher
Civil
servant
Police/
judiciary General Total
Muslim women: pro 3 4 13 20
Contra 1 2 3
Muslim men: pro 2 1 3
Contra 0 0 0
Minority organization: pro 1 0 1 3 5
Contra 1 0 1
Non-Muslim woman: pro 6 5 11
Contra 2 2 1 5 10
Non-Muslim men: pro 1 3 1 9 14
Contra 6 3 9 6 24
Other organizations/sex or
ethnicity unknown: pro
303
Contra 1 1 1 0 3
6 24 6 17 44 97
Seventeen other claims concerned Islamic face-covers: ten of non-Muslim men and
two of whom the identity could not be established, three of non-Muslim women and
only one of a minority organization.
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Table A3. Actors in the Debate about Burqas in NRC, Trouw, Telegraaf,
and AD.
BURQAS
General
ban
Contextual
regulations
Against
general ban Total
Muslim women 0 2 6 8
Muslim men 2 2 1 5
Non-Muslim women 1 0 2 3
Non-Muslim men 4 3 3 10
Other/identity unknown 0 1 0 1
Total 7 8 12 27
NOTES
Sawitri Saharso is a member of the VEIL project and Professor of inter-
cultural governance at the Faculty of Management and Governance of the
University of Twente and senior lecturer at the department of Sociology of
the VU University Amsterdam.
Doutje Lettinga is a member of the VEIL project and PhD student at the
department of Sociology of the VU University Amsterdam.
1. We will use “the veil” as a shorthand to refer to all forms of Muslim
women’s head and body covering together and when the public or legal
debate addresses a specific form of veiling, such as the headscarf or the
burqa, this will be mentioned as such.
2. We suggested (Saharso 2007) that this laicism is informed by another
aspect of German history; the German left, while rejecting an ethno-
cultural notion of nationhood, is allergic to the reintroduction of strong
group identities because of Germany’s national socialist past and is there-
fore not drawn to a multiculturalism Dutch style, but to a French style civic
assimilationism.
3. That it concerns here a typical Dutch understanding of educational
neutrality shows when we compare it with a like case in Germany, In the
Ludin case, from the local administrative court of Stuttgart to the federal
administrative court recognized that Germany adhered to a notion of open
neutrality that did not ban religion to the private sphere. Nevertheless, they
ruled that a teacher wearing a headscarf, even if she did not engage in mis-
sionary activities, would contravene neutrality, because it forced pupils to
engage with this expression of religious identity (see Saharso 2007). So while
both are corporatist countries, the meaning of neutrality (in education) is dif-
ferently understood in accordance with their national traditions.
4. “Notitie Landelijk kledingreglement” (January 16, 2004) of the
Advisory Committee Kleding Nederlandse Politie of the Council of Head
Commissioners.
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5. Letter of Mr. P. Deelman (of the Council of Head Commissioners) to
the Minister of Interior Affairs (March 28, 2006), “Uiterlijke verschijnings-
vormen Nederlandse Politie.”
6. http://www.nu.nl/news/1334675/11/Kamer_tegen_agent_met_
hoofddoek.html
7. In both cases, semipublic institutions asked the advice of the
Commission about their desire to impose clothing restrictions on face-
covers for their clients, mainly for reasons of “respectful” and “efficient”
communication: CGB, 2004-95 (a school that wanted a mother to remove
her face-cover when registering her son) and CGB, 2005-86 (an institution
of social councilors having regular conversations with clients who wear the
niqab).
8. Geert Wilders used to be a member of the liberal party Volkspartij
voor Vrijheid en Democratie, but launched his own faction (“Groep
Wilders”) in 2004. Wilders recently launched a controversial movie, Fitna,
in which he attacked (radical) Islam for undermining Western liberties.
9. TK29 754, no. 41 (2005 – 06).
10. The Dutch interest organization of public transportation responded
in a letter to the responsible minister of transport, Camiel Eurlings, that it
considered the existing means sufficient to safeguard general security, and
suggested that a ban would be unnecessary and also difficult to implement.
Currently, the government is consulting this branch to discuss the possi-
bility of refusing women who wear face-covers (TK31 200 VII, no. 67).
http://www.nu.nl/news/1426174/30/‘Boerkaverbod_in_openbaar_vervoer_
onwerkbaar’.html.
11. Source:NOM Print Monitor, October 2006–July 2007. (www.
nommedia.nl/printmonitor.html). The NOM Print Monitor research col-
lects data regarding print media in the Netherlands through annual surveys
over 20,000 individuals aged thirteen and older. The research is carried out
by the independent research institute Intomart GfK.
12. LexisNexis is an online international database that exists of several
national and regional newspapers, magazines, and journals.
13. We selected 1998, because then the first national headscarf contro-
versy emerged (over the trainee insisting on her right to wear a headscarf in
a public school). Moreover, LexisNexis has not archived several newspa-
pers in the period before.
14. Source:NOM Print Monitor, October 2006–July 2007.
15. This part of our analysis is based on Bekers, Bijl, and Saharso
(Submitted). The analysis of the burqa debate is based on four
newspapers (de Volkskrant,Trouw,NRC, and Telegraaf). We took only
those articles into account that mentioned the word burqa at least five
times in the text.
16. The Islamic background was derived from self-identification of the
actors, from the context or categorization of the newspaper or from the
particular name of the actor. It is an attributed identity and hence does not
refer to whether the actor regards him or herself as a (believing) Muslim.
Converted Dutch are also identified as Muslim actors.
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17. This is partly caused by an article in Trouw newspaper, reporting
on a demonstration in November 2006 against the ban, in which four
Muslim women were interviewed.
18. L. Mulder (Humanistisch Verbond), “Hoofddoek 3” (June 5, 1999).
Endnote until and including note 29 are all from NRC Handelsblad.
The quotes about the burqa were found in either NRC,Trouw,AD,orde
Telegraaf.
19. W. Looyestijn, “Hoofddoekje 2” (May 1, 2001).
20. A. Ramdas, “Hoofddoek als lingerie” (July 9, 2001); and
A. Benali, “Moslims rouwen niet met drie minuten stilte” (September 20,
2001).
21. C. van Geen, “Hoofddoek 7” (June 19, 1999). U. Lambrechts,
“Hoofddoek 1” (June 5, 1999).
22. D. Houwaart, “Hoofddoekje 1” (May 1, 2001). See also
D. Begemann, “Hoofddoekje 1” (July 11, 2001) who claimed that the pos-
ition of the Commission of Equal Treatment undermines democratic norms
and values and gives leeway to fundamentalism.
23. For example, in a letter of June 30, 2001, October 16, 2001, and
December 22, 2001.
24. For example, Bas Heijne, “Een oude tulband” (May 12, 2001). Or
Hatic Can-Engin of Inspraak Orgaan Turken in “Feminisme en hoofddoek
kunnen best samengaan” (March 8, 2001), who said that it is a symbol of
emancipation.
25. Fatima Elatik in “Feminisme en hoofddoek kunnen best samen-
gaan” (March 8, 2001) and in “De symboliek van de hoofddoek mag”
(June 27, 2001).
26. For example, student Hind Shouli, member of an Islamic cultural
organization Ettaouhid in a report: “In Marokko ga je op vakantie, naar
Turkije ga je terug” (April 23, 2005), or students Aouatif Tawfik and
Naima el Hannouche in a public debate in Amsterdam in: “Mijn sluier”
(January 31, 2005).
27. “Elke wijk zijn eigen hoofdddoekbeleid; Stadsbestuur wil geen alge-
mene regels voor het dragen van hoofddoekjes” (March 4, 2005).
28. G. Burger in: “Ongerust over de integratie; pionier migrantenbeleid
Rottterdam blikt terug” (March 17, 2005). See also Arabic and Islam
expert Ruud Peters in: “Niet iemand van oneliners; het vonnis van de
Hofstadgroep stoelt ondermeer op analyze van Ruud Peters” (March 13,
2006).
29. Will Tinnemans, a journalism teacher at the university of Sana’a, in
Volkskrant (January 23, 2007).
30. For example, Famile Arslan in Volkskrant (December 22, 2005).
31. From April 2001 into force: nieuwe Vreemdelingenwet.
32. From September 1998 into force: Wet Inburgering Nieuwkomers
(WIN); in 2003 a new law was adopted that went into force from January
2007 onwards: nieuwe Wet Inburgering Nederlanders.
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