Citizenship Studies

Vol. 12, No. 1, February 2008, 27–43

A history of sex and the state in Southeast Asia: class, intimacy

and invisibility
Tamara Loos*

Cornell University, History Department, Ithaca, NY, USA

( Received 14 November 2006; final version received 2 August 2007 )

This essay offers a history of international marriages that questions the definition of
marriage and what it meant to belong, as a legal subject or citizen, to a colonial state
in Southeast Asia. European imperial states deployed monogamous marriage
alongside other weapons of empire as a justification for intervention into Southeast
Asian societies. With monogamous marriage came also European notions of
belonging that traced surnames and legal subject status (later citizenship) via
husbands and fathers. The ramifications for individuals in international marriages
between Asian women and European men are well known. However, the vast
majority of ‘international marriages’ were not those between colonial Europeans and
Southeast Asian women, but between Southeast Asian women and lower class Asian
men from India and China. Colonial states ignored or failed to register these lower
class intra-Asian intimacies because their unions did not threaten colonial rule so
long as they ensured a continuous pool of labor and promoted the colonial economy.
Unlike recent theories which argue for an omniscient state that penetrates into the
personal lives of its populations, this essay maintains that states intensely regulated
marriage and belonging for some subjects but not for others. This longstanding
unevenness in the management of intimate unions provides a historical context for
understanding shifts in the marital regimes of contemporary postcolonial states.
Taking a long-term view, the essay asks if recent increases in international marriages
might be better understood as spikes rather than as absolute increases resulting from
‘globalization’. A historical framework ties the rise and fall of international marriage
to early modern trade patterns, imperialism’s labor requirements, war, and the recent
demand for labor that has arisen from low birth rates and economic changes. Each of
these ‘events’ entailed a large-scale movement of populations which resulted in the
development of intimate unions.
Keywords: International marriage; interracial union; concubinage; monogamy;
Southeast Asia; colonialism

Introduction
Colonial regimes in Southeast Asia differentially managed the sexual affairs that arose
among members of their diverse populations. These states, which included the British in
Burma, Malaya and Singapore, the French in Indochina, the Dutch in the East Indies
(Indonesia), the Spanish in the Philippines, and the Siamese in Siam (Thailand), regulated
intimate unions with intensity or treated them with indifference depending on its strategy
of governance and on who was sleeping with whom. Their administrations defined and
interpreted racial belonging, citizenship, and the kinds of intimate practices that solidified

*Email: tl14@cornell.edu

ISSN 1362-1025 print/ISSN 1469-3593 online

q 2008 Taylor & Francis
DOI: 10.1080/13621020701794133
http://www.informaworld.com
28 T. Loos

or challenged the line between rulers and ruled. In these ways, intimate matters were a
fundamental concern of colonial governments.
Scholarship on sexual relations under colonial rule has largely focused on the
management of unions between Europeans and Southeast Asians, rather than on
relationships between the vast group of foreign Asians and local Southeast Asians. Both,
however, count as what is today called ‘international marriages’. If we momentarily
simplify what are in reality ambiguous racial categories, intra-Asian relationships were
and are more numerous than more visible white European – Asian unions.
The critical history of ‘international marriage’ below questions the categories of race
and nationality, and in particular, the manner in which individuals were determined to
belong within them. It also centrally incorporates the class background of foreign, non-
local Asians, such as the Chinese or South Asians, who had intimate relationships with
Southeast Asian women. Historians of Southeast Asia have long noted the ease with which
wealthy Chinese, for example, married into some Southeast Asian ruling dynasties and
upper classes. However, a focus on lower class Asian immigrants to Southeast Asia during
the colonial period reveals the existence of different kinds of relationships (especially
informal unions) that only infrequently are monitored by states (or by scholars).
Historically, lower class intra-Asian intimacies fell off the colonial state’s bureaucratic
grid because their unions did not threaten the state so long as they ensured a continuous
pool of labor and promoted economic growth.
By concentrating on intra-Asian marriages during the era of high colonialism in the
nineteenth and early twentieth centuries, this essay gives contemporary scholarship on
international marriage a broader context and history. It challenges certain assumptions such as
the idea that international marriages and the citizenship complications they produce are on the
rise in the twenty-first century (Constable 2003). Convincing statistics have been mustered to
prove an undeniable recent increase in international marriage in Taiwan, Singapore, South
Korea, and Japan where aging populations and low birth rates have encouraged the
‘importation’ of foreign brides, the majority of whom come from the PRC and other regional
countries, including those in Southeast Asia. In Taiwan, for example, where the fertility rate
was only 1.18 children per woman (Wang and Bélanger 2006), international marriages
counted for an extraordinary 32% of all marriages in 2003 (Jones and Shen 2006). Over 13%
of all marriages in South Korea (Lee 2006) and 6.6% of marriages in ultra-homogenous Japan
in 2005 were international ones (Chapple 2006). These marriages tend to occur between rural
and lower class urban men in South Korea, Japan, and Taiwan, and women from poorer Asian
countries such as the PRC, Vietnam and the Philippines. The impact these marriages will have
on notions of cultural and national belonging remain to be seen.
Despite these astounding statistics, the historical record suggests the possibility that
intimate unions were as or more common during the colonial period than they are today.
The fact that colonial-era regimes unevenly monitored and rarely enumerated Asian
mestizos makes the comparison with today’s international marriages difficult. However,
placing contemporary studies of intra-Asian unions within historical context may
attenuate implicit claims of absolute increases resulting from ‘globalization’. In other
words, a historical view would see fluctuations in international marriage rates that are tied,
in chronological order, to early modern trade patterns, imperialism’s massive demand for
labor in its public works projects and plantations, war (WWII, the Korean War, and
US – Vietnam War, for example) and most recently the demand for labor that has arisen
from low birth rates and uneven economic development. Each of these ‘events’ entailed a
large-scale transnational movement of populations which resulted in the development of
intimate unions.
 Citizenship Studies 29

To explore these issues, I focus below on the period of high imperialism in Southeast
Asia from the late nineteenth century until the early twentieth. British, Dutch, French, and
Spanish imperial states had by this point colonized all of Southeast Asia except for Siam.
I analyze Siam within the same framework as European colonial governments, unless
otherwise noted, because Siam’s law and policies on nationality, subject status (which
determined the legal regime applied to non-Siamese individuals residing in Siam),
immigrant labor, and the like operate in ways similar to those of colonial governments in
Southeast Asia from the mid-nineteenth until the early twentieth.
To clarify assumptions about the racial constitution of international marriages and
their frequency over time, I ask four fundamental questions. First, what makes these
relationships international? Because this essay concentrates on the period of high
imperialism, the term citizenship does not apply. Yet the category of ‘legal subject’ can be
regarded as a precursor to ‘citizenship’, not so much because it suggests an emotive sense
of belonging and patriotism but because it enabled the state to keep track of and manage its
subjects. Even prior to the colonial period in Southeast Asia, evidence suggests that the
gender asymmetries that characterize modern citizenship applied. Certainly by the late
nineteenth century in Southeast Asia, men unidirectionally passed on their subject status to
their wives and children in officially recognized marriages.
The second and third questions are interrelated: what defines a relationship as marriage,
historically, and what relationships failed to meet the legal standard of ‘international
marriage’? These questions form the core of the argument which centers on the invisibility
in the historical record of the majority of intimate unions that occurred in colonial Southeast
Asia – those between Chinese or South Asian male immigrant laborers and Southeast
Asian women. An analysis that focuses exclusively on state recognized marriages would
‘see’ only a minority of the relationships that formed the landscape of intimacy.
The fourth question steps back and asks why states intervene in marriage in the first place.
It combines insights from the work by Frederick Engels, James Scott, and Ann Stoler even as
it critiques their approach. These four questions structure the remainder of the essay. Each
one requires that we keep our eye on the state and which ‘international marriages’ it
recognized as important to regulate. They also demand exploration of the sexual unions that
attracted uneven and often indifferent state attention: those that occurred between Southeast
Asians and the far more numerous foreign, lower class Asian migrant communities.
Ultimately, an individual’s race, calibrated by class, gender, and other factors, determined
whether one’s marriage across borders would attract the gaze of the state.

Legitimate ‘international marriages’ in colonial Southeast Asia

Imperial monogamy: defining legitimate marriage
A variety of sexual relationships existed in colonial Southeast Asia, ranging from one-time
commercial encounters and temporary marriages to long-term polygynous and
monogamous unions. Colonial-era regimes permitted or tolerated all of these, but ranked
them in a moral hierarchy of sexual unions, as explained below. Which of these did
colonial-era states count as ‘international marriages’? When state recognition is brought
into the equation, these marriages are removed from their customary and often ceremonial
contexts and placed within the arena of the state bureaucracy, replete with its hierarchy of
legal categories within which individuals were placed. In other words, the desire or need
on the part of two individuals from distinct legal communities to register their marriage
with the state in colonial Southeast Asia invited the state’s bureaucratic machinery into
their ‘private’ lives. States created laws to regulate the subject status (as ‘European’,
30 T. Loos

‘Native’, ‘Foreign Orientals’, ‘Chinese’, ‘Asiatic protégés’ and so on) of those individuals
who married across legal categories and their progeny. From its onset, the
institutionalization or bureaucratization of marriage was linked to empire in Southeast
Asia because states determined who could marry whom and what form of marriage was
deemed legitimate. Aside from helping states regulate membership in the ruling class,
laws regulating marriage had additional gendered, racialized, and classed effects.
State-sanctioned marriages adhered to state-specific (and in the Philippines, Church-
specific) laws regarding who could marry whom and how. It goes without saying that these
laws recognized only heterosexual relationships. Moreover, empire created a hierarchy of
marital forms with monogamy as its pinnacle and could, depending on the background of
the individuals being married, require both parties to be Christian. The Western European
Christian system of monogamous marriages was projected globally by imperial countries
through law and moral pressure: a country that did not at least formally adopt heterosexual,
monogamous marriage as the basis for its modern family system was not considered fully
modern by other powerful countries. Frederick Engels first theorized the nexus of marital
form and empire. According to him, Western capitalism and its dominant family form,
bourgeois monogamous marriage, propelled imperialism. Here ‘bourgeois’ refers to the
monogamous family’s patriarchal inheritance patterns that determined property rights.
Engels’ analysis reflected and in some cases foreshadowed the deployment of
monogamous marriage by European imperialists. Colonial rulers in Southeast Asia
applied this marital hierarchy unevenly in their colonies when they refused to recognize
let alone sanction polygynous marriages between European men and Asian women (even
if men unofficially practiced polygyny), but permitted the practice of polygyny and other
marital forms among indigenous and foreign Asians. The hegemony of monogamous
marriage worked hand in glove with imperialism: any country that did not abide by
monogamous marital forms was by definition less civilized and their non-monogamous
marital practices often served as a justification for imperial intervention.1
Patriarchal monogamy and capitalism not only facilitated and ideologically justified
imperial intervention, but a country’s marital norms affected the legal categorization of
their subjects in European colonies – a categorization with enormous legal, political, and
social ramifications. For example, according to Peter Burns’ study of colonial law in the
Netherlands East Indies, after the nineteenth century the legal category of ‘Europeans’
included ‘all Japanese and other peoples (for example, Americans, Argentineans,
Australians) who came from states in which substantially the same family law was
observed as that which held good in Holland’. There, the category ‘Foreign Orientals’
encompassed all non-Europeans and non-natives on the basis of their observance of
‘polygamous family law’ (emphasis added, Burns 1988).
Siam precariously stood out as an exception – it was a politically sovereign state that
continued until as late as 1935 to officially endorse polygyny as a legal marital form (Loos
2006). Although its domestic marital policies defied international marital norms, Siam’s
officials conceded that foreign states had the final say in determining the legitimacy of
marriages between Western men and Siamese women. Western consuls would accept as
legal international marriages performed in Siam only if the foreign man’s consular court
approved the marriage.2

Subjects that matter: defining ‘international’ subjects

Legitimate marriage and subject status, the legal precursor to citizenship, were bound up
with imperialism from the beginning. For a marriage to be considered ‘international’, the
 Citizenship Studies 31

two individuals involved must come from either different states or from distinct legal
categories within the same colony. Clearly ‘citizenship’ is an anachronistic term when
applied to colonial Southeast Asia because it presumes an independent nation-state and,
theoretically, a form of government that grants political rights to its citizens. Given that all
of Southeast Asia was under European imperial rule until the post-WWII period, and that
the single politically sovereign state, Siam, was an absolute monarchy ruling over subjects,
the term citizenship does not, with a few exceptions, apply to the Asian subjects studied
here. Instead, individuals belonged to specific legal categories of rule based on ‘race’ but
strongly tempered by gender and class.
States did not keep track of, let alone legitimize all marital unions, as the discussion of
monogamy revealed. Colonial regimes most rigorously controlled marriages that involved
elites and ‘Europeans’ because, if we agree with postcolonial feminist scholars like Ann
Stoler, these marriages helped regulate who belonged to the ruling class. In this sense,
‘international marriage’ was an elite class and racial issue that involved a numerical but
powerful minority.
Control along racial and class lines had not always been the dominant means by which
‘international marriage’ was regulated. The earliest categories of belonging utilized by
polities in Southeast Asia were religious rather than racial or national. In 1633, the King of
Ayutthaya prohibited relations between Mon and Thai women, who were presumably
Buddhist, and certain foreign men, including English, Dutch, Javanese and Malay men –
all of whom belong to cultures dominated by non-Buddhist faiths – because it would
render these women, and perhaps more importantly, their children, susceptible to ‘wrong
beliefs’ (Dhiravat 2000). Notably, one of the largest groups of foreign traders to
Ayutthaya, the Chinese, is not mentioned in the law, presumably because most Chinese
practiced a form of Buddhism. Even then, belonging was determined along gender lines as
women and their children were assumed, at least in law but not necessarily in practice, to
belong to the religious communities of their husbands/fathers.
In the Spanish Philippines, where the majority of locals had converted to Catholicism,
the state and Church only considered as legitimate marriages between Catholics.
The Spanish depended on the Chinese and Chinese mestizo populations for the Manila
Galleon trade but believed that those Chinese who converted to Catholicism would be
more amenable to Spanish Catholic rule. As a consequence, as early as 1620, the Spanish
encouraged intermarriage between Catholic Chinese and Catholic indios, their appellation
for natives, by offering them tracts of land (Wickberg 2000 [1965], p. 18). Nearly 400
years of Spanish rule resulted in a population of hispanized Catholic Chinese mestizos
who dominated the economy of the Philippines by the nineteenth century.
The Netherlands East India Company (VOC) banned marriages between Christians
and non-Christians from 1617 until 1848 (Taylor 2001, Stoler 2002). In fact, in the
Netherlands East Indies (NEI), all three extant legal traditions – colonial (Christian)
European law, Confucian tradition, and Muslim prescription – discouraged women from
marrying across the boundaries of religion (which was loosely affiliated with race, even
though religious and racial categories did not always neatly conflate), by expatriating from
her birth community the woman who married a ‘foreigner’ and by considering her part of
her husband’s (Taylor 1997).
By the late nineteenth century, quasi-racial categories had eclipsed religious ones in
determining an individual’s legal status. The gendered operation of these practices at this
time became inscribed in law as well. In British Singapore, Burma and Malaya, marriage
asymmetrically granted subject status on the basis of gender – women adopted the subject
status of their husbands. In French Indochina, the situation was more complex and
32 T. Loos

allowed, in some cases, women to retain their original legal status. In the majority of
instances, however, women who married foreigners obtained the status of their husbands
(Cheung 2002).
The 1848 Civil Code applied in the NEI assumed that marriages between ‘Europeans’ and
‘Natives’ – neither their religion nor their gender are specified – would assimilate Natives
into the European category. Up to that point, most marriages occurred between men with
European status and native women so it was unnecessary to specify the gendered operation of
the law in practice. However, by the end of the century women classified as ‘European’ were
marrying non-European men in greater numbers. This raised the specter of ‘European’
women becoming members of polygynous native households and being subject to ‘barbarous’
adat law rather than European law. After intense debate, however, Dutch lawmakers decided
that any woman with ‘European’ status who chose to marry a native man was either of such
low morals or, more likely, was biologically mostly ‘native’ already, that she deserved to have
her status as a European revoked. As a consequence, the 1898 Mixed Marriage Law decreed
that women’s legal status followed that of their husbands (Stoler 2002).
In Southeast Asian colonies and in non-colonial Siam, similar laws came into existence
over the course of the nineteenth century. In a letter written in about 1885 by Prince
Devawongse, the Minister of Foreign Affairs, to Siam’s King Chulalongkorn (r. 1868–1910)
about marriages between British and Siamese, the prince makes it clear that Siam would
adhere to British norms when considering the subject status of Siamese women who legally
marry foreign men: wives would acquire the citizenship of their husbands.3 Moreover,
European women who married foreign men were compelled to take on his legal status even if
that meant relinquishing her extraterritorial rights. Foreign moral disapprobation followed
closely on these legal heels, if the remarks of one late nineteenth century British woman are
any indication. A certain Mrs. Grindrod had this to say in 1894 about Miss Inn, a British
woman recently ‘married’ to Siam’s Foreign Minister Prince Devawongse:
Inn herself, bedizened with jewels, accompanied by Dewan’s [Devawongse’s] first wife, she
glowing pride at being the last of the Minister’s concubines . . . M [Robert Morant] asserts
that Siamese in the Palace, no less than Europeans outside, will scoff at the morality of the
English ladies, for they know exactly what English monogamy is and how severely the British
nation views polygamous connection. They will regard Miss Smith [the woman who allowed
Inn to reside with Devawongse] as an outcast from her own nation, unprincipled, unworthy of
the higher ideals the West assumes over the East, and all this reasonably enough . . . As for
Inn, she has met the fate we all expected of her and her selfishness, cleverness and cruelty may
yet bring her to the top rung of the ladder. (Grindrod 1982 [1894], pp. 102– 103)
In sum, governments decided who belonged within each legal category on the basis of
religion initially but this changed to prioritize ‘race’. Both policies were conditioned by
gender, privileging men in the determination of membership. Because marriage between
individuals who belonged to different legal categories required the wife and their children
to adopt the legal status of the husband/father, racial mixing occurred in practice but was
rarely reflected in official legal classification schemes.4 As a consequence, legal categories
such as ‘European’, ‘Native’, ‘Siamese’ and so on only loosely related to ethno-racial
origins. To underscore this point, Ann Stoler shows that the NEI category ‘European’
could include ‘Japanese, Jews, Arabs, Armenians, Filipinos, naturalized Javanese,
Sudanese wives of Dutch-born bureaucrats, recognized children of mixed marriages, and
Christian Africans’ (Stoler 2002). She argues that to be included in the European category
entailed the acquisition of certain cultural competencies, including adherence to
Christianity, a European upbringing and education, and, if the former proved difficult to
acquire, then marriage or adoption by a European would suffice. Only those who belonged
 Citizenship Studies 33

to elite classes could afford to obtain these ‘cultural competencies’. Aside from a minority
of poor whites who registered their marriages with the state, the majority of individuals
who sought and could procure state recognition of their union came from the ruling
classes. They thereby benefited from the protections bequeathed to those in category
‘European’ and perpetuated their rule.
So far I have only treated official marriages; that is, those recognized and legitimized
by the state in colonial-era Southeast Asia. If we narrowly restrict the definition of
international marriage to include the legal, state-authorized unions between a man who is
registered as the subject of one state and a woman who is registered as the subject of
another, then not only will the number of such marriages be negligible, but the findings
will not be applicable outside a small percentage of the population in Southeast Asia.
Although these marriages are important to consider because they formed among the ruling
class and thus crucially shaped colonial rule, ‘international marriages’ of these type are
ultimately an elite phenomenon (Taylor 2001). The definition is too narrowly legalistic to
include the vast majority of inter-ethnic, interracial and international marriages that
occurred. Broaden it to include other arrangements that fall outside the law, and there is an
issue of immense historical magnitude and importance to the very structuring and
maintenance of colonial power in the nineteenth and twentieth centuries.

Unregistered intimacy in colonial Southeast Asia

Ann Stoler’s work illuminates the range of intimate unions that were directly and indirectly
encouraged by the myriad laws the Dutch issued in the Indies in an effort to control the
boundaries between ruler and ruled (see the following section). In addition to legitimate
marriages, she and other scholars of the NEI treat cohabitation, concubinage, and prostitution
as forms of intimate unions between individuals of distinct legal statuses that fell short of
state-sanctioned marriage (Ming 1983, Locher-Scholten 2000, Taylor 2001, Stoler 2002).
Cohabitation differed from concubinage perhaps only ideologically – both suggest long-
term relationships but cohabitation implies that the women involved in these relationships
enjoyed social privileges, which they may or may not have. Because of high rates of venereal
disease and moral degeneracy associated with the profession, prostitution certainly existed
but was not particularly encouraged between Europeans and local women. By contrast, it was
encouraged for Chinese male laborers or ‘coolies’ (Dararat 1983, 1984, Stoler 2002).
Because the distinctions among these forms of intimacy were often blurred in practice, I use
the terms cohabitation, concubinage, and intimate unions interchangeably, and do not
address prostitution because of the short-term nature of the sexual encounter which did not
typically result in the production of a longer-term ‘marital’ unit with or without children.
A consideration of the skewed ratio of foreign male to female immigration to
Southeast Asia suggests that unregistered marital forms dominated the landscape of
intimacy. In the early 1600s, the VOC’s first governor-general famously explained:
‘Everyone knows that the male sex cannot survive without women’ (Taylor 2001, p. 12).
Cultural norms regarding lower class male masculinity anticipated that European men in
the settlements would need sexual outlets. Given the severe restrictions that the VOC
eventually placed on European female immigration, the VOC encouraged non-marital
unions between its men, most of whom were destitute, and local women because it was
less expensive, was believed to prolong the lives of their mestizo children, and, as
elucidated by Taylor and Stoler, helped maintain white prestige.5 In other words, formal,
legitimate marriage was the preserve of elites who could ensure that their marriages
adhered to European standards of civility associated with whiteness.
34 T. Loos

The European population in the NEI grew from 2000 individuals in 1620 to 17,000 in
1852. This number doubled by 1872 and by 1900 there were 76,000 individuals
enumerated as ‘European’ in the Dutch colony (Taylor 2001). By the 1880s, nearly half of
the European male population in the NEI – tens of thousands by this accounting – were
cohabitating with Asian women (Stoler 2002). Skewed gender ratios among Europeans
existed in other European colonies as well, where empire remained a man’s arena until the
steamship and the opening of the Suez Canal enabled the immigration of European women
on a larger scale.6 Even then, in the French protectorate of Tonkin in 1931, there were
14,085 European men compared to 3083 women (Stoler 2002). Figures for the Spanish in
the Philippines are harder to come by, but Wickberg estimates 1000 Spaniards resided in
Manila in 1603 and that these numbers remained small by comparison to Chinese mestizo
and Chinese immigrant populations (Wickberg 2000 [1965], pp. 5 –6).
If we believe, following this logic, that the abundance of European male immigrants to
Southeast Asia and the absence of European female immigration facilitated the development
of intimate liaisons between European males and local females, then how true might this be
for the immigration of men from other areas of the world? Compared to Europeans, the
Chinese and South Asian male immigrant population in Southeast Asia during the colonial
period far outnumbered that of Europeans. Intra-Asian ‘international’ intimate liaisons, it
follows, were likely to have been far more numerous but less regulated by the colonial state.
These unions preceded the colonial period: in Malacca in 1511, 50,000 traders – only a
small minority of which might have been European – were reported to have had temporary
wives. In 1596, 3000 Chinese men in the trade port next to Batavia engaged in similar
relationships with local women (Taylor 1997). Barbara Andaya has called these intimate
associations arranged between local women and foreign male traders during the early
modern period ‘temporary marriages’. The majority arose between Chinese traders and
local women who facilitated trade by extending to him her kinship networks and ability to
dissemble with officials. Upon his departure, he paid her relatives and her honor remained
intact (Andaya 2006).
The magnitude of trade and human movement exploded by the mid-nineteenth century,
when transportation technology improved and the demand for cheap labor was met by
massive human diasporas and displacements. In Southeast Asia, Siam and European
colonial states encouraged the migration of Chinese and South Asian laborers to toil on
public works projects such as railways, mining projects, plantations, canals, telegraph lines
and the like.
According to G. William Skinner, large-scale Chinese male migration to Siam occurred
throughout the turn of the nineteenth century. Nearly 80,000 Chinese remained in Siam over
and above those who emigrated back to China from Siam between 1882 and 1892; that
number jumped to 193,000 between 1893 and 1905; and hit over 180,000 from 1906 to 1917
(Skinner 1957). In 1900, the Chinese population in Siam was 608,000. In contrast, before
1893, Chinese women almost never migrated. Around 5% of Chinese immigrants were
women between 1893 and 1905, a number that rose to 10% between 1906 and 1917 (Skinner
1957). Chinese women began migrating in the early twentieth century only after restrictions
on their migration eased but even then, the sex ratio remained skewed (Bao 2005).7
Many Chinese ‘married’ (unofficially – individuals were not required to register their
marriages with the state until 1935, and even then the state weakly enforced the law)
Siamese women. There existed few obstacles to their union except for language and
poverty, which meant that the marriage rate was higher for wealthier Chinese and for those
in occupations other than mining and wage labor (Skinner 1957, p. 127). However,
Skinner notes that regardless of their initial poverty or occupation, most Chinese men who
 Citizenship Studies 35

stayed for a few years in Siam were considered as wealthy as Siamese men, that upward
mobility was extremely high, and that marriage was the rule for those who stayed (Skinner
1957, pp. 127, 136 – 137). During the nineteenth and early twentieth centuries, the Siamese
government allowed unrestricted Chinese immigration to and movement within Siam,
demanded low taxes, and only intervened in their lives when Secret Society feuding
compelled government intervention (Skinner 1957, p. 143). Only with the rise of Chinese
nationalism did the Siamese state (and colonial regimes) more tightly monitor its Chinese
and mestizo populations.
As was the case in Siam, the Spanish began to encourage Chinese immigration to the
Philippines in the latter half of the nineteenth century, although the numbers remained
small by comparison to the rest of Southeast Asia. At its high point, there were over 90,000
Chinese in the Philippines between 1876 and 1886. The rate of intermarriage did not
decline which contributed to the growth rate of the Chinese mestizo population, which was
estimated at between 150,000 and 300,000 (6% of the Philippine population) between
1850 and 1900 (Wickberg 2000 [1965], pp. 41, 61, 134).
While assimilation of Chinese male migrants was the rule for most of Southeast Asia,
especially in the precolonial period, it was not consistently the case in parts of British
Malaya and the Dutch East Indies. In other words, colonial states sometimes promoted
Chinese immigration without necessarily supporting Chinese marriage with local women.
In Java, Dutch policy (and often Javanese and Chinese predilections) aimed to keep the
Chinese population separate from the local population. Still, the absence of Chinese
female immigrants meant that the Chinese intermarried with local women and that this
gave rise to a mestizo class. These communities did not obtain a distinct legal category.
Instead, the local wives and children of Chinese men were subsumed into the legal
classification ‘Chinese’ (Taylor 2003, p. 186). By 1930, the Dutch government
enumerated 1.2 million racially ambiguous ‘Chinese’ resident in the Dutch East Indies.
The statistics for British Singapore and Malaya are sketchy, but according to one
scholar, there were about 175,000 Chinese there in 1881. Only 15% of them were locally
born while the remaining had recently immigrated (Tan 1988, p. 49). Chinese immigrant
men married local Malay women and Sino-Malay women, thereby creating and
perpetuating a Chinese Peranakan or Baba community which spoke Malay but considered
themselves Chinese (Tan 1988, p. 43). Tensions developed between the Peranakan
communities and Chinese immigrants, whose numbers soared when the British encouraged
Chinese immigration in the late nineteenth century. This was no doubt complicated by the
arrival of South Asian men who ‘immigrated’ to British Malaya as the British expanded
Malaya’s plantation economy. By 1891, the Indian population in Malaya was over 75,000;
by 1911 it was 270,000; and by 1931 it had reached 625,000. Again, the vast majority of the
immigrants were male (Arasaratnam 1979, p. 28). These numbers do not, it appears,
include mestizos nor is there a discussion of intermarriage or mestizo populations. It is
possible that South Asian migrants, the vast majority of whom were Hindu Tamils, did not
intermarry as readily with the largely Muslim Malays. Even so, some ‘international’ unions
must have occurred especially given that the 1922 Indian Emigration Act, which legislated
a sex ratio rule among Indian emigrants to alleviate the social disruption caused by sex
imbalances, was not applied in Malaya (Arasaratnam 1979, p. 67).
By contrast to the meager research on mixed Malay – Indian marriages in Malaya is an
exceptional account of mixed race unions in British Burma. Historian Chie Ikeya analyzes
the impact of Indian, Indo-Burmese, and Eurasian (European and Burmese) populations
on early Burmese nationalism in colonial Burma (Ikeya 2006). The statistics she cites for
1931 provide a snapshot of the immigrant population there. South Asian immigrants made
36 T. Loos

up about 80% (617,521) of the total foreign immigration, Chinese amounted to 15%, and
presumably Europeans and others comprised the remaining 5%. Seventy-two percent of
the 617,521 South Asians were male and 68% of the Chinese population were male. True
to Coen’s crass commentary, once in Burma these men became involved with local
women, as statistics on the numbers of Eurasian (European and Asian) and Indo-Burmese
progeny reveal. By 1931, after four decades of lenient immigration policies, there were
nearly 200,000 Indo-Burmese – far more than the 20,000 Eurasians registered by the
census (Ikeya 2006).
The point is that depending on how one defines who counts as an ‘international’ subject
and what counts as marriage, one will draw radically different conclusions about the size
and significance of populations and state policies regarding ‘international marriage’ in
colonial-era Southeast Asia. The colonial states and Siamese regime of the nineteenth and
early twentieth centuries did not intervene into these most numerous of ‘international’
intimate liaisons. Far less legible to the state than European – Asian marriages were unions
among Asians (and mestizos) who held distinct subject status, and who did not register
their unions, temporary or long-term, with the colonial or Siamese state.
Colonial-era states in Southeast Asia were no doubt aware of these liaisons since they
had encouraged the immigration of male Asian migrants in massive numbers to their
colonies and had, in some cases, enabled the proliferation of houses of prostitution to
accommodate these men. However, colonial states and Siam did not prohibit, force the
registration of, or otherwise regulate sexual unions among non-European women and men
so long as these liaisons did not disrupt the states access to these men as laborers. Had
intimate unions among Asians – male members of the Asian diaspora and local women –
interrupted the flow of male laborers to state public works projects, then local regimes would
have presumably more closely monitored them so as to better subject them to state control.
To sum up, one must ask how much the form and directionality of international
marriages has changed from the colonial era to the early twenty-first century. Today
registration of marriage is compulsory and heeded by many more Southeast Asians than
during the colonial period. While modern nation-states similarly encourage the
immigration of cheap labor, it seems that the gender ratios are more balanced and may
even have shifted in favor of women in some places. In addition, the directionality of labor
migration seems to have shifted. Unlike during the colonial period, global capitalism now
encourages the movement of Southeast Asians to foreign countries (the Middle East,
Japan, and Singapore, to name a few) rather than exclusively promoting the movement of
others (European colonials, Chinese and South Asians) to Southeast Asia. If this is true,
then potentially different kinds of ‘mixed unions’ are occurring between Southeast Asian
women, many of whom move abroad as maids or wives purchased on the marriage market,
and foreign men.
The explanation of ‘international marriage’ offered above may have unpacked and
redefined these terms, but it only hinted at a rationale for why states in colonial-era
Southeast Asia found it essential to regulate these unions in the first place. Below I explore
some of the possible motivations.

Why colonial states regulated ‘international marriage’

Why did colonial regimes regulate the sex life of their populations? What was at stake?
Did colonial authorities prioritize economic profit and regulate the familial and sexual
lives of subjects as an afterthought? This ordering of priorities seems normatively true.
However, it fails to explain why British and Dutch East India Company officials
 Citizenship Studies 37

intervened in the ‘private’ lives of Europeans and Southeast Asians under their authority
from the moment they moored their ships in local harbors and with increasing surgical
specificity.
The first governor-general, Coen, of Dutch East Indies Company in Batavia referred to
the behavior of the polyglot European group of men and women who arrived on those first
ships in the late sixteenth century as abominable, scandalous, and bestial: ‘Our reputation
has suffered badly and the Indians are absolutely scandalized by them, because of their
bestial living, their constant drunkenness and lewdness’ (cited in Taylor 2001, p. 12).
Dutch regulation of the sexual life of the inhabitants of Batavia thus began despite the
obscure relationship between such directives and economic profit. By the mid-1600s, the
Company had issued copious decrees delimiting the relationships between European
males and females, both local and European, and the status of their offspring.
The British East India Company intervened in the lives of its native subjects in India
and Southeast Asia, paradoxically, by making the decision to apply English law in all
criminal, commercial and civil matters except for those involving religion and custom –
arenas that encompassed familial and sexual issues such as marriage, divorce, inheritance,
funerary practices, and others. This decision, applied earlier, was first codified by the
British in 1781 in India, and applied eventually throughout the British empire (Hooker
2002). The theory behind the decision was that marital relations belonged within the realm
of religion and culture, both of which were essentialized as barometers of a people’s
authenticity. Intervening to change such ingrained behaviors, the British conjectured,
would cause rebellion and thus hinder governance and economic extraction. In practice, as
Stoler, Taylor, Ghosh, Loos and others have demonstrated, colonial administrations
intervened in the religious, gender, and sexual practices of colonized populations even as
they espoused the principle of non-interference in local traditions. Although marriage
remains the focus of this discussion, it is important to note that it formed part of a larger
group of practices regulated and organized by the state for similar reasons.
There are several different frameworks for understanding why and how colonial (and
postcolonial) states intervened in the family and sexual lives of subjects and citizens –
who was allowed to marry whom, the kinds of unions deemed legitimate, how divorce
operated, inheritance standards, child custody norms, and so on. I have divided them into
three: a Marxist framework exemplified by Engels; a Foucaultian model of biopower and
governmentality as exemplified by James Scott’s recent work; and a feminist, postcolonial
framework exemplified by the work of Ann Stoler and others. These models share a great
deal in common despite their distinct emphases, are not mutually exclusive, and are not
meant to be comprehensive (other models exist to explain state control over the definition
of family). However, they offer the most pertinent scholarship on state regulation,
especially of the ‘private’ lives, of individuals in colonial Southeast Asia.
Frederick Engels, writing in 1884, offers a trenchant critique of late nineteenth century
capitalism in the West which he saw as the motor of imperialism, and of its concomitant
familial form, bourgeois monogamous marriage (Engels 1964). In Engels’ evolutionary
model, based largely on the research of Morgan (1877), Bachhofen (1861) and other proto-
ethnologists, the dominant family structure of a given society paralleled the degree of its
political and economic advancement. The latest stage of development (nineteenth century
capitalism) offered monogamy as its privileged form of marriage. In his model, the
eradication of ‘mother-right’ – an allegedly prehistoric system by which mothers were
exclusively recognized as the parent of their children because non-monogamous relations
made it impossible to determine paternity – its replacement by patriarchy, and the creation
of private property form the foundation of modern society (Engels 1964). Engels’ theory
38 T. Loos

is based on (but critical of) the same evolutionary modeling that considered the modern
monogamous family as not just the normative form of marriage, but the most civilized
marital form because it implied women’s equality to men, unlike non-monogamous
marriage. Official policy espoused by European imperial powers in the nineteenth and
early twentieth centuries supported the normative view.
Engels turned the evolutionary rationale on its head. The patriarchal monogamous
family, he argues, amounted to the ‘world historical defeat of the female sex’ because it was
‘founded on the open or concealed domestic slavery of the wife’ (emphasis in original,
Engels 1964). In other words, the status of women in society lowers as a society becomes
more ‘civilized’, meaning as it adopts capitalist modes and relations of production.
According to Engels’ (and Marx’s) class analysis, the first division of labor was that between
man and woman for the propagation of children, and the first class oppression is that of the
female sex by the male, in particular through the institution of monogamous marriage.
In Engels’ work, patriarchy and capitalism interact but are analyzed separately, with
economic causality taking precedence (Scott 1996). Engels grants the economy ultimate
agency not the state, which merely reinforces and regulates the power relations established
by the creation and advance of private property and capitalism generally. One way it does
this is by supporting the patriarchal institutions of marriage and the monogamous family.
This model does not speak directly to international marriages or colonial state, but we can
extrapolate that the colonial state would seek to promote marriages that maintain and
enhance the wealth and power of the ruling elite, and limit marriages that would diminish
their strength.
For colonials, wealth and power were directly related to their position in the colonial
government. Because of logistical issues such as the long duration of travel and slow
communication between the European metropole and the colony, during most of the
colonial period official posts were not determined so much by the metropolitan
government, but by connections with powerful individuals within the colonies themselves.
These connections were formed in the social world of the colonial capital, as described by
Jean Taylor (2001). She argued that in the case of Dutch Batavia from the sixteenth until
the mid-nineteenth centuries, the ruling (mestizo) class sustained itself for over 200 years
through marital alliances formed among European men who married each other’s Indo-
European female relatives. Indies women remained in Batavia while men, typically Dutch
born, were eventually sent back to the Netherlands. As a consequence, all property and key
political positions and connections were passed to European men through these mestizo
women (contra Engels’ model). If the early Marxists were generally correct that the states
sought to maintain and reproduce certain relations of production and class hierarchies,
then this could best be achieved through the regulation of such marriages.
A second framework for understanding why states regulate marriage has less to do,
directly, with property and more with inexorable state efforts to render all aspects of its
population’s lives legible and thus manageable. James Scott’s recent work details the
process by which increasingly modern states make populations progressively more
knowable for the joint purposes of control and, ideally, of improving the lives (especially
the health) of populations (Scott 1998; Scott et al. 2002). He elaborates on the creation of
family surnames as one of many mechanisms that enables the state to trace unique
individuals. Permanent surnames help the state chart its human topography by creating
individual identifications that are linked to the growth of state control over individuals, the
development of legal systems, and the promotion of property regimes (Scott et al. 2002).
By imposing a European system of naming through patronyms, colonial states largely
eradicated local systems of ordering and knowing their populations.
 Citizenship Studies 39

European colons were not the only ones to adopt this system. In Siam, King
Vajiravudh (Rama VI, r. 1910– 1925) promulgated Siam’s first nationality (sanchat or
sanyachat) law on the same day as the first modern family law (Surname Act) on 22 March
1913.8 Both laws operated according to the principle of patronymic descent: fathers passed
their nationality and family names to children, and wives adopted their husbands’
citizenship and surnames.9
The purpose of creating family surnames in the colonies, according to Scott, was to
distinguish individual male subjects for taxes, conscription, land revenue, court
judgments, witness records, police work, and other tasks. It helped the state enforce
private property rights, seize land, advance primogeniture regimes, display paternity and
inheritance rights, monitor subject populations, and to discriminatingly promote the state’s
vision of welfare, health and development (Scott et al. 2002).
In Scott’s usage, the micromanaging of patronyms that rendered visible the identities
and property of male European colons and colonial subjects did not directly endeavor to
regulate sexuality and reproduction or the boundaries between ruler and ruled. Scott
analyzes the gendered operation of family surnames (and their parallel implications for
determining citizenship) as part and parcel of a larger state disciplining regime that
Foucault called ‘biopower’.10 According to Foucault, states ‘administered’ sex because it
was related to the management of the population – as wealth, as labor capacity, as a growth
indicator, as a resource problem – and thus was an economic and political issue. Scott’s
work exemplifies Foucault’s notion of governmentality, which developed out of the idea of
biopower, and has been interpreted to mean ‘the dramatic expansion in the scope of
government, featuring an increase in the number and size of the governmental calculation
mechanisms’ (Hunt and Wickham 1994). As such, it describes a new form of governing
that arose in the mid-eighteenth century that was closely allied with the creation and growth
of the modern bureaucracies. The relentless uniformity imposed on populations by states
(colonial and otherwise) of measurements, timetables, administrative forms, and methods
of naming, to name a few, which Scott animates with relevant (and mostly failed) examples
from around the world, exemplifies Foucault’s notion of governmentality (Scott 1998).
Although he does not discuss international marriage explicitly, Scott offers this regime
of visibility as a framework for understanding the state regulation of marriages across state
boundaries. It was less an attempt to control economic profit, the distinctions between
classes, or sexuality and reproduction per se than a compulsion to make all aspects of the
lives of individuals visible to the state to better enable their management. Laws on
citizenship, marriage, and immigration might change in myriad ways over time, but the
impulse and means to govern them become increasingly precise in this model.
Scott’s paradigm does not, however, delve into the shady realm of what remains
invisible or illegible to the state. Although it offers a great deal of insight into why the state
continually regulated and attempted to render visible official marriages among elite
classes, it fails to shed light on other forms of intimate unions. Compared to European –
Asian marriages, unions between non-European men and women were typically not
enumerated, banned, or otherwise directly regulated by most colonial-era states in
Southeast Asia. Moreover, Scott, like Engels, analyzes state efforts to control its citizenry
or economy and assumes the operation of these efforts along gendered lines without
questioning why patronyms and patrilineal forms of inheritance became the norm in the
first place.11 Finally, because men are more useful to the state as laborers, soldiers, and tax
payers (until women also were enumerated separately), their visibility was more important
than that of women, who remain invisible except in population censuses.
40 T. Loos

By contrast, female bodies play a central role in analyses by feminist scholars, who,
unlike Engels and Scott, consider gender and sexuality (not just class and race) as essential
categories in their investigations. International marriage figures more prominently in this
framework because it focuses on state and cultural understandings of gender differences as
they are embedded in laws on marriage, nationalism, and citizenship. Most pertinent to our
discussion is the work of Yuval-Davis and Anthias, who argue that states regulate sexual and
marital relations through women because women are reproducers of boundaries of national
groups (or subject statuses, in colonial times) (Yuval-Davis and Anthias 1989). To
paraphrase Margaret Jolly, ‘[W]omen’s sexual and reproductive bodies’ are privileged in the
creation of nation-state borders. Because their bodies matter more, their bodies – not men’s
– are marked and remarked as they cross religious, ethnic, class, and national borders in the
process of marrying and, I would add, in the process of engaging in sexual relations because
of its potential to produce children that encompassed these divides. For these reasons,
women’s bodies, through legislation, are rendered visible and manageable by state laws as
they marry across borders (Yuval-Davis and Anthias 1989, Jolly 2001). This scholarship
places less emphasis on state control per se, on the maintenance of class and property regimes
(Engels), or on the state compulsion to manage individuals and their activities (Scott), than
on the significance of women’s bodies and their reproductive capacities for the state.
Ann Stoler’s work stands out among the best feminist postcolonial scholarship for its
analysis of state legislation of women’s bodies through racialized marital regimes in the
NEI and French Indochina (Stoler 2002). She shows how the colonial state policed racial
boundaries through the management of sex because it affected citizenship status and
enumeration as European. Stoler argues that regulating sex and reproduction offered the
state a way to maintain the boundary between the rulers and the ruled even if that boundary
was continually redefined over time. Colonial states distinguished between interracial
sexual unions, which were not regarded as particularly dangerous and were instead often
encouraged between European men and native women, and interracial legitimate marriage,
which was restricted in ways outlined earlier. Marriage offered public legitimacy to the
unions and their progeny who would consequently inherit European wealth and privilege
(Stoler 2002). The colonial regime’s focus on official marriage also stemmed from a
concern for the creation of reliable and governable citizens, white and otherwise.12
The problem with the postcolonial feminist scholarship on international marriages is that it
tends to focus on elites or unions between European men and non-European women and
ignores other forms of marriage occurring across various racial, legal, and ethnic divides.
As should be clear, none of these three frameworks are mutually exclusive but they each
underscore distinct rationales for why colonial-era states in Southeast Asia attempted in
myriad ways to restrict and regulate marriages of all sorts, including international and
interracial ones, but usually excluding intra-Asian unions. The desire to understand why
these policies operate rather consistently to the disadvantage of women may in the end elude
resolution. The ‘why’ behind patriarchy is, in our contemporary context, only interpretable in
ideological terms.13 If we sidestep the ideological aporia regarding patriarchy, it is apparent
that state intervention in marital practices and what becomes ‘citizenship’ have resulted in
the expansion of bureaucratic power into the family lives of its citizens over time.14
I have combined all three approaches to shine the light on the far more numerous but
unregistered non-elites and their intimate affairs. Scott and Stoler overlap in key ways to
reveal that the colonial state may not overly regulate the intermarriages between lower
class male immigrants and local women yet it retains the power to determine when an
alliance becomes a ‘marriage’. The colonial state’s enduring preoccupation with sex did
not always directly translate into strict control, but it bears keeping in mind why the state
 Citizenship Studies 41

decided to ‘ignore’ some forms of intimacy but not others. These forms were monitored,
but their significance was recorded only in terms of their progeny – as the statistics on
Indo-Burmans indicates – or, in other words, for their ability to reproduce the laboring
class.

Acknowledgements
The author would like to thank Coeli Barry, Mika Toyota and the other organizers of the Conference
on International Marriage, Rights, and the State in Southeast and East Asia (ARI, Singapore,
September 2006), and the anonymous reviewers who provided excellent suggestions for improving
this essay.

Notes
1. See Loos (2006, Chapters 1 and 4).
2. Prince Devawongse to King Chulalongkorn, ‘Ruang ying sayam ja pen sapayek angkrit’
[About Siamese women who become British subjects], National Archives Microfilm R. 5
R.L.-Ph.S. 16, ‘Saraban samut phiset’, 1885. ‘Phraratchabanyat samrap taengngan khon tang
prathet nai krung sayam’ (1935).
3. Prince Devawongse to King Chulalongkorn, ‘Ruang ying sayam ja pen sapayek angkrit’
(1885).
4. The mestizo category in the Spanish Philippines is one exception.
5. When white women came on the first VOC ships to the Indies, they allegedly behaved
abominably, much like their lower class male counterparts. Because women then (and now)
are regarded as privileged bearers of culture, this behavior threatened white prestige in a way
that that of their male equivalents could not. White women residing in the colonies were
expected to maintain bourgeois culture, which meant that their lifestyles were also expensive
to maintain. In addition, white women also may have existed as a moral check on the sexual
excesses of European men. For these reasons, European colonial states restricted the
immigration of their female nationals.
6. The ratio of women to men rose between 1900 and 1930 from 47:100 to 88:100 overall
(Stoler 2002, p. 53). Indonesia in 1930 included 60 million Indonesians. Of these, 240,000
were Europeans (including mixed race individuals) and 113,000 were women; 1.2 million
were in the Chinese category and the rest were natives (in Locher-Scholten 2000, p. 17).
7. For statistics regarding male and female Chinese migration to Thailand between 1919 and
1947, see Bao (2005, 192–193, n. 6). At a high point in 1939, 335,524 men migrated
compared to 188,538 women.
8. ‘Phraratchabanyat sanyachat p.s. 2456’ (Nationality Law of 1913), 22 March 1913, PKPS,
Vol. 25, 256– 259. Sections on Rama VI’s two laws are paraphrased from Loos (2006,
pp. 223– 224).
9. ‘The citizenship law claimed as Siamese citizens all persons born in Siam; all persons born to
a Siamese father regardless of birth place; all persons born to Siamese mothers when the
father was unknown; and all foreign women married to Siamese subjects. The law privileged
fatherhood in considerations of nationality: it proactively considered as Siamese all children
born to a male Siamese citizen, regardless of their birth place and of the nationality of the
mother. If parents gave birth to a child outside the boundaries of legitimate marriage, then the
Siamese father had the authority to claim or disregard the child as his own and, thus, to
inscribe the child as a Siamese national. Mothers, by contrast, had no comparable power in
regards to passing on citizenship. The law only allowed a woman to pass on her nationality to
her children in the absence of a father/husband. Furthermore, the authority of a Siamese
male’s citizenship negated his wife’s nationality, making her Siamese regardless of her
original citizenship’ (Loos 2006, pp. 223– 224).
10. Biopower refers to the institutions (including universities and prisons, for example),
disciplinary fields (such as demography), and other techniques by which individual bodies
and entire populations are subjugated and controlled. It is not exercised by state institutions
and discourses alone but kinship and family regimes which also shape and discipline everyday
practices (see Foucault 1990, pp. 24 – 26, 140– 144).
42 T. Loos

11. The imposition of patriarchal legal forms in Southeast Asia is particularly inapt given that
polygynous unions were legitimate for most of Southeast Asian history. Determining the rank
of children depended not on the father, whom all children shared in common, but on the
mother.
12. Her work is especially powerful in its focus on the colonizers: ‘Racial thinking was part of a
critical, class-based logic that differentiated between native and European and . . . was part of
the apparatus that kept potentially subversive white colonials in line’ (Stoler 2002, p. 13).
13. In his study of ‘development’ in Lesotho, James Ferguson (1994) offers a way to avoid
ideological pitfalls. He is not interested in pursuing ideological questions about development –
whether or not development ideology (like patriarchy) is right or wrong, good or bad – but
instead traces the effects that ideas about development produce and shows how are they
connected to larger social processes. Ideas about development shape development
interventions in ways that often fail, in terms of their development goals, but succeed in
allowing expanded bureaucratic power and in denying its political effects. Something similar
happens in discussion about patriarchy and its origins.
14. For a recent example of this in Singapore, see Heng & Devan (1995).

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