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Copyright © SAGE Publications 2009 (Los Angeles, London, New Delhi, Signapore and Washington DC) 1468-7968
Vol 9(1): 75–93; 099905
DOI:10.1177/1468796808099905
http://etn.sagepub.com

What is living and what is dead

in multiculturalism
GEOFFREY BRAHM LEVEY
University of New South Wales, Australia

John R. Bowen, Why the French Don’t Like Headscarves: Islam, the State,
and Public Space. Princeton, NJ: Princeton University Press, 2007. x + 290
pp. ISBN 0-691-12506-6.
Tariq Modood, Multiculturalism: A Civic Idea. Cambridge: Polity Press,
2007. viii + 193 pp. ISBN 978-0-7456-3289-6.
Anne Phillips, Multiculturalism Without Culture. Princeton, NJ: Princeton
University Press, 2007. 202 pp. ISBN 978-0-691-12944-0.
Joan Wallach Scott, The Politics of the Veil. Princeton, NJ: Princeton
University Press, 2007. x + 290pp. ISBN 978-0-691-12543-5.

Multiculturalism as a public policy was born fewer than 40 years ago, yet
everywhere today it is on the nose. Inaugurated in Canada by the Trudeau
government in 1971, and adopted in a modified form by Australia a few
years later, the 1980s and early 1990s saw multicultural policies introduced
in many countries, including Britain, the Netherlands and Germany. As in
Britain, such policies did not always issue from a state commitment to
multiculturalism. In the US, where it is not official government policy at any
level, multiculturalism arose as a protest movement from ‘below’ among
African Americans and other assorted identity groups who felt that the
‘difference-blind’ policies flowing from the 1964 Civil Rights Act were not
working for them, and that henceforth their difference should be a matter
of emphasis and pride. Whose cultures and ‘narratives’ are taught in college
curricula thus became a key multicultural issue there (Glazer, 1993). Even
France, arguably the most resistant democracy to the recognition and

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76 ETHNICITIES 9(1)

accommodation of cultural differences, briefly witnessed a ‘differentialist’

turn in public discourse and, to a lesser extent, public policy in the 1970s
and early 1980s (Brubaker, 2001).
What distinguishes multiculturalism from other, long-established
arrangements of minority cultural rights – such as those built into the
constitutions or constitutive political arrangements of Belgium and Sweden
in the West, Israel in the Middle East and Singapore and Malaysia in the
East – is not always obvious. But, as Tariq Modood (pp. 6–8) observes, a
distinguishing feature of multiculturalism is that it emerges from the
implicit or explicit attempt to honour liberal or democratic egalitarianism
and citizenship. That is, multiculturalism is the child of the liberal demo-
cratic values of liberty, equality and fraternity. The debate largely has been
about whether it is a legitimate or bastard child.
Against this background, the shift in sentiment against multiculturalism
in recent years may seem like deja vu. After all, influential critiques
decrying multiculturalism as misguided political correctness that disunites
society and undermines national identity have been around for decades
(e.g. Blainey, 1984; Hughes, 1994; Peter, 1981; Schlesinger, 1991).
However, it is fair to say that the reaction against multiculturalism has
been steadily gathering force among scholars, policy-makers, governments
and mass publics over the past decade or so (Barry, 2001; Brubaker, 2001;
Entzinger, 2003; Joppke, 2004). The recent animus is distinctive, perhaps,
only in that it has been occasioned by a set of developments bound up
with Muslim immigration to western liberal democracies, and the coinci-
dent rise internationally of militant Islam. As a result, the intellectual and
polemical critiques of multiculturalism are now witnessing public policy
shifts rather more readily than they once did. For example, the reforms to
multicultural policy that the Netherlands introduced in the 1990s took a
much more concerted turn in the wake of the murder of the filmmaker
Theo van Gogh by a Muslim radical in 2004. In France, Jewish and Sikh
students had been wearing religious signs to state schools for ages without
incident; it was only when Muslim schoolgirls sought to wear the hijab to
state schools in the dozen years from 1989 and, especially, after 2001, that
the French public and state became increasingly agitated to the point of
banning all such conspicuous signs in 2004. In Canada, Catholics and Jews
had been allowed to use their respective religious tribunals as alternative
dispute resolution avenues for many years; it was only when Muslim
Canadians sought the same recognition for Sharia institutions that Canada
ruled against all such facilities in 2005. And in Australia, in early 2007, the
federal government ceased using the word ‘multiculturalism’ in favour of
‘citizenship’ and ‘integration’ in the wake of a series of local and inter-
national events involving Muslims. Suddenly, with Islam and Muslims, the
boundaries of the tolerable are deemed to have been stretched so far that
they are now snapping back rapidly in the opposite direction.

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Still unclear is what they are snapping back to. On the one hand, many
observers see in these developments and the rise of citizenship and
language tests a regrettable return to the harsh nationalistic and assimila-
tionist models of old. On this view, the contemporary emphasis on ‘integra-
tion’ is really only a thinly disguised call for rank conformity to the
dominant culture. Even Will Kymlicka, who famously proclaimed, in 2001,
that multiculturalism had won the day and was now the accepted orthodoxy
in the academy, has ruminated more recently on multiculturalism’s sliding
fortunes and dim prospects in practice internationally (Kymlicka, 2001: 32;
2007). On the other hand, announcements of multiculturalism’s demise
seem decidedly premature. For one thing, many of the specific statutes,
policies and guidelines fashioned in its name remain standing in various
countries. Among these are anti-discrimination laws covering ‘indirect
discrimination’ that adversely impacts minorities, exemptions for minority
practices or the observance of minority festivals, publicly funded inter-
preter and translation services and grants-in-aid to ethnocultural associ-
ations. Similarly, the recent adoption of language tests for immigrants by
many liberal democracies is aimed at encouraging proficiency in the lingua
franca; there is little interest in outlawing or discouraging the speaking of
other languages as well, unlike in the heyday of assimilationism. Indeed,
much of the anxiety over multiculturalism seems to be semantic and
semiotic – that is, it concerns the word itself for allegedly sending the wrong
signals to immigrants that cultural relativism reigns and ‘anything goes’.
Thus, liberal democracies today seem to be in something of a state of
limbo regarding multiculturalism: retreating from it in certain policy
respects and suspicious of the word, but, at the same time, institutionally
and attitudinally reshaped by its commitments and norms; reaching for a
new idiom and a renewed emphasis on commonality, yet reluctant to quash
diversity and reinscribe brute assimilationism. Detecting an apparent
‘return of assimilation’ in France, Germany and the US in the 1990s, Rogers
Brubaker (2001: 531) helpfully suggested that the return is not to the ‘old,
analytically discredited and politically disreputable “assimilationist” under-
standing of assimilation’ but to a more complex notion. As it turned out,
this suggestion proved a tad premature in relation to France. Nevertheless,
while there is little doubt that we are not all multiculturalists now (see
Glazer, 1997) – and surely never were – multiculturalism, in some sense, still
seems to be an important ingredient in the more complex notion that many
liberal democracies are now reaching for. But what is this sense of multi-
culturalism that remains vital and perhaps unavoidable? And what in multi-
culturalism is dead or no longer worth saving?
The four books reviewed here provide valuable purchase on these
pressing questions. Joan Wallach Scott’s The Politics of the Veil and John
Bowen’s Why the French Don’t Like Headscarves each treat the French
case as a cautionary tale about the perils of assimilationism and what liberal

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democracies should not do. The stories they tell often overlap, but also
interestingly diverge in emphasis. Tariq Modood’s Multiculturalism: A
Civic Idea and Anne Phillips’s Multiculturalism Without Culture are, in
contrast, theoretical elaborations and defences of multiculturalism. They,
too, agree on several points, but approach the subject from very different
perspectives. Taken together, these four fine books help locate, I suggest,
where we are in the multiculturalism debate, why we are there and what we
might expect going forward.

THE FRENCH LESSON

Few issues have animated French public life like the so-called affaires des
foulards. Beginning in October 1989 with three Muslim girls refusing to
remove their hijab while attending their middle school in Creil outside
Paris, the affair was rekindled in 1993 by political efforts to have ‘ostenta-
tious’ religious signs prohibited in schools – this against the background of
the civil war and Islamic fundamentalism in Algeria. These efforts proved
fleetingly successful with a decree by education minister François Bayrou
in September 1994 that the courts and the State Council soon overturned.
The affair dramatically erupted again in 2003 with then interior minister,
Nicholas Sarkozy, insisting that Muslim women remove their headwear for
identity photographs, the National Assembly establishing a body to inves-
tigate the extent of the headscarf problem and President Jacques Chirac
appointing a commission headed by Bernard Stasi to consider the need for
a legislative response. Come September, public attention was focused on
yet another case of girls refusing to remove their headscarves at school, this
time involving two Muslim sisters fascinatingly named Lévy (whose father
declared himself to be a ‘Jew without God’ and whose Kabyle mother was
baptized a Catholic during the Algerian war). Finally, the affair culminated
amid extraordinary public controversy in March 2004 with a law banning
the wearing of ‘conspicuous’ signs of religious affiliation in state schools.
How, then, could something as seemingly innocuous as a headscarf worn
by a few schoolgirls spark such political turmoil and be considered so
threatening to the French nation? This is the question that Scott – an
historian and influential scholar in gender studies with the Institute for
Advanced Study, Princeton – and Bowen – an anthropologist at Washington
University – each seek to answer.
For Scott, the key to the explanation is French racism pure and, as it
turns out, not so simple. At least since the 1830s and its colonial ventures
in North Africa, the French, she argues, have thought of themselves as a
superior culture whose mission it was to civilize France’s colonial subjects.
And, in French eyes, no people were more in need of this civilizing than the

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presumptively coarse and inferior Arabs and Muslims of North Africa. In

the postcolonial era, France has simply applied its ‘civilizing mission’ to
Tunisians, Moroccans and Algerians as immigrants instead of as colonial
subjects. But there is a catch, she says. In both cases – colonial and post-
colonial – the notion of a civilizing mission implied that North Africans
could be assimilated to French ways of life. Yet, French conceptions of
Muslims and Arabs – ranging over religious practices, presumed sexual
proclivities, emotional responses and family organization – often imagined
them as essentially unassimilable. No matter what they did, believed or
looked like, Arabs/Muslims were indelibly different and inferior, beyond
redemption. One symptom of this racist history and social bind, Scott
suggests, is that even though the ‘offending’ Muslim schoolgirls were
wearing a foulard or headscarf – with their face clearly visible and only their
hair, ears and neck covered – French discourse quickly adopted the term
voile (veil) in discussing the issue. Even when Muslim girls’ faces were, as
it were, staring them in the face, and even though headscarves have long
been choice accessories in French women’s apparel, the French saw the
Muslim schoolgirls as veiled and hidden. And as Scott (p. 45) puts it, ‘in
French eyes, the veil has long been a symbol of the irreducible difference
and thus the inassimilability of Islam’.
These dynamics cut to the core of France as an immigrant nation since
the vast majority of foreign-born French citizens – roughly, 10 percent of
the population today – are from North Africa. Indeed, as Riva Kastoryano
observes, in France, ‘immigrant’ has long been synonymous with North
African while all North Africans are assumed to be Arabs (which they
are not), and all Arabs are assumed to be Muslims (which they are not)
(Kastoryano, cited in Scott, p. 17). As with prejudice everywhere, stereo-
types are superimposed on stereotypes, and there is little escaping the
process of ‘othering’.
Of course, other factors were in play. Scott devotes a chapter each to
secularism, individualism and sexuality, although sometimes the impression
is given that these factors had only supporting roles. ‘Racism was the
subtext of the headscarf controversy’, she writes, ‘but secularism was its
explicit justification’ (p. 90). In contrast, in his conclusion, Bowen (p. 246)
notes that French racism may have been a factor only in passing; his book
credits the force and complicated history of French secularism much more
fully as a factor in its own right. But he also discusses ‘communalism’ (the
flipside of Scott’s ‘individualism’) and ‘Islamism’ as a specific iteration of it,
and ‘sexism’ as additional parts of the puzzle. So, what of these other
factors?
Proponents of the ban on headscarves typically invoked France’s distinc-
tive commitment to public secularism or laïcité. Dating back to the after-
math of the Revolution and the attempt to keep the Catholic church at bay,
and formalized (and refashioned) in the law of 1905, France’s approach to

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secularism is less about separating church and state and protecting each
from one another (as in the American model) than it is about the protec-
tion of individuals from religion, and thus also – and perhaps paradoxically
– about publicly controlling religion. In the headscarves affairs, laïcité thus
dovetailed with a second key principle of the French republican model –
individualism. In the same way that freedom of religious belief is to be
respected, but is considered a private matter, French public life is imagined
to comprise only autonomous individuals, who, in sharing the status of
citizen, belong, first and foremost, to a community of equals whose primary
identity is French and whose first allegiance is to the French state and
nation. Ethnic and religious group identities, while permitted, are again
supposed to be confined to the private sphere, not publicly visible, and
always subordinate to French identity. The hijab worn by some Muslim
schoolgirls was thus perceived as a triple assault on French norms: the intru-
sion of religion into public space, the exhibition of particularistic identities
or communalism and – what was arguably worse – foreign political alle-
giances over French identity and allegiance; and the denial of these girls’
autonomy to dress how they wished rather than how their fathers and
brothers wanted them to appear.
Each of these perceptions was seriously skewed, as both books compre-
hensively show, and as we soon see. The two books also converge in their
interpretation of the significance of sexuality to the controversy. Both
suggest that the French are made uncomfortable by Islam’s public exhibi-
tion of clearly defined gender roles in Islam because it highlights their own
hypocrisy regarding the supposed equality between the sexes in French
society. The latter proclaims such equality but practises and, indeed,
expects gendered roles and sexual inequality, especially in the name of
femininity. As Bowen (p. 220) puts it, ‘here was a social group [Muslims]
that outdid Frenchmen in dominating their women’. Bowen also explores
the ‘specific quality of French feminism’, namely the emphasis on (repub-
lican) mixité between the sexes in contrast to American sex-separatism.
This, he suggests, helps explain the hostile reaction of many French
feminists to Islamic practices of gender separation, such as exclusive-use
times for women at swimming pools.
It should be clear even from the above small sample that both books are
enormously rich in detail and thought provoking in their interpretations.
While it is perhaps tempting to press them on their respective emphases –
racism vs republicanism – searching for ‘primacy’, in this case, scarcely
seems fruitful. For example, since the 19th century, state schools in France
have been charged with the responsibility of inculcating the values of the
Republic, and this probably helps explain why it was Muslim girls at these
schools that caused all the fuss, and why there was no attempt to ban the
hijab at universities or in public places in general (a point in favour of the
‘republican’ explanation). Yet, the furore was specifically over the hijab,

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and not other religious signs, at state schools (a point for the ‘racist’ expla-
nation). Or take the New Republic’s review of Why the French Don’t Like
Headscarves, which suggested that the headscarf controversy was driven
mainly by a factor unnoticed by Bowen, namely, that the state’s authority
was being challenged:

The crucial factor may not be that Muslim schoolgirls were ‘bringing religion’
into the schools, but that they were actively defying school officials. The secular
state can accommodate certain ‘public’ forms of religion, but it will not tolerate
blatant religious opposition to state authority, however minor the gesture,
however young the opponent. How else to understand Chirac’s extraordinary
statement, on December 5, 2003, that the headscarf is ‘a kind of aggression
difficult for [the French] to accept’ . . .? (Bell, 2007)

But the fact is that from 1989 to 2003, Muslim schoolgirls simply
wishing to wear a headscarf at school were not defying state authority. On
the contrary, and as Bowen discusses in great detail, the constitution guar-
anteed freedom of religious expression and the courts and the State
Council had all supported the right of these girls to wear the hijab at
school. The provisos were that the wearers did not proselytize or cause
disorder, and the onus was on head teachers to show how a girl had done
specific things that breached these conditions. This formula only began to
change in the wake of the 2001 World Trade Centre attacks when, in the
new charged climate post-9/11, the very act of wearing a hijab at school
was increasingly deemed to be divisive and disruptive. The ‘challenge to
authority’ argument overlooks the facts of the case. Nor are Bowen and
Scott hard pressed to explain remarks that the headscarf is an ‘aggression’:
they interpret them as alluding, variously, to an attack on the neutrality
of public space and on the unity of the French nation, a violence perpe-
trated on women’s bodies and an affront to one’s fellow citizens in
signalling special piety and moral superiority. The only sensible conclusion
regarding the headscarf controversy is that it was ‘overdetermined’ (Scott,
pp. 18, 115).
The more important question, at least for present purposes, is what may
be learnt from the French case. Both books conclude that the episode
harbours lessons for other liberal democracies. Bowen even holds out hope
that France itself might wise up as a result of the experience. In fact, the
books discuss three quite different problems in the French case without
always distinguishing them. One is the French republican model considered
in the abstract. On this model, France seeks to realize the tricolour values
of liberté, egalité and fratenité through a rigorous observance, in the public
sphere, of individualism (and correlative denial of communalism), secular-
ism and, putatively, gender equality. Clearly, such a model denies public
space for minority differences, and, while perhaps motivated by a well-
meaning concern for integration, equality and a unified nation, actually

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ends up excluding and marginalizing segments of the population and

dividing the nation.
A second problem concerns the fact that the French republican model
is, in any case, largely mythic. Over and over again, Scott and Bowen make
the point that historically France has made all sorts of accommodations of
difference in practice that are at variance with the idealized republican
model. As noted, for years Jewish boys had worn yarmulkes and Sikhs
turbans to state schools without incident. Yet French political leaders, intel-
lectuals and majority public opinion sought to insist on the terms of the
idealized model when it came to Muslims and Islam.
The third problem differs from the previous two in that it does not
necessarily cast doubt on French republicanism in theory or in practice.
Through their case material and interviews, both authors canvass the often
deeply and personally reflective decision-making that lay behind many
Muslim girls donning the headscarf. The Lévy sisters, who wore the hijab
against their father’s wishes, are a case in point. Indeed, one of Bowen’s
interviewees remarks that it was precisely thanks to France and its religious
freedom that she came to learn about Islam and to be a practising Muslim,
whereas in North Africa she had always found Islam ‘too traditional and
troublesome’ (p. 72). While cases of coercion and politicization of the hijab
doubtless occurred, many girls wore the headscarf as a matter of personal
choice, religious conviction or self-expression. In other words, notwith-
standing the strictures against communalism, the practice of wearing a hijab
often conformed to the cherished republican principles of individualism,
autonomous agency and women’s equality. Here the problem was that
Muslims and Islam were mythologized, not republicanism; they were
imagined to involve the denial of women’s autonomy and equality by
definition.
Some might argue that the French case is too distinctive to be of much
relevance to other democracies. But Scott and Bowen are surely right in
drawing attention to the illiberal, perverse and counterproductive conse-
quences that can flow from policy regimes that bluntly insist on sameness
and assimilation among the citizenry. Moreover, implicit in the French story
– and in much of Scott’s and Bowen’s respective analyses – are two aspects
that have wide currency in liberal thinking and in the daily life of liberal
societies. One is the deep assumption in so-called ‘Enlightenment’ liberal-
ism (Galston, 2002) that the observance of religious and cultural traditions
is perforce a matter of blind faith and obedience. Conflict or divergence
between the individual’s and the group’s practices is evidence that the indi-
vidual’s critical faculties are at work; conformity to tradition or convention
is taken as evidence that they are not. ‘The human faculties of perception,
judgement, discriminative feeling, mental activity, and even moral prefer-
ence, are exercised only in making a choice’, writes John Stuart Mill. ‘He
who does anything because it is the custom makes no choice’ (Mill, 1972:

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116). That one might deliberately and independently choose to follow

custom for custom’s sake is not thought a possibility. The liberal suspicion
towards custom (and especially religious customs) is accompanied, ironi-
cally, by the pervasive tendency among national communities to construe
liberal democratic (and republican) values in the terms of their own
national-cultural customs. Thus, as Scott (pp. 82–3) wryly observes, a ‘girl
in a headscarf was a member of a “community”, but a girl in a miniskirt was
expressing her individuality’. Or as Bowen (p. 247) puts it, ‘some Muslim
immigrants find that the one-way direction of “integration” requires too
little of those who drink wine and wear berets, and too much of those who
prefer tea and headscarves’. The tendency to conflate liberal democratic
values with the sentiment ‘this is how we do things here’ is understandable
enough given the subliminal force of cultural norms, and need not be racist.
But precisely for this reason, the tendency needs to be doubly scrutinized
if liberty and equality are to be protected.
The Politics of the Veil and Why the French Don’t Like Headscarves leave
readers in no uncertain terms about the self-contradictions and practical
dangers inherent in assimilationist or ‘one-way integration’ policies in the
name of liberty, equality and fraternity. They show, lucidly and incisively,
how liberal democracies should not go about dealing with cultural diversity.
However, beyond endorsing a generally more accommodationist approach
of ‘two-way integration’, these books do not really tackle the question of
how liberal democracies should respond to the cultural diversity in their
societies. After all, what exactly is two-way integration? What should be its
terms and limits? How far should liberal states go in adjusting their laws
and institutions to accommodate cultural minorities? These questions
return us to the state and fate of multiculturalism. In particular, they mean
confronting the question of whether multiculturalism matches French
republicanism in going too far, albeit in the opposite direction.

WHAT IS LEFT OF MULTICULTURALISM?

Modood’s Multiculturalism: A Civic Idea and Phillip’s Multiculturalism

Without Culture were written in response to the backlash against multi-
culturalism now sweeping the world. Both authors thus have their eyes wide
open to the alleged pitfalls of multiculturalism, while seeking to defend a
certain version of it. Yet, their versions are very different: whereas Modood
approaches multiculturalism via a broadly democratic politics paradigm,
Phillips does so via an essentially liberal one. The two approaches thus
effectively bookend the liberal democratic debate over multiculturalism.
But, as we shall see, it is their points of agreement as much as disagreement
that help chart the likely shape of multiculturalism in the future.

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Although Multiculturalism: A Civic Idea is a small book written for a

general readership – it being a distillation and development of arguments
Modood has made elsewhere (e.g. Modood, 2005; Modood and Kasto-
ryano, 2006) – it is likely to be the more provocative of the two books.
Indeed, one critic has recently cited Modood’s position on equality as
evidence that multiculturalists endorse cultural relativism (Malik, 2008).
The charge is unfair (as usual), but it is not hard to see why the book might
be read this way. Modood is a sociologist as well as a political theorist at
the University of Bristol, and he approaches multiculturalism first and
foremost as a political and social phenomenon, anchored in the conditions
of lived experience. He rejects approaches that seek to derive multi-
culturalism from philosophical accounts of the importance of culture or
even of liberal democratic principles. (He devotes a chapter, for example,
to critiquing the ‘liberal bias’ and ‘culturalism’ of Will Kymlicka’s well-
known liberal theory of cultural rights.) Rather, it is better, he says, to ‘build
[multiculturalism] up from the specific claims, implicit and explicit, of the
postwar extra-European/non-white immigration’ (p. 40). In doing so, he
makes two sets of arguments designed to produce a multiculturalism that
respects diversity both within and among groups.
First, instead of ‘culture’ – which he sees as too constraining and as
encouraging the tendency to essentialize groups – Modood employs the
categories of ‘difference’ and ‘identity’. ‘Difference’ is said to have the
advantage of including not just aspects arising from within the group but
also the negative definitions of those outside. That is, multiculturalism is
largely about groups reacting to negative or limiting or oppressive catego-
rizations emanating in the wider society and seeking to transform them into
positive forms of appreciation and recognition. Indeed, groups are them-
selves constituted and shaped through this process. Similarly, the concept
of ‘identity’ is said to allow greater self-definition on the part of minority
group members, who are not then beholden to observing their traditional
cultures as the only authentic expression of their difference. Identities,
Modood rightly notes, may outlive as well as diverge from the cultural
contexts that helped give rise to them.
Second, Modood (p. 39) sees the ‘struggle’ for recognition of one’s
difference and identity as fundamentally a quest for belonging and equal
citizenship. Here, he draws on some of the points developed by ‘philosophi-
cal multiculturalists’. Following Charles Taylor (1992), he distinguishes
between ‘equal dignity’, or the kind of equality that addresses the common
humanity or common citizenship status of individuals, and ‘equal respect’,
which addresses the particular group identities and collective interests indi-
viduals may have. Failing to recognize or misrecognizing an individual’s
group-based difference is, on this view, a form of oppression. Thus,
Modood is critical of what he calls ‘ideological secularism’ or the attempt
by many liberals to treat religious groups differently from other identity

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groups, confining them to the private sphere and debarring them from
public expression or support. Rather, he endorses a form of ‘institutional
secularism’, which, while ensuring an appropriate separation between state
and religion, nevertheless allows for the state accommodation and support
of religious group interests like any other group’s interests.
Following Iris Young (1990), he maintains that while equality may be
framed in terms of applying a uniform set of rules or conventions, it may
also and more fully be understood as applying a set of rules and conven-
tions that does not disadvantage the interests of any of the parties subject
to them. Thus, he argues that taking equality and groups’ interests seriously
means that different groups will likely be accommodated in different ways
and to different degrees. Indeed, he distinguishes multiculturalism from
other forms of ‘two-way integration’ largely on this basis: it recognizes the
social reality of groups (and not just individuals), and ‘it is taken to work
differently for different groups’ (p. 48), such that a truly multiculturalist
society is a ‘variable geometry’ (p. 83). So, for example, Muslims might
model their organization and representation to the state on the Board of
Jewish Deputies in Britain, or on the established model for faith communi-
ties in France, but there should be no compulsion that they follow these
precedents. They should be free to organize and liaise with the state in ways
that work best for them, which also means that some Muslim groups may
choose to organize separately from each other and liaise independently
with the state (see Modood and Kastoryano, 2006: 173).
Modood offers a fresh and compelling perspective on multiculturalism.
His account of the politically grounded, contestative character of multi-
cultural politics is a vital reminder that multiculturalism emerges from, and
is a response to, real world politics, and is not simply the product of the
feverish, politically correct imaginations of leftist intellectuals and policy-
makers (as its critics like to suggest). His rejection of culturalism – strongly
shared, as we see, by Anne Phillips – in favour of fluid and diverse kinds of
identity nicely sidesteps the problem of the reification and essentialization
of groups and group identity, which plagues much of the discourse on multi-
culturalism. And his insight, under the rubric of ‘political multiculturalism’,
that minorities are, in some sense, recreated as well as propelled into agitat-
ing for recognition as a result of the negative ways in which they are already
being perceived and treated is extremely important, and needs to be
reckoned with.
Still, some questions remain. Even if multiculturalism emerges from real
political struggles, is this where – in theory and in policy – it should end up?
After all, Taylor (1992: 60–1) framed his argument for equal respect in
relation to ‘distinct societies’ and bounded cultures (Quebec being his
paradigm case), where the interest is a culture’s survival. Modood, as we
have seen, rejects this kind of defined culturalism, seeking to apply the
‘equal respect’ argument instead to the more open and contingent notions

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of identity and difference. But this move multiplies the potential claimants
for equal respect exponentially, and effectively lowers the bar for what
constitutes breaches and thus oppression. Is every failure to publicly recog-
nize a group’s identity and difference really a case of oppression? Might not
some (many?) instances of non-recognition or misrecognition simply be
inconvenient or unfortunate or even unremarkable? It seems far-fetched,
for example, to claim that Muslim and Jewish citizens of western democra-
cies are being oppressed or undergoing psychological damage because
there is not a public holiday recognizing an Islamic or a Jewish festival as
their Christian fellow citizens enjoy with Christmas and/or Easter (Levey,
2006). In short, we need some criteria for differentiating among identity and
difference claims, and for sorting out which warrant equal respect in the
form of public recognition, which warrant equal respect perhaps in some
other way, and which do not warrant equal respect at all.
This last question is, of course, crucial in a liberal democracy. Taylor
understood ‘equal respect’ to be an iteration of liberalism; even in its most
‘hospitable’ (to difference) version, it insisted on some fundamental indi-
vidual rights. Modood (p. 8) is ambivalent about liberalism: ‘In my view,
multiculturalism could not get off the ground if one totally repudiated liber-
alism, but neither could it do so if liberalism marked the limits of one’s
politics.’ So which aspects of ‘liberalism’ should not be repudiated? And
how do these aspects not mark the limits of (acceptable) politics? Modood
does not engage these questions directly. He stresses the importance of
equality in relation to groups, and says little about the place of individual
rights in a defensible multiculturalism. Yet, he clearly accepts such rights as
limiting conditions. He would outlaw practices that ‘would be unacceptable
to just about everybody’ (child sacrifice, sati, cannibalism) or even ‘for
many’ (cliterodectomy), because ‘Recognition should not infringe the
fundamental rights of individuals or cause harm to others’ (p. 67). Funda-
mental individual rights, the ‘no harm’ principle and perhaps other aspects
of liberalism do indeed, then, frame Modood’s multiculturalism. This much
is not surprising in a multiculturalism intended to comport with liberal
societies. However, what is missing is some elaboration of which individual
rights should be considered fundamental, and of how they inform the
assessment of claims based on identity and difference.
It is here that Anne Phillips joins the debate with her book Multicultural-
ism Without Culture. Phillips shares Modood’s concerns about the essen-
tialization and reification of culture and group identity. But where
Modood’s thinking about multiculturalism is informed principally by the
situation of Muslims today and emphasizes equality between groups,
Phillip’s thinking is informed primarily by the situation of women, where
equality between groups is advanced only on the basis of equality between
the sexes and the rights of individuals within groups. As the late Susan Okin
(1999) noted, many minority cultural claims revolve around controlling

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women, and specifically their sexuality and reproductive capabilities.

Phillips – a political theorist and gender studies scholar at the London
School of Economics – agrees with Okin’s observation, but not with her
quick condemnation of all such minority practices and rejection of multi-
culturalism. She notes how the stock arguments both for and against
multicultural accommodation tend to treat cultures in unduly fixed terms.
On the one hand, membership of minority cultures is considered involun-
tary, and their members are seen as non-autonomous, whose options are
deeply constrained by their cultures. While for many multiculturalists these
are reasons for cultural accommodation, for their critics (such as Okin),
they are reasons for the state to ‘liberate’ minorities from these cultures.
On the other hand, the majority culture is assumed to be culturally neutral
or else to enjoy a wholly open culture of freedom and equality, whose
members are fully autonomous agents. These assumptions about minority
and majority cultures are not only stereotypical and simplistic, but, in many
cases, demonstrably false. They have helped to fan the current reaction
against multiculturalism around the world.
What is called for, then, is a more realistic and careful approach to
cultural matters. Phillips’s arresting suggestion is that culture should be
treated much as gender and class are treated:
. . . it has proved difficult in the debates around multiculturalism to allow for the
relevance of culture without making culture a determinant of action . . . this is
perplexing, given the relative ease with which law courts, governments and
popular opinion have come to differentiate influence from determination in
regard to gender or social class. (p. 131)

In practice, treating culture along the lines of gender and class means
that courts and governments should adopt nuanced and more targeted
responses to minority cultural practices instead of blanket judgements and
bans. Thus, in clear reference to the French case, Phillips argues that there
is no justification for assuming Muslim girls are coerced into wearing their
headscarves, even as an administrative convenience. As difficult as it may
be to establish coercion in some cases, governments should intervene only
where they have evidence of such coercion, and otherwise not violate girls’
right to dress as they please, even if socialization lies behind their choices.
Cases of indirect discrimination against cultural minorities are also better
handled on the gender and class model, since there is no need to make any
assumptions about identity or the impossibility of acting otherwise given
one’s gender, class or cultural background. One only has to ‘demonstrate
that it is harder – though not impossible – for people of one cultural group
to meet [a particular] requirement’ (p. 113). Importantly, Phillips allows
that showing adverse impact is not the end of the story, as there may be
competing security, public health or national-cultural considerations that
legitimately recommend against redressing that impact.

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Phillips brings nuance to other areas of multicultural debate. The

problem with cultural defence in criminal cases, she argues, is not that the
cultural background of a defendant is taken into account in judging
responsibility, but rather the deterministic view of culture implicit in ‘my
culture made me do it’ propositions. At the same time, those (like
Kukathas, 2003) who argue for cultural toleration as long as individuals
have the right to exit their group do not take the pressures of culture and
group life seriously enough. It is imperative, Phillips insists, that dissenting
individuals also have an opportunity to ‘voice’ their concerns and poten-
tially reform their cultural traditions from the ‘inside’. Finally, and in stark
contrast to Modood, Phillips is leery of according powers and resources to
cultural groups. While funding for ethnocultural associations and efforts to
increase the political representation of minority group members are fine,
granting ‘regulatory authority’ to cultural groups and recognizing custom-
ary or religious law are not, since this immediately subordinates the inter-
ests of some group members, women not least among them, to those who
hold authority in the group (p. 169).
Phillips has fashioned an admirably subtle, suitably cautious and unmis-
takably liberal position on multiculturalism. Individual autonomy and
equality between the sexes are placed front and centre of the argument. The
book, though, seems strangely titled, since her objection is really to cultur-
alism or reified notions of culture, and not to culture as such, which she
accepts in spades. As she puts it in the first pages, a ‘more careful under-
standing of culture provides a better basis for multicultural policy than the
overly homogenised version[s]’ (p. 9). The central tension in the book,
however, concerns autonomy. Phillips knows only too well how slippery this
concept is. Though there are many definitions of autonomy, stipulative defi-
nition is not the problem: Phillips follows Marilyn Friedman’s perfectly
workable formulation, where autonomy ‘involves choosing and living
according to standards or values that are, in some plausible sense, one’s
own’ (quoted in Phillips, p. 101). The difficulty lies in specifying what consti-
tutes ‘choice’ and values that are plausibly one’s own in situ.
Phillips herself frames the dilemma in terms of ‘choice versus coercion’.
Locke defined coercion as that which acts on a person’s will. While there
are some minority practices that are clearly coercive in this way – such as
forced marriage, rape as a form of wife selection (among the Hmong
people) and honour killings or the threat of honour killings – they are rela-
tively straightforward to deal with precisely because they so obviously
involve force. However, Phillips (p. 126) believes that the ‘complexities of
emotional and moral pressure’ also constitute ‘literal and outright
coercion’. I tend to agree with her regarding emotional pressure. There was
a time, not so long ago, when every Jewish son knew that when his mother
said, ‘go ahead, marry your shiksa, I’ll survive’, she was actually saying ‘over
my dead body’, and that one could not keep both one’s blond, blue-eyed

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beloved and one’s mother. But saying that moral pressure and the
entreaties of one’s religious or community leaders to live a certain way for
the sake of God or one’s community are coercive seems to me to be over-
reaching. It runs the risk of making the partiality integral to most moral and
cultural communities dictatorial, which is the very thing Phillips is rightly
at pains to challenge.
Moral pressure and background cultural context nevertheless present
their own set of problems. Arguably the most challenging cases that culture
poses with respect to autonomy arise where pressures act through a
person’s will, that is, conformity, which was the great worry, in their
different ways, of Mill, Marx and Freud (Skinner, 2002). How should one
respond to women who say they want to wear the burka, for example, or
to the ‘happy housewife’, who says she wants to clean and wash and cook
endlessly for her husband and children? Autonomy presses us to consider
the conditions under which choice is served as against subverted. When are
adaptive preferences merely socialization or rational choice and when are
they something more sinister? Phillips (p. 178) is surely right that these
questions do not admit of simple or uniform answers in practice. Her own
practical suggestion is that ‘institutions should be developed that will better
enable individuals to articulate what they want’, citing as an example the
British response to forced marriage in requiring police, social workers and
teachers to give young people the opportunity to speak to them alone, away
from their parents or community representatives. Indeed, liberal democra-
cies have developed all sorts of institutions to allow their citizens to be well
informed, know their options and articulate what they want. These range
from the case-specific, such as graphic television advertisements on the
dangers of smoking, to mandating a general education. Some cultural
groups see a liberal education, in particular, as undermining their norms
and the attachment of their young members. Similarly, some multicultural-
ists will see Phillip’s multicultural prescriptions as not being nuanced or, in
Modood’s phrase, ‘geometrically variable’ enough.

CONCLUSION

Where, then, does this leave multiculturalism today? As we saw with Scott’s
and Bowen’s dissections of the French ban on headscarves, rigid non-
accommodationism, be it in the name of national culture or political prin-
ciples, is bound to backfire. I think Modood’s and Phillips’s books, taken
together, help clarify three key points about the viability of multicultural-
ism today as an appropriate response to cultural diversity.
First, culturalism is dead. Not, I hasten to add, in the sense that we
have seen the end of it; on the contrary, raw and vigorous culturalism is

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everywhere about. Rather, it is dead in that demanding accommodation in

the name of cultural authenticity or cultural relativism or preserving cultural
integrity is unlikely to win favour anymore in democracies, if it ever did. But
note it is the reified and homogenized notions of culture that have exceeded
their ‘use-by-date’, not culture. Of course, burying culturalism immediately
presents a difficulty for the term ‘multiculturalism’. The word has always
harboured an ambiguity. On the one hand, the ‘ism’ was simply meant to
designate a broad commitment to the idea of cultural recognition, accommo-
dation and state support. On the other hand, the ‘culturalism’ in the word
could be read – and often has been read – as signifying distinct and homo-
geneous cultures to which all else should defer. This is why the term ‘inter-
culturalism’, which is rather more common in continental Europe than in
the Anglophone democracies, but is now being promoted in Canada and
elsewhere to replace ‘multiculturalism’ (e.g. Bouchard and Taylor, 2008), is
not much help. The perceived trouble with multiculturalism is not – or not
only – that communities do not adequately interact with each other; it is that
they exist and interact as if they were monolithic, self-absorbed and inde-
pendent units. Having different cultural fiefdoms interrelate with each other
as suggested by ‘interculturalism’ repeats rather than solves the problem.
The term ‘multiculturalism’ will continue, then, to grate on publics and
governments. Finding a suitable alternative will be a challenge. It may be
that we will need to speak of ‘multicultural integration’ or the like instead.
Second, more than anything else, the ‘multi’ is what continues to live in
multiculturalism. Modood expresses this with his categories of ‘identity’
and ‘difference’, and Phillips does so with her insistence on the primacy of
individual autonomy. Both believe that cultural claims should be agent
driven, not ‘essence’ driven, and therefore should and will be open to
diverse interpretations within cultural groups, let alone between them.
Both also argue for equality between groups, though in very different ways
– and this, too, is instructive. Phillips’s suggestion of securing multicultural
equality through our established framework of indirect discrimination
strikes me as a sensible one. However, it has a notable limitation: as the
French ban on the wearing of conspicuous religious signs in state schools
shows, one way of avoiding indirect discrimination and differential adverse
impact is to restrict the liberty of all relevant groups. Modood’s approach
to equality is less vulnerable to this objection inasmuch as he welcomes
disparate treatment and variable outcomes for groups, as long as these
differences amount to positive and not negative discrimination. Another
way of securing the same result, but which is more in tune with Phillips’s
focus on autonomy, is to insist on a right to cultural expression that is
separate from the right to non-discrimination. Australian multicultural
policy does exactly this (Levey, 2008: 11–13).
Another area where Modood and Phillips diverge over the realization and
protection of the ‘multi’ in multiculturalism concerns group representation.

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Modood is an enthusiastic supporter of cultural groups mobilizing and

winning formal recognition from the state, and the more the merrier.
Phillips worries such recognition will promote corporatism, empower group
elites and entrench male privilege. Minority representation does, indeed,
pose a real dilemma. Government agencies need to be able to liaise with
their constitutive communities and vice versa; yet, multiculturalism seems
to overlay the iron law of oligarchy with an iron law of patriarchy. Whether
Modood’s point that dissenters should be able to form their own group and
pursue their own representation with government is enough to alleviate the
problem is an open question. Perhaps we would do well here to take a leaf
out of Phillip’s book, and reject blanket assumptions and proscriptions in
favour of treating cases on their merits.
Third, there is the conundrum of national identity. One can scarcely
argue for multicultural accommodation in the name of liberty, equality or
fraternity without including national identity and culture in the discussion.
Yet many multiculturalists ignore national identity, and Phillips is one of
them. National identity does not appear in her index. In contrast, Modood
emphasizes the importance of a shared national identity: ‘it does not make
sense to encourage strong multicultural or minority identities and weak
common or national identities’, he cautions; the former ‘need a framework
of vibrant, dynamic, national narratives and the ceremonies and rituals
which give expression to the national identity’ (p. 149). So it is surprising
to find him so coy about the content of British national identity, saying only
that it ‘should be woven in debate and discussion, not reduced to a list’
(p. 153). To be sure, national identities should be – and typically are –
works-in-progress, but the debate and discussion have to be about some-
thing. Modood worries stipulated core values – such as British prime
minister Gordon Brown’s suggestion of liberty, fairness and enterprise –
will be ‘too bland or too divisive’ (p. 152). But perhaps debating the
meaning and application of such putative core values is exactly what the
national conversation about national identity in liberal democracies needs
to be about. Does a commitment to liberty really mean that one cannot be
British unless one wears a bowler hat and eats mashed potato? Does one
really honour equality by extending state subsidies to Anglican, Catholic
and Jewish schools, but not to Muslim schools? Modood’s arguments
regarding equality and Phillip’s arguments regarding autonomy are exactly
in this vein. The challenge liberal democracies face regarding national
identity lies precisely in working out where national-cultural traditions are
appropriate markers of national membership and identity and where they
are not, and what governing values such as equality and autonomy should
mean in practice. The flipside of ‘culturalism’ no longer being a legitimate
part of multiculturalism, after all, is that national culturalism also has no
rightful place. Coming to terms with this realization is likely to prove a
significant challenge for national publics in liberal democracies.

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Beyond this, multiculturalism is likely to endure in practice, if not in

name, in the suggested forms as long as liberal democracy endures. As
Modood shows so well, democracy will perforce invite the pursuit of
cultural interests and the quest for equality and inclusion like any other
interests. And as Phillips shows so well, liberal equality and autonomy will
not only support many of these cultural or identity claims, but check many
of them as well. In each case, contestation and debate are suitably central.
Multiculturalism without culturalism has a long life yet.

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GEOFFREY LEVEY is Senior Lecturer in Politics and IR/Jewish Studies

at the University of New South Wales. [email: g.levey@unsw.edu.au]

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