Struggles for Belonging: Citizenship in

Europe, 1900-2020 Dieter Gosewinkel

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Struggles for Belonging
Struggles for Belonging
Citizenship in Europe, 1900–2020
DIETER GOSEWINKEL
Translated by
RHODES BARRETT
 Great Clarendon Street, Oxford, OX2 6DP,
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First published in German in 2016 with the title Schutz und Freiheit? - Staatsbürgerschaft
in Europa im 20. und 21. Jahrhundert
English translation © Rhodes Barrett
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 referenced in this work.
The translation of this work was funded by Geisteswissenschaften International –
Translation Funding for Work in the Humanities and Social Sciences from Germany, a joint
initiative of the Fritz Thyssen Foundation, the German Federal Foreign Office, the collecting
society VG WORT, and the Börsenverein des Deutschen Buchhandels (German Publishers &
Booksellers Association).
 To
Claire, Max, Anna, and Hélène
 Preface to the English Edition (2021)

When this work appeared in German in June 2016, no one could

have guessed that it would have needed rewriting only a few weeks
later. Brexit, decided in June 2016 and executed in 2020, pulled the
United Kingdom out of the European Union—and consequently out
of European citizenship, the concluding topic in the study, thus
confirming the adage that the historian who ventures into the
present is overtaken by the future. This experience gives food for
thought. It scotches the temptation to prophecy to which scholars in
matters historical are sometimes prone. A united Europe is neither
the end-all nor vanishing point in a European history of citizenship,
which is presented here in English. There are good reasons for
publishing it in that language, even though the sole English-speaking
country among the European states under study—Germany, France,
Russia, Poland, the Czech Republic, Slovakia, and the United
Kingdom—has uncoupled from the European integration express.
Firstly, there is more to Europe than the European Union, and the
United Kingdom is joined to the continent by more deep-seated
commonalities than are apparent at first glance. They include the
legal institution of citizenship, which from the beginning of the
twentieth century developed into a common European structure of
membership. The second reason lies in the prominence of
conceptualization and research on the subject as a whole in the
English language. “Citizenship”—notably as a concept in American
constitutionalism and British welfare-state thinking in their respective
global impact—has become a lead concept in a field of global
research that communicates in English. This is also and especially
the case for Europe. Since French and German lost their standing as
European bridge languages in the twentieth century, English has
gained in importance as the key vehicle for communication in
multilingual Europe. In this language, Croats and Portuguese,
Russians and Dutch converse in publications and negotiations on
citizenship, which since 1989 has become more and more a subject
of common European concern. Externally, too, the lingua franca
English makes it easier to convey the legal and linguistic multiplicity
of citizenship traditions in Europe and to compare the position
structurally with developments outside Europe, for instance, in India
and Africa. Not least of all, this is because the state institutions and
citizenship developed in Europe were often imposed during the
colonization of areas outside Europe, leaving behind a global pattern
in the organization of political belonging in the post-colonial age.
This book is not only a translation but—to a limited degree—a
sequel to and update of the German edition. The English edition has
benefitted from the suggestions offered by colleagues. Originally, I
had implied that a fundamental function of citizenship, the granting
of equality in membership status, was all too self-evident. Equality,
along with the other fundamental functions of citizenship, to provide
protection and freedom, is now more strongly emphasized. The
pathologies of citizenship in the twentieth century often arose from
the disregard and destruction of equality, which in turn led to the
violation of freedom. Furthermore, the final chapter of the book
addresses political developments since 2016 that have had direct
repercussions for the political legitimacy and legal design of
citizenship in Europe. Apart from Brexit, they include the
consequences of the immigrant and refugee wave of 2015/2016, the
rise of anti-immigration parties and movements, the persistent
instrumentalization of citizenship for geopolitical purposes, especially
in Eastern Europe, and the erosive effect of the COVID-19 pandemic
in the European Union on freedom of movement, the essence of
Union citizenship. Moreover, important new literature up to the end
of 2020 has been taken into account.
As with the German edition, the English edition of this book has
enjoyed a great deal of support from many. First and foremost from
the sponsors of the “Geisteswissenschaften International” prize,
which the German Publishers and Booksellers Association awarded
me in 2019, making the translation possible. I wish to thank Philipp
Hölzing of the Suhrkamp Verlag for his staunch backing in proposing
the book for the prize. Gratitude is also due to the president of the
WZB Social Science Center Berlin, Jutta Allmendinger, for her rapid
and generous support for the translation. Over the years, the WZB
has proved an ideal base for my research. My thanks also go to the
Institut d’Études Avancées in Paris, its director Saadi Lahlou, and
scientific director Simon Luck for supporting the English translation
of a book much of which came into being on the Île Saint-Louis.
As fellow of the Käte Hamburger Center for Advanced Study in the
Humanities “Law as Culture” in Bonn 2016/2017 and as Alfred
Grosser Visiting Professor at Sciences Po Paris in 2018/2019, I had
opportunity to discuss the theses of the book in expert circles. I
thank above all Alain Chatriot, Marc Lazar, Paul-André Rosental, and
Werner Gephart. My gratitude also goes to Nina Dethloff and
Johannes Masing for their friendly support over and beyond
solidarity among colleagues. Thank you Mattias Kumm, my co-
director at the Center for Global Constitutionalism, David Dyzenhaus,
and Hiroshi Motomura for your generous advice and ready help in
preparing this English edition, which to my joy is being published by
Oxford University Press. I would also like to thank the anonymous
reviewers for their enthusiasm and important substantive
recommendation, as well as Jamie Berezin and Jack McNichol from
Oxford University Press for their friendly and meticulous care with
the printing. The burden of translation lay with Rhodes Barrett, who
shouldered the task like a veritable Atlas. I thank him for his
exceedingly careful work, drawing on his long experience, not least
with my texts. Amélie Günther collected new literature. Clara
Jungblut and Anna Katzy-Reinshagen devoted themselves with great
zeal to getting the manuscript into shape and processing the up-to-
date literature. For a period of time, they made another’s work their
own. My heartfelt thanks.
Even if I, as a historian, am sceptical about foretelling, I must
admit that prophecies can on occasion be fulfilled. When in 2011 this
entire book project was in difficult labour, my wife Claire de Oliveira
declared on seeing the imperial premises of Oxford University Press
in Oxford that my book would be appearing there. And so it has
come about. I dedicate this book to Claire, who believed in me, and
to our children Max, Anna, and Hélène.
Berlin, March 2021
 Preface to the Original German Edition
(2016)

In late 2015 when this study had been completed, flight and
migration to Europe had attained the highest levels since the mid-
twentieth century. The European continent, united politically since
1989 and a haven of stability and prosperity compared with
neighbouring Africa and Asia, became a place of refuge for millions
of people fleeing from war, persecution, and poverty. Citizens of
countries outside Europe, they sought the protection and freedom
that their own states failed to give them. They raise the question
that faces every form of citizenship: To what extent does the
individual enjoy protection and freedom as a member of his or her
state, as a citizen, and to what extent as a human being? The
question of territorial and personal belonging, which the freedom of
movement within the European Union had seemingly rendered
obsolete, was now doubly urgent: at both the internal and external
borders of the Union. From time immemorial borders had served to
sort out the members of a polity from non-members. And
throughout history, these borders had been not only territorial
frontiers but also legal dividing lines of citizenship. This study
addresses the issue. Citizenship has always been a membership
status constituted in terms of inside and outside, of inclusion and
exclusion. Citizenship therefore sets legal bounds and requires such
demarcations to gain substance.
Since the nineteenth century, many Europeans have personally
experienced the significance and bounds of political membership in
states. At the Moscow embassy of the Federal Republic of Germany
in 1977, I gained a vivid personal impression of this system when
witnessing “ethnic Germans” receiving passports of the Federal
Republic that allowed them at long last to leave the Soviet Union. In
Sopron on the Austro-Hungarian border in August 1989, I saw the
breached fence that for decades had symbolized and marked out the
division of Europe into opposing politico-ideological memberships.
Thousands of people swarmed westwards across the border in
search of new belonging. As a scholar, I later enjoyed working in
various European countries and feeling myself to be a “European.”
These are the sorts of experiences that accompany and enliven a
contemporary’s interest in a scholarly subject even when the work
itself begins to take on aeonic proportions. I had toiled on this
project for many years. The study owes a great deal to the people I
met and the institutions that supported the endeavour. In 2001 the
Center for Comparative History of Europe at the Free University of
Berlin and its director Jürgen Kocka supported my interest in a
project on the history of citizenship in Europe. I was able to present
first results during visits to the Maison des Sciences de l’Homme, the
École des Hautes Etudes en Sciences Sociales, and at Sciences Po
Paris. A fellowship for a year at the Institut d’Études Avancées de
Paris permitted me to complete a major part of the manuscript on
the Île Saint-Louis. I benefited greatly from the discussions with and
friendly support of Hinnerk Bruhns, Alain Chatriot, Caroline Douki,
Morgane Labbé, Paul-André Rosental, and Michael Werner. Thanks to
Hans Joas, a fellowship gave me access to truly interdisciplinary
discourse at the Max Weber Center in Erfurt. I thank the Center for
European Studies and its director Jane Caplan at St Antony’s College,
Oxford for the opportunity to spend a year contemplating the
continent from outside, from a vantage point at the scholarly heart
of a former empire. However, the home base for my work was the
WZB Berlin Social Science Center, which offered me the best
conceivable working conditions for a long-term, demanding project
straddling historical, legal, and social science. I am thankful for the
many suggestions and the support I received there. In particular I
thank Dieter Rucht and Mattias Kumm for their cooperative
collaboration. For their enormous and untiring help during the long
phase of research and copy-editing, I thank Inken von Borzyskowski,
Sarah Bianchi, Johannes Steinbrück, Henriette Müller, Dominik
Scholz, Jeannette Higiro, Jenny Neubert, Alex Berezin, Oliver
Ditthardt, and in the final stages quite particularly Lisa Kämmer and
Manarsha Isaeva. I thank Janusz Porowski, Veronika Siska, and
Richard Hermann for researching Polish, Czech, and Slovakian
sources. My thanks also to Benno Gammerl, Monika Kayser, Claudia
Kraft, Matěj Spurný, and Jakob Zollmann for reading parts of the
manuscript. As editor at the Suhrkamp Verlag, Phillipp Hölzing took
meticulous care of the manuscript from the first version on. Hartmut
Kaelble was the first to read the draft, my father Dieter Gosewinkel
then edited it and helped give it the final polish. My heartfelt thanks
go to both for bringing to bear their great experience and
engagement as historians to the benefit of the manuscript. As the
author, I of course take responsibility for anything that might have
escaped their attentive perusal.
I must thank Claire de Oliveira for very much more than her loving
encouragement and active support in the decisive years of the
project, which also unfolded in intellectual exchanges between Paris
and Berlin. I dedicate this book to my son Max Gosewinkel. As a
German and European, he has the opportunity to gather his own
experience with political belonging in the twenty-first century.
Wherever he seeks needful protection and freedom, may he be
granted them.
Berlin, January 2016
 Table of Contents

List of Abbreviations

Introduction: Citizenship—Probe into a History of Europe

1. Diversity and Demarcation: National and Imperial Citizenship
Policy around 1900
1. An Institution of Closed Statehood: Citizenship in the
German Empire
2. Nationalization through Territoriality: Citizenship in France
3. A Fragmented Status: Subjecthood in the Russian Tsarist
Empire
4. Territorial Hierarchy: “Subjecthood” in the British Empire
2. Confrontation and Conflict: Citizenship in the Struggle for
Political Belonging—The First World War (1914–1918)
1. The Limits to Equality: National Communities of Defence in
Total War
2. Deprivation of Rights, Extension of Rights: Enemy Aliens and
Citizens
3. Nationalization and Ethnicization: Citizenship Rights between
Democracy and the Racial State (1918–1945)
1. Minority Rights and Citizenship in International Law
2. National Citizenship Policy
3. Citizenship Rights between Constitutional Democracy and
Dictatorship
4. Border Control Regimes and the Crisis of State Sovereignty
5. The Second World War: Exclusion and Colonization in the
Racial State
4. Conquest and Subjugation: Hierarchies of Citizenship Rights
between Colonization and Decolonization (1900–1950)
 1. From Imperial Subjects to National Citizens: The British
Empire
2. Indigenous Subjects of the Republic: The Empire Français
3. From “Natives” to “Untermenschen”: German Colonial
Empires
4. Subjects, Soviet Citizens, and Enemy Aliens: Status Barriers
in Russian Colonialism
5. Liberalization and Community Ties: Citizenship in Divided Post-
war Europe (1945–1989)
1. Reorganizing the Post-war World: Forced Migration,
Citizenship, and Human Rights (1945–1950)
2. The Development of Citizenship Rights in Divided Europe:
Decolonization, Welfare State, and Migration (1950–1970)
3. Loosening the Bonds of the National Community: Human
Rights and Citizenship from the Cold War to the European
Turn (1970–1989)
6. Integrating Europe and Demarcating States: Towards the
Europeanization of Belonging? (1989–2020)
1. Constitutional Revolution and Citizenship Rights Since the
1990s
2. Citizenship and Migration in a United Europe
3. European Citizenship: The Europeanization of Political
Belonging?
Conclusion: Membership as Basis and Boundary for Protection,
Equality, and Freedom
1. Key Findings
2. Citizenship in Broader Context

Bibliography
Index
 List of Abbreviations

ECHR European Convention on Human Rights

ECtHR European Court of Human Rights
GDR German Democratic Republic
ILO International Labour Organization
UDHR Universal Declaration of Human Rights
 Introduction
Citizenship—Probe into a History of Europe

In 1949, the English sociologist Thomas H. Marshall gave a lecture in

Cambridge on the subject of “Citizenship and Class.” He posited that,
since the eighteenth century, citizenship had made a decisive
contribution to the emancipation of the individual from subjection to
abject poverty and social inequality and to more social justice. A
historian by training, he propounded a historical succession in the
development of citizenship: from the emergence of civil rights in the
eighteenth century to political rights in the nineteenth century and
social rights in the twentieth century.1
The text was to become a classic in the sociology of the twentieth
century. It followed in the footsteps of great analyses of society from
the first half of the century that had argued in historical terms, such
as those of Max Weber and Émile Durkheim. The scholarly message
of the work and the historical context in which it was written
favoured its advance to canonical rank.2 It was the quintessence of a
liberal, “optimistic” analysis of society whose intellectual ambition,
meticulous argumentation, and empirical intensity breathed the very
spirit of the Enlightenment. In 1949, the welfare state in Britain and
Western continental Europe was reaching a peak in development
and importance. In theoretical texts like Marshall’s “Citizenship and
Social Class,” the “trente glorieuses,”3 the three decades of singular
economic upturn and social security in the Western industrial
countries after the Second World War, found historical consistency
and political affirmation. The text was also category forming because
it embodied a narrative of progress. It told of the successful and
growing implementation of individual rights vis-à-vis the state and
the social class opponent, of the achievements of social movements
in combating social inequality, and finally, of growth in material
prosperity and social participation.
 The present book tells another story of citizenship, with a different
analytical thrust and greater thematic and spatial reach than the
work of the English sociologist. It has two objects: first, to provide
an account of citizenship as legal institution and political practice
since the beginning of the twentieth century; second, to explore the
historicization of a normative ideal of citizenship. The key question is
therefore: What are the historical conditions for the possibility—and
thus the limitations—of an ideal of progressive equality, participation,
and integration, which since the Enlightenment had been immanent
in the concept of citizenship and often invoked in its practical
implementation? This focuses attention not only on the content of
citizenship rights but also on the preconditions and forms of their
attainment. Our analysis sweeps from the opportunities of inclusion
to the risks and hardships of exclusion, from the “internal” aspect of
exercising rights to the “external,” formal aspect of their granting
and denial. It is about political interests, which in the struggle for
citizenship rights produce winners and losers; about the historical
tensions between extensive and restrictive concepts of citizenship;
and about the discursive use, functional change, and
instrumentalization of the community-building ideal of citizenship up
to and including segregation.
“Citizenship and Social Class” is rooted in a certain period and
spatial experience. Marshall used the politico-theoretical concept of
“citizenship” as a key to historical deduction and theoretical
comprehension with respect to the findings of social analysis in the
mid-twentieth century. But to what extent has “citizenship”—as
understood in this context—really been a key to explaining societal
development in Europe as a whole during the twentieth and twenty-
first centuries? Since the nineteenth century, the word “citizenship”
has had a place in the legal and social orders of all countries in
Europe.4 But what did it mean and what was its function in the
various national and political contexts? Did it everywhere and in a
similar manner signify the promotion of equality and participation in
the political practice of a turbulent “century of extremes” (Eric
Hobsbawm)? For whom did it realize the promise of protection,
equality, and freedom of the individual that was the ground stock of
citizenship, and for whom did it not do so?5
This book is about the internal aspect of citizenship rights in the
state and about the external aspect of national demarcation, as well
as inclusion in the community of citizenship and exclusion from this
community. It is about the guarantee of protection, equality, and
freedom through citizenship and its use in colonial, gender, and
political discrimination.
On closer inspection, Marshall’s biography itself provides pointers
on the meanings and functions of citizenship that raise doubts about
the unambiguity of its equalizing and socially integrative effect.
While a student in Germany in 1914, the young Englishman and
subject of the British Crown was interned like other Britons as a
civilian prisoner upon the outbreak of the First World War. In
Germany, the British guest was suddenly an “enemy alien,” who,
unlike Germans, no longer enjoyed fundamental freedoms in that
country.6 This focused attention on another—“external”—aspect of
citizenship in the sense of nationality, which alongside the “internal”
aspect, the individual rights of a citizen, had its own meaning and
function: nationality was the condition for access to citizenship
rights. In the case of the interned student Marshall, citizenship
proved a stigma, marking a first limitation. It developed a strong
national exclusionary effect and demonstrated both the personal and
the territorial limitations of citizenship rights. The freedom of
movement and exit of a Briton who by nationality belonged to an
“enemy state” was abrogated in the German Empire, and the power
of disposition over his property could be restricted.7 Only the legal
ties of diplomatic protection linked him to his home country, whose
rights he, as a British citizen, could not exercise on German soil.
Especially in international conflicts, it seemed, the nation-state
granted and denied citizenship rights by national criteria.8
A second analytical limitation of “Citizenship and Social Class”
arises from its concrete historical context of reference, namely the
history of Britain from the eighteenth to the twentieth century.
Britain was certainly the birthplace of the industrial revolution and,
as an imperial world power, a centre for the development of
citizenship rights—together with the United States and France the
most important. But since the eighteenth century, development in
the United Kingdom had been evolutionary, without recourse to
radical political forms of dictatorial or totalitarian rule. The rule of
law was fundamentally respected, and thus the separation of politics
and law, which made the formation of secure individual rights as a
basis for citizenship possible in the first place. In this Britain differed
from most states in continental Europe during the twentieth century,
which came under dictatorship. Even these authoritarian and
dictatorial regimes, which so profoundly marked the “century of
extremes” in Europe, championed the principles of citizenship and
welfare-state equality nominally and in their propaganda. But this
institution of citizenship fulfilled a different function here: to
constitute a political, social, and ethnic community and close it off
against outsiders. The aim was not to promote the equality and
freedom of individuals but to incorporate them into a homogeneous
community at the cost of freedom. Integration and inclusion became
less important than external segregation. Moreover, citizenship rights
in authoritarian regimes had not been gained by social struggles and
expanding participation of the kind familiar to Marshall from British
social movements. They were both granted and withdrawn at the
discretion of the regime. This shows that the classical concept of
citizenship as Marshall saw it provides insufficient categories for an
analytical account of European history since the twentieth century.
A third limitation of “Citizenship and Social Class” lies in the
orientation of the citizenship concept on social conflict, class
difference in the development of industrial society.9 Although, as we
shall see, citizenship rights contributed to reducing social inequality
in Europe during the twentieth century, they marked out and
reinforced processes of cultural, religious, and ethno-national
exclusion10 that find no mention in Marshall’s historical development
model. These processes include the historically deep-rooted,
enduring, and drastic exclusion of women11 and certain religious
groups from the full rights of citizenship. Then there was the use of
the institution of citizenship as an instrument of dominion to
systematically legitimize and implement hierarchical ranking in the
legal status of ethnically or “racially” defined groups,12 for example,
under colonialism. Marshall’s classical concept of citizenship captures
neither this dimension based on systematic exclusion and
segregation nor a new, opposing dimension regarding individual
rights: from the 1970s onwards, citizenship rights, frequently
reinforced by human rights standards, became the point of reference
for decidedly individualistic demands for the recognition of
otherness, of difference. Not integration in a social or political
community but the right to—cultural, religious, and so on—
difference was thus made the object and goal of citizenship. This
broader significance of citizenship has found support with the
growing heterogeneity of multicultural and multi-religious societies
since the late twentieth century.13 Forced communal socialization
and the freedom to be different have been polar dimensions of
citizenship in the development of the institution from the beginning
of the twentieth century, together with and far beyond Marshall’s
welfare-state dimension.

1 Subject
The key assumption on which this study builds, anchoring its subject
in an exposition of twentieth and early twenty-first century history, is
that citizenship became the hallmark of political belonging in Europe
over the course of the twentieth century. While estate, religion,
party, class, and nation in the “century of extremes” forfeited their
categorial and political formative power, citizenship developed into
the deciding category of political membership.14 Thereafter, being a
citizen meant exercising the concomitant rights in relation to the
equality and freedom of other citizens, and not being restricted in
doing so—or only in decreasing measure—by inequality of estate or
by membership in a certain class, religion, party, ethnicity, or nation.
Access, governed by the preconditions for and limits to the
development and implementation of citizenship rights, determines
both the object and conceptuality of citizenship. This study uses the
term “citizenship” in a broad sense in keeping with Anglo-American
usage.15 As a generic concept it couples two dimensions covering
different functions: nationality (Staatsangehörigkeit) in the sense of
membership in a state and citizenship (Staatsbürgerschaft) in the
narrower sense of citizenship rights. By nationality we mean legally
defined and constituted membership in a unified state
(Staatsverband).16 In the narrower sense citizenship refers to the
individual rights that—in principle if not without exception—are
conveyed by citizenship and for which the status of citizen is a
precondition. Nationality is the17 “external aspect” of citizenship. It
decides on inclusion in and exclusion from the community of citizens
and sets effective and politically strongly contested bounds about
citizenship rights, which are closely associated historically with the
origins and development of the nation-state. Citizenship rights in the
narrower sense, by contrast, change in content over time. They are
fought for politically, shaped and extended by the law; they often
impose duties but can also be revoked or abolished. Marshall’s three
basic types of citizenship rights—civil, political, social—are
fundamental to historical developments since the eighteenth century.
But, in twentieth-century “struggles for recognition,”18 further,
notably cultural, dimensions and legal demands have been added
that are now deemed integral elements in the modern concept of
citizenship.
We examine citizenship in this broad sense in its historical
development since the beginning of the twentieth century. The focus
is thus not on the long development of citizenship rights in major
European legal codifications since the late eighteenth century and
their close association with the founding of European nation-states.
This genesis is taken as given. Our interest centres on the critical
junctures in politics and society since the twentieth century when
the form and function of citizenship changed drastically. Citizenship
operated in a wide range of contexts: national and imperial;
dictatorial and liberal; post-colonial and post-national; and finally,
transnational. We concentrate on Europe but treat the vast territorial
and power-political expansion of the continent’s sphere of influence
during colonialism as an integral part of European history. Also
included are the major impulses that countries outside Europe,19
notably the United States of America, have given to the development
of citizenship since the eighteenth century.
Precisely because the history of citizenship in Europe in the
twentieth century was extremely fragile, protean, and profoundly
shaped by national history, we attempt no exhaustive account but
reconstruct developments based on six cases: Britain, France,
Germany, Czechoslovakia, Poland, and Russia. There are three
reasons for this selection: first, by their size and political importance,
the states under study are among those that have played a decisive
role in the political development of Europe in the twentieth century.
Second, we examine them not in isolation but in their close relations
with each other, and mutual influence—arising from territorial
proximity, historico-cultural ties, and relations of hegemony or
dependence. Third and last, our selection—spanning the traditional
divide between Eastern and Western Europe—includes countries
from both regions of the continent. Apart from size and political
significance, these neighbouring states are linked by incessant
political entanglement in conflict and adaptation traversing the
continent and shaping its history.

2 Issues and Problems

Measuring Rod for Inclusion and Exclusion?

In this book, citizenship in the twentieth century serves as a probe
for historical social analysis. What does the development of
citizenship tell us about the justification and extent of inclusion and
exclusion in twentieth-century European societies? Our point of
departure is the polarity of two fundamental political conceptions
that run through the twentieth and nascent twenty-first centuries:
the first is concerned with allowing and legally safeguarding
heterogeneity and individuality, the second primarily with achieving
homogeneity. Inclusion and exclusion20 are measured against
outward-looking willingness for inclusion and the internal plurality
and institutionalization of individual civil rights in European societies.
They manifest themselves in procedures for the admission and
inclusion of foreigners coming from outside and in the integration or
segregation of minority groups present within the state.
In both diachronic and synchronic comparison, we examine
political decision-making processes and practices in the countries
under study that reflect historical continuities and breaks in inclusion
and exclusion policy.
The polarity of inclusion and exclusion innate to citizenship as a
legally constituted institution of membership is under fundamental
tension: while the citizenship ideal championed by political theory
and the emancipation movement in European modernity promises
the individual protection in equality and freedom, in political practice
formidable exclusionary and widespread discrimination and violations
of freedom perpetrated in contravention of existing citizenship rights
or even in the name of citizenship. This book takes the gap between
ideal and political practice as given,21 spells it out, and measures it
against the critical yardstick of equality and freedom. However, the
gauge of equality is not the ideal of universal equality22 but the
equality that goes back to the historical origins of citizenship as
membership in city or state: equality grounded in membership and
limited by membership—equal rights within and lower rights
without.23 The polarity of inclusion and exclusion is treated in this
book as fundamentally legitimate.24 However, the particular shape it
has taken in historical practice is subjected to critical analysis.

Constellation Instead of Nation?

During the nineteenth and twentieth centuries, specific conceptions
of nation played a major role in explaining why a state adopted an
inclusionary or exclusionary stance on citizenship. In the literature,
the predominant historical discourse on the authoritative concept of
nation in a nation-state understands nation as a consolidated
“cultural idiom”25 that can not only influence political decisions on
inclusion and exclusion over longer periods of time but also
determine them. This rationale produces a useful, ideal-typical
dichotomy seen as having a decisive influence on the design of
citizenship: first, a political, state-centric understanding of nation
that fosters assimilation-friendly and inclusionary policy on
citizenship; second, an ethno-cultural conception of nation based on
pre-state values and the idea of the common descent of members of
the nation. Most authors see this as more strongly essentialist,
encouraging discrimination against the outside world and rendering
difficult any assimilation into the national community. Can this
dichotomous model be upheld as the dominant explanation for the
open or closed nature of a nation-state?
This book challenges the explanatory value of this model for the
European history of the twentieth century on the basis of historico-
empirical findings. It takes the view that, when it comes to radical
historical changes in citizenship, the conception of nation is only one
of numerous constitutive factors and often not the deciding one. The
institution of citizenship affects so many political, socio-economic,
and cultural areas of life that the interests and intentions of the
political actors that establish citizenship cannot clearly or even
largely be derived from a specific understanding of nation. We
therefore posit that the constitution and alteration of specific
politico-social constellations are decisive for historical change in the
institution of citizenship. By politico-social constellations we mean
the interlinkage of contextual conditions for foreign, social, and
population policy with the politically organized interests that shape
the concept and the institutional form of citizenship over a given
period. This invites the hypothesis that change in the constellation
brings about change in the institution of citizenship in the field of
tension between inclusion and exclusion. If, however, cultural
concepts of nation are only one among many factors determining
the nature and alteration of a politico-social constellation and hence
citizenship, due weight must be given to transnational explanatory
factors: influences and transfer relations not only within but also
between nation-states play a significant role in shaping the
institution of citizenship. These external factors become apparent
only in comparing European states and in the history of their
relations, as presented by this study.

Development Gap between Western and Eastern

Europe?
I set out from the assumption that citizenship is an institution
common to Europe of the legal and political order in the twentieth
and twenty-first centuries. Some, if not all,26 of its key functions27
are to be found in all European states since the twentieth century.
But how valid is this statement for the concrete design and workings
of citizenship in a given state? Can we discover an overarching
pattern in citizenship policy across states? This book looks at
whether and to what extent different “paths” of development are to
be found beneath the surface of a common European institution. In
the research, a widespread interpretive pattern positing a close link
between concepts of nation and citizenship sees a marked distinction
between Western and Eastern Europe,28 with a political,
assimilation-friendly “Western” type largely concurring with the
territorial principle set against a Central and Eastern European
ethno-cultural closure type closely associated with the descent
principle. The thesis of a conditional relationship between concept of
nation and citizenship is thus projected onto a geographical–cultural
demarcation line across Europe, a consolidated qualitative divide. Is
there an “Eastern European” path of development in citizenship that
differs specifically from a “Western European” path? Is the difference
systematic-categorial or only historically contingent?
This widespread thesis of a West–East dichotomy is critically
addressed in this book. We examine whether the specific
predominance of inclusionary or exclusionary factors can be
attributed to changing politico-social constellations or to a
geographic and cultural divide and essential differences between the
two political hemispheres in Europe. Can this critique of the
geographical–cultural essentialization of systems of nationality also
be transferred to the development of citizenship rights? To what
extent does the design of citizenship in Central and Eastern Europe
during the twentieth century continue the “modernization of Eastern
European rights” that had begun in the nineteenth century and has
since been largely overlooked by research in both cultural and legal
history?29 Even if we take account of differences in the development
of law within Eastern and Central Europe, the assumption of a West–
East modernization gap still has to be examined; it is far from
substantiated.

Repercussions of Colonization?
To what extent does the institution of citizenship operate through
the constitution of membership and non-membership, of inclusion
and exclusion essentially by generating and establishing social
hierarchies? This question primarily addresses relations of political
dependence and subordination, notably in relations between states
and within their territory. Throughout the twentieth century, the six
states under study held dominion over dependent territories or were
themselves dependent on others of the group. This was the case in
extra-European colonial expansion for Britain, France, Germany, and
Russia, and in intra-European colonization policy for Germany and
Russia or later the Soviet Union. On the other hand, during the
armed conflicts of the twentieth century, contiguous continental
states generated more and more relations of dependence and
hierarchies between states. The mutilated and violent history of
Europe in the twentieth century bears witness to this, telling of wars
that impacted the whole world, of a continent divided into political
blocs, and of the late phase of colonization and subsequent
decolonization. In these acts of usurpation, this essentially forcible
determination of membership and its hierarchical rankings, rules on
citizenship codified not only existing power structures. In the course
of territorial changes, they constituted new personal memberships
and consolidated them; they decided on state protection or
defencelessness, freedom or dependence, voice or voicelessness; on
the right to remain or enforced departure,30 and thus on existential
opportunities in the lives of millions of Europeans. This raises the
question of whether and to what extent the standardizations and
visions of ethno-racial hierarchies survived the political power
structures of colonization and occupation that had bred them. Did
not the exclusion of colonized populations from the rights of
citizenship affect the policy of belonging in the parent countries? Did
colonial discrimination produce lasting legal and social hierarchies in
post-colonial societies because of post-colonial migration? Vice
versa, to what extent did the forcible ascription of state and ethnic
membership survive the time of violent occupation and annexation
to be subsequently turned against the former occupying power by
the liberated states? In brief: Did institutionalized hierarchies of
citizenship rights draw lines of continuity in the twentieth and
twenty-first centuries that reached from political constellations of
discrimination and tyranny into supposedly secure equality and
participation?

Tool of Social Ranking

Beyond colonization and occupation, policy on citizenship established
and consolidated legal rankings and social hierarchies in the societal
orders of states. The dividing line between those who enjoyed the
full rights of citizens and those who were excluded from them is
drawn by the discourses and norms on membership politically
dominant in a society. This dividing line shifted during the twentieth
century and, moreover, was drawn differently from country to
country in Europe. Can a basic historical longitudinal trend
nevertheless be identified for Europe? Are the rights of citizenship
becoming more inclusionary? Are old forms of exclusion being
replaced by new ones?
This question concerns all groups that differ from the politically
dominant norms of membership or are perceived as deviating from
them. The spectrum ranges from newly arriving immigrants to
groups amid the old-established population stigmatized and
discriminated against as “racially” or culturally deviant. To provide a
common basis for comparison between European countries, our
account concentrates on two groups: women and Jews, who, in all
the countries under study, were either completely or in some
measure denied the rights of citizenship or restricted in their
exercise thereof over longer periods of time. The degree of and
reasons for the exclusion of these two groups from citizenship rights
are threads running through the book. Moreover, these two groups
stand out in the spectrum of discrimination in both quality and
quantity: women were the largest group to suffer systematic
discrimination with respect to their citizenship rights; and Jews were
the most severely disadvantaged minority: discrimination against
them went as far as physical liquidation.

*
In pursuit of these issues, citizenship is used as an analytical probe
in investigating the history of Europe in the twentieth and twenty-
first centuries, pinpointing differences between states but also
commonalities and transfer relations between countries and regions.
Only thus can the historical background to three related questions
be clarified that lead us to a key issue of European integration at the
turn of the twenty-first century. At the beginning of the twenty-first
century, does the institution of citizenship represent an institution of
jus publicum europaeum?31 Is there evidence that nation-state
developments in citizenship have been tending—over a century—to
converge, or does divergence predominate? In short: What does the
history of citizenship tell us about the conditions for the possibility
and the prospects for the development of a European “Union
citizenship”? To what extent does it confirm the widespread
expectation that the integration of Europe will be attained initially
and above all through the law?
 3 Sources and Literature
In writing a history of European states in the twentieth and twenty-
first centuries from the perspective of citizenship, legal sources must
be at the forefront. The point of departure for this study
consequently sets out from the legal norms on citizenship and
citizenship rights. We examine their origins and political
implementation, as well as their societal contingency and effect.
Given the broad temporal and spatial frame of comparison and the
highly heterogeneous literature situation, certain restrictive
preliminary decisions are required. We draw on published, not
unpublished, archival sources. They are above all concerned with
normative decisions of legislative and administrative actors, and in
some cases also with the practice of norm application. The latter are
primarily files of naturalization and police authorities and so on,
whereas judicial interpretations and corrections of administrative
practice are considered only in a limited number of cases.
Contemporary scholarly discourses, notable in jurisprudence, have
also often been taken into account. To draw on the individual and
collective experience of historical actors would certainly have been
enlightening but was possible only in exceptional cases. For
example, the experience of rejected applicants for naturalization and
of discriminated minorities would presumably have been just as
useful in understanding citizenship as, vice versa, the experience of
accepted immigrants with inclusion and integration. However,
experience has been considered in our argument where it found
collective political expression—for instance, in petitions and protests.
Also systematically exploited are statistics and material on the
history of populations, migration, and social development in the
countries under study.
To focus on normative sources does not mean methodologically
narrowing our investigation. All modern historiography is aware that
the politico-social effect of a legal institution can be reconstructed
only partially from its normative basis. For this reason, we repeatedly
turn to sources of population and social history, as well as
contemporary political discourses. However, the predominance of
politico-normative sources is not simply accepted as inevitable. It is
justified by both the status of research and the conceptual and
synthetic ambition of this study. Studies on the legal and social
practice of citizenship are lacking in the six countries under study.
Even in the comparatively better researched countries—Britain,
France, and Germany—that can offer well developed traditions in the
study of the classical political and theoretical concepts citizenship,
citoyenneté, Staatsbürgerschaft and Staatsangehörigkeit, there is a
paucity of historico-empirical research, for example, on the practice
of naturalization and the social distribution of citizenship rights.32
Particularly fragmentary is the research situation in the Central and
Eastern European countries in our study, where the issue dealt with
in the present book has as yet barely been addressed. Finally, what
is lacking in the existing literature is genuinely European
comparison.33 The present study is the first to attempt an historico-
empirical analysis of the politics of citizenship in both Western and
Eastern European countries. It draws on historical, sociological, and
jurisprudential research literature on all the countries under study,
and in the relevant languages. This book attempts the first synthesis
of a history of citizenship in Europe since the beginning of the
twentieth century that deals equally with Western and Eastern
Europe.
The ambition of this volume is the historical analysis from new
angles of the broad discussion on citizenship (Staatsbürgerschaft,
citoyenneté, obywatelstwo, občanství гражда́нство) and to render
the findings fertile in addressing key issues that face today’s Europe.
Our study is to be understood as a history of European statehood
since the twentieth century from the perspective of citizenship. It
addresses a public interested in the fundamental problems
encountered in the development of Europe since the end of the
nineteenth century particularly from historical, sociological, and
juristic standpoints. At issue are the historical import of and future
opportunities for European citizenship in a world of globalization.
 1 Thomas H. Marshall, Citizenship and Social Class: And other Essays
(Cambridge: Cambridge University Press, 1950).
2
From the copious literature on the reception of Marshall: J. M. Barbalet,
Citizenship: Rights, Struggle, and Class Inequality (Minneapolis: University of
Minnesota Press, 1988), 57–79; Ursula Vogel and Michael Moran, eds., The
Frontiers of Citizenship (Basingstoke: Macmillan, 1991); Jürgen Mackert and Hans-
Peter Müller, Moderne (Staats)Bürgerschaft: Nationale Staatsbürgerschaft und die
Debatten der Citizenship Studies (Wiesbaden: VS Verlag für Sozialwissenschaften,
2007); Richard Bellamy and Antonino Palumbo, Citizenship (Farnham: Ashgate,
2010); Adalbert Evers and Anne-Marie Guillemard, “Introduction: Marshall’s
Concept of Citizenship and Contemporary Welfare Reconfiguration,” in Social Policy
and Citizenship: The Changing Landscape, ed. Adalbert Evers and Anne Marie
Guillemard (Oxford: Oxford University Press, 2013), 3–34; Martin Bulmer and
Anthony M. Rees, eds., Citizenship Today: The Contemporary Relevance of T. H.
Marshall (London: University College London Press, 1996); Yasemin N. Soysal,
“Marshall, Thomas Humphrey (1893–1981),” in International Encyclopedia of the
Social & Behavioral Sciences, ed. James D. Wright (Amsterdam: Elsevier, 2015),
626–629.
3 Going back to: Jean Fourastié, Les trente glorieuses ou la Révolution invisible

de 1946 à 1975 (Paris: Fayard, 1979); Thomas Piketty, Capital in the Twenty-First
Century (Cambridge, MA: Harvard University Press, 2017), chap. 2.
4 On the beginnings of a comparative history of the relevant concepts, see

Dieter Gosewinkel, “Citizenship, Subjecthood, Nationality: Concepts of Belonging in

the Age of Modern Nation States,” in European Citizenship: National Legacies and
Transnational Projects, ed. Klaus Eder and Bernhard Giesen (Oxford: Oxford
University Press, 2001), 17–35.
5
With this issue, this study addresses a finding of the literature on nouvelle
citoyenneté that stresses the exclusionary effect of congruence between
citizenship and citizenship rights (citoyenneté classique)—albeit without construing
this finding normatively in the sense of a devaluation of nationally restrictive
citoyenneté classique. Like Dominique Schnapper (La relation à l’autre: Au coeur
de la pensée sociologique (Paris: Gallimard, 1998), 413–414, 448), I am
concerned with the “dialectics of inclusion and exclusion” in citizenship, which
necessarily treats inclusion and exclusion as connected.
6 Elmar Rieger, foreword to Bürgerrechte und soziale Klassen: Zur Soziologie

des Wohlfahrtsstaates, by Thomas H. Marshall (Frankfurt/M.: Campus, 1992), 10.

7
See Matthew Stibbe, British Civilian Internees in Germany: The Ruhleben
Camp 1914–1918 (Manchester: Manchester University Press, 2010); Daniela
Caglioti, “Property Rights in Time of War: Sequestration and Liquidation of Enemy
Aliens’ Assets in Western Europe during the First World War,” Journal of Modern
European History 12 (2014): 523–545.
 8 In detail Reinhard Bendix, Nation-Building and Citizenship: Studies of our
Changing Social Order (New York: John Wiley & Sons, 1964), 56–104; Rogers
Brubaker, Citizenship and Nationhood in France and Germany (Cambridge, MA:
Harvard University Press, 1992), 27–29.
9
Critical: Bryan S. Turner, Citizenship and Capitalism: The Debate over
Reformism (London: Allen & Unwin, 1986); Barbalet, Citizenship, 52, 56, 97–107.
10 On the function of exclusion, see Brubaker, Citizenship and Nationhood in

France and Germany, 21–23.

11
See Ursula Vogel, “Is Citizenship Gender-specific?,” in The Frontiers of
Citizenship, Ursula Vogel and Michael Moran (Basingstoke: Macmillan, 1991), 58–
85; Ruth Lister, Citizenship: Feminist Perspectives, 2nd ed. (Basingstoke:
Macmillan, 1997), 68, with double critique of Marshall in so far as he overlooks
“gender” as a category (of exclusion), while—contrary to Marshall’s temporal
sequence—women often acquired political rights before citizenship rights; on the
historical struggle of women for independent citizenship as wives and against
“marital denaturalization,” see Helen Irving, Constitution, Alienage and the Modern
Constitutional State: A Gendered History (Cambridge: Cambridge University Press,
2017).
12 See William Julius Wilson, “Citizenship and the Inner-City Ghetto Poor,” in The

Condition of Citizenship, ed. Bart van Steenbergen (London: Sage, 1994);

Emmanuelle Saada, Les enfants de la colonie: Les métis de l’Empire français entre
sujétion et citoyenneté (Paris: La Découverte, 2007); Rieko Karatani, Defining
British Citizenship: Empire, Commonwealth, and Modern Britain (London: Frank
Cass, 2003); Eric Lohr, Russian Citizenship: From Empire to Soviet Union
(Cambridge, MA: Harvard University Press, 2012).
13
See Will Kymlicka, Multicultural Citizenship: A Liberal Theory of Minority
Rights (Oxford: Clarendon Press, 1995; Will Kymlicka and Wayne Norman, eds.,
Citizenship in Diverse Societies (Oxford: Oxford University Press, 2000).
14 Dieter Gosewinkel, “Citizenship as Political Membership: A Fundamental

Strand of Twentieth and Twenty-first Century European History,” in Boundaries of

Inclusion and Exclusion, vol. 2 of The Transformation of Citizenship, ed. Jürgen
Mackert and Bryan Turner (Abingdon: Routledge, 2017), 15–34.
15
See, for instance, the entry on “citizen” in Black’s Law Dictionary, ed. Bryan
A. Garner, 10th ed. (St. Paul: Thomson Reuters, 2014), 298; entry on “citizenship”
in Jowitt’s Dictionary of English Law, vol. 1, 5th ed. (London: Sweet &
Maxwell/Thomson Reuters, 2019), 433. On this use of “citizenship” as generic
concept, see also Kristin Henrard, “The Shifting Parameters of Nationality,”
Netherlands International Law Review 65 (2018): 272.
16 For “nationality,” which corresponds to the German term
“Staatsangehörigkeit” as legally defined membership in the state, the term
“citizenship” is a frequent synonym in Anglo-American usage, see, for example,
the entry on “nationality” in Black’s Law Dictionary, 1186; on the history of the
concept, see Gosewinkel, “Citizenship, Subjecthood, Nationality: Concepts of
Belonging in the Age of Modern Nation States.”
17 On historical trends towards decoupling “Staatsangehörigkeit” from

“Staatsbürgerschaft,” see chaps. II.3, III.5, and III.6 on the advance of ethno-
racial homogeneity as criterion for the granting of citizenship rights; Dominique
Colas, Citoyenneté et nationalité (Paris: Galimard, 2004).
18
Axel Honneth, The Struggle for Recognition: The Moral Grammar of Social
Conflicts (Cambridge: Polity, 1995); Jürgen Habermas, “Struggles for Recognition
in the Democratic Constitutional State,” in Multiculturalism: Examining the Politics
of Recognition, ed. Amy Gutmann (Princeton: Princeton University Press, 1994),
107–148.
19 On the history and theory of citizenship in the USA: John Higham, Strangers

in the Land: Patterns of American Nativism, 1860–1925, 4th ed. (New York:
Atheneum, 1966); Gerald Newman, Strangers to the Constitution: Immigrants,
Borders, and Fundamental Law (Princeton: Princeton University Press, 1996);
Rogers M. Smith, Civic Ideals: Conflicting Visions of Citizenship in U.S. History
(New Haven: Yale University Press, 1997); Sigal R. Ben-Porath and Rogers M.
Smith, Varieties of Sovereignty and Citizenship (Philadelphia: University of
Pennsylvania Press, 2013).
20
Niklas Luhmann, “Inklusion und Exklusion,” in Die Soziologie und der Mensch
(Opladen: Westdeutscher Verlag, 1995), 237–264; Rudolf Stichweh, Inklusion und
Exklusion: Studien zur Gesellschaftstheorie (Bielefeld: Transcript, 2005), addressed
in the historical analysis of Lutz Raphael, “Figurationen von Armut und Fremdheit:
Eine Zwischenbilanz interdisziplinärer Forschung,” in Lutz Raphael, Zwischen
Ausschluss und Solidarität: Modi der Inklusion/Exklusion von Fremden und Armen
in Europa seit der Spätantike (Frankfurt/M.: Peter Lang, 2008), 13–36.
21 This was also the clear and plausible point of departure for criticism in

Dimitry Kochenov, Citizenship (Cambridge, MA: MIT Press, 2019), XII, 20.
22
This is also the starting point for the formidable study by Ayelet Shachar, The
Birthright Lottery: Citizenship and Global Inequality (Cambridge, MA: Harvard
University Press, 2009), 9–12, 21–69, who criticizes the arbitrary unequal
distribution of “high opportunity” and “low opportunity” citizenships in the world
population through the acquisition of nationality by accident by birth.
23 For a current assessment of the continued social and economic relevance of

citizenship see Irene Bloemraad, “Does Citizenship Matter?,” in The Oxford

Handbook of Citizenship Studies, ed. Ayelet Shachar et al. (Oxford: Oxford
University Press, 2017), 524–550.
24
Kochenov, Citizenship, appears to take the opposite view, branding
citizenship as an “historically violent and ultimately totalitarian status of
premodern nature” (XI). Although from an exclusively universalistic standpoint on
equality (21, 246, 251), this might well be logical, it fails to take account of the
historical origins and purpose of citizenship. Simply to describe it as “totalitarian” is
to abandon the basis for historically grounded analysis. Citizenship is certainly
used by totalitarian regimes to curb equality and freedom (see Chapter 3 in this
volume), but it is used by other political systems to promote the independence,
freedom, and prosperity of as many of their members as possible.
25 Fundamentals in Brubaker, Citizenship and Nationhood in France and

Germany, then, for example, Marc Morjé Howard, The Politics of Citizenship in
Europe (Cambridge: Cambridge University Press, 2009); sceptical about the
explanatory value of “cultural idioms” for historical comparison: Thomas Janoski,
Ironies of Citizenship (Cambridge: Cambridge University Press, 2010), 8, 88.
Explicitly contesting the heuristic usefulness of the civic–ethnic divide in the
historical analysis of citizenship: Dieter Gosewinkel, Einbürgern und Ausschließen:
Die Nationalisierung der Staatsangehörigkeit vom Deutschen Bund bis zur
Bundesrepublik Deutschland, 2nd ed. (Göttingen: Vandenhoeck & Ruprecht,
2003); Patrick Weil, How to Be French: Nationality in the Making since 1789
(Durham: Duke University Press, 2008); Benno Gammerl, Subjects, Citizens, and
Others Administering Ethnic Heterogeneity in the British and Habsburg Empires,
1867–1918 (New York: Berghahn Books, 2018), 13; Frederick Cooper, Citizenship,
Inequality, and Difference: Historical Perspectives (Princeton: Princeton University
Press, 2018), 127; also contesting the East–West divide, presenting a “surprisingly
strong assimilationist ius soli tradition in the East”: Eric Lohr, Russian Citizenship,
7.
26
On the specific conception and practice of citizenship in European
dictatorships see Chapters 3 and 5.
27 On the fundamental functions see Siegfried Wiessner, Die Funktion der

Staatsangehörigkeit: Eine historisch-rechtsvergleichende Analyse unter besonderer

Berücksichtigung der Rechtsordnungen der USA, der UdSSR und der
Bundesrepublik Deutschland (Tübingen: Attempto, 1989).
28
Going back to Hans Kohn, The Idea of Nationalism: A Study in Its Origins
and Background (New York: Macmillan, 1944); Rogers Brubaker, “Nationalizing
States in the old ‘New Europe’—and the New,” in Nationalism Reframed:
Nationhood and the National Question in the New Europe, ed. Rogers Brubaker
(Cambridge: Cambridge University Press, 1996), 79–106; on the dichotomy:
Heinrich August Winkler, “Der Nationalismus und seine Funktionen,” in
Nationalismus, ed. Heinrich August Winkler, 2nd ed. (Königstein/Ts: Athenäum,
1985), 7–12; but already critical: Hans Mommsen and Albrecht Martiny,
“Nationalismus, Nationalitätenfrage,” in Sowjetsystem und demokratische
Gesellschaft: Eine vergleichende Enzyklopädie, vol. 4, ed. Claus-Dieter Kernig
(Freiburg i. Br.: Herder, 1971), 648–669; Bernard Yack, “The Myth of the Civic
Nation,” in Theorizing Nationalism, ed. Ronald Beiner (Albany: State University of
New York Press, 1999), 103–118; Stephen Shulman, “Challenging the Civic/Ethnic
and West/East Dichotomies in the Study of Nationalism,” Comparative Political
Studies 35, no. 5 (2002): 554–585; summing up criticism of the analytical value of
the civic–ethnic divide: Dieter Gosewinkel, “‘Staatsbürgerschaft’ als
interdisziplinäres Feld historischer Forschung,” in Staatsbürgerschaft im 19. und
20. Jahrhundert, ed. Julia Angster, Dieter Gosewinkel, and Christoph Gusy
(Tübingen: Mohr Siebeck, 2019), 62–77.
29 Tomasz Giaro, ed., Modernisierung durch Transfer zwischen den Weltkriegen:

Alt- und Neueuropa; Rezeptionen und Transfers (Frankfurt/M.: Vittorio

Klostermann, 2007); Giaro, “Legal Tradition of Eastern Europe: Its Rise and
Demise,” Comparative Law Review 2, no. 1 (2011): 1–23: “The discourse on
Eastern, or East Central, Europe obviously remains an occidental and, at least
partially, an occidentalist one. In the legal field, it is conducted in a language of
western experts on ‘law and development’ who continue, quite often in a personal
union, the function of former Sovietologist” (21); on doubts about the East–West
dichotomy, taking the example of citizenship in the British and the Habsburg
Empires see Gammerl, Subjects, Citizens and Others, 10–13, 248–250.
30
Albert Hirschman, Exit, Voice and Loyalty: Responses to Decline in Firms,
Organizations, and States (Cambridge, MA: Harvard University Press, 1970).
31 On the concept and its history, see: Armin von Bogdandy and Stephan

Hinghofer-Szalkay, “Das etwas unheimliche Ius Publicum Europaeum,” Zeitschrift

für ausländisches öffentliches Recht und Völkerrecht 73, no. 2 (2013): 209–248;
Armin von Bogdandy et al., eds., Handbuch Ius Publicum Europaeum, 8 vols.
(Heidelberg: C.F. Müller, 2007–2021).
32
Important earlier work on the countries under study: Weil, How to Be
French; Karatani, Defining British Citizenship; Lohr, Russian Citizenship; Gammerl,
Subjects, Citizens, and Others; Rainer Bauböck, Bernhard Perchinig, and Wiebke
Sievers, eds., Citizenship Policies in the New Europe (Amsterdam: Amsterdam
University Press, 2007); Andreas Fahrmeir, Citizenship: The Rise and Fall of a
Modern Concept (New Haven: Yale University Press, 2007); Eli Nathans, The
Politics of Citizenship in Germany: Ethnicity, Utility and Nationalism (Oxford: Berg,
2004); Gosewinkel, Einbürgern und Ausschließen.
33 On Western Europe and the United States for the twentieth century: Andreas

Fahrmeir, Citizenship: The Rise and Fall of a Modern Concept; for a major, largely
intellectual-history overview, see Pietro Costa, Civitas: Storia della cittadinanza in
Europa, vol. 1–4 (Rome: Laterza, 1999–2001).
 1
Diversity and Demarcation
National and Imperial Citizenship Policy around 1900

In around 1900, Europe was in the throes of radical change.

European empires ruled the world, contending for spheres of
influence overseas and within their own borders. They were engaged
in momentous political, economic, and military struggles to stake out
the territorial boundaries of their power and gain dominion over
populations. Considering the violence that had erupted around the
world in the second half of the nineteenth century, armed
confrontation was, surprisingly, still limited to areas outside Europe.1
But in continental Europe, too, the distribution of imperial power was
being increasingly called into question and the status quo was under
fierce attack. National movements in East Central Europe were
fighting for politically and culturally self-determined statehood. The
Czechs and Slovaks, for instance, sought to escape the bonds of the
Austro-Hungarian double monarchy. The struggle of the Poles—
people of Polish ethnicity—to regain the statehood dismantled a
century earlier put political pressure on the partitioning powers of
Russia and Austria and the German Empire headed by Prussia. In
the west of the German Empire, the annexation of Alsace-Lorraine
plunged relations with France into a latent state of permanent crisis,
and, like the annexation of North Schleswig from Denmark, fired
separatist aspirations. On the western and southern edges of the
European continent, imperial powers lost influence. In the contest
for overseas territories and spheres of influence, Spain, Portugal,
and the Netherlands had long since been overtaken by the “new”
colonial powers Britain, France, and Germany. In the Balkans, the
new nation-states Greece, Bulgaria, and Romania had emerged from
the disintegrating Ottoman Empire. Serbia, with a strong national
movement, was fighting to exit the Habsburg Empire. The United
Kingdom’s insular geography and the British Empire’s maritime,
overseas orientation meant that the country was not directly
affected by the national political cleavages criss-crossing the
continent. But it faced a national conflict of its own: the Irish drive
for secession.2 From the vantage point of the twenty-first century,
the old European empires were clearly on the wane. The struggle for
territorial spheres of influence beyond and within the European
continent were further exacerbated in the imperial mother countries
by nationalistic aspirations, as the example of the German Empire
shows.3 What is more, imperial ambitions came into conflict with,
indeed starkly contradicted, the strong national movements. The
battle cry of nation-state autonomy planted a revolutionary bomb
under the political structure of Europe, which had seemed so stable
over the course of the long nineteenth century.
The year 1900 was not a turning point in European history, but it
did mark a change. The period between the turn of the century and
the outbreak of the First World War was the golden age of European
imperialism. It also introduced the heyday of nationalism, the key
political notion since the French Revolution in legitimating the state.
“Empire building” and “nation building” coincided in focusing on
territory as the material basis and symbol for attaining and
consolidating political power. At the beginning of the twentieth
century, however, where imperialism and nationalism found
themselves in competition, it was the nation and national
movements that gained the upper hand. The principle of the nation
and that of the nation-state—to be won or consolidated—were
broadly entrenched in the European population and mobilized unique
political force. The promise of political and cultural autonomy, of
social emancipation and security embodied in the concept of a
nation-state, was politically more concrete and spatially more
tangible than the culturally less homogeneous, politically looser, and
economically more fluid structure of an empire.
 Recent studies have shown how strongly the transcontinental
imperial reach of a society could promote the nationalization of
society in the mother country and, accordingly, the development of
national particularities and demarcations.4 National notions of
identity and perceptions of alterity were in many ways constituted
and reinforced through confrontation with others in crossing national
boundaries or global deterritorialization. This was apparent in
various areas. The growing cross-border mobility of European
societies since the mid-nineteenth century reached a peak at the
turn of the century, and triggered a strong counter-movement of
control and rejection, notably in prosperous European industrial
countries.5 The intensification and radicalization of national
movements in European countries at the turn of the century often
arose from perception of an external threat, symbolized and
reinforced by the immigration of population groups felt to be
profoundly alien and therefore dismissed as nationally inferior.
Having to share the same territory and its resources with “others”
sharpened the need to define one’s personal identity and to distance
oneself from others within the territory of the nation-state. This lent
force to an integral nationalism, which in Europe at the end of the
nineteenth century displaced the liberal, emancipatory nationalism of
the first half of the century to establish a mass basis for a
comprehensive, quasi-religious binding force of nation as the acme
of political life.6
In this process, a distinction between a national majority as state
or titular nation and minorities within the nation-state or empire was
often drawn and sharpened.7 This distinction involved not only
differentiation but also deprecation, which could find expression in
systematic discrimination and even threats against minorities. The
legitimation of national discrimination was reinforced by ethnic and
“racial” criteria of quality. Especially the Jews, who in all European
countries were a minority primarily defined in religious terms, fell
victim to exclusion, discrimination, and persecution on national,
ethnic, and finally, racist grounds.8 In nation-states that defined their
membership increasingly by ethnic criteria, Jews, as “nomads” were
genuine “others,” non-members of the nation, and thus fair game.9
Anti-Semitism was an element shared by nationalization processes
across continental Europe at the turn of the century.10
Increasingly, the European nation-state at the turn of the
twentieth century was developing into a social state. The surge of
industrialization that had seized Europe since the mid-nineteenth
century demolished the last relicts of estates-based society but
introduced new hierarchies and class conflicts whose intensity
required intervention by the state to maintain internal peace.
Although there were marked differences in development, for
example, between the industrial pioneer England and the still
strongly agrarian Russia, the trend was the same in almost all
European countries11: in search of work, the rural population was
moving to the industrialized urban centres. The mass pauperization
of large sections of the population, their intolerable living and
working conditions—in stark contrast to the growing affluence of the
propertied classes—led to political radicalization and the progressive
organization of workers in parties and trade unions to defend their
interests. Two developments thus converged: the growing
representation and participation of worker interests in state bodies
and institutions and increasing intervention by the state in the
economy. The more the interventionist state assumed responsibility
in organizing the economy, the more was demanded of it. There
were, first, collective demands for the economy to be more justly
reorganized and, second, individual demands for the provision of
social security and protection against exploitation. Common to these
two types of social demand was the increasing use of the law as a
tool. The law was expected to define spheres of entitlement in social
conflicts and, above all, to establish individual entitlements.12 The
social interventionist state juridified social relations as a means of
maintaining peaceful order. The scientification of law and the
differentiation of its forms of action, to be found in all European
countries at the end of the nineteenth century,13 favoured
development towards a welfare state while also benefiting from this
development.
 The interventionist and social state was also an auditing state,
which employed improved recording techniques for the systematic
collection of social data, and hence for auditing society. Optimized
methods for gathering statistical information provided data on the
distribution of property and social inequality, the distribution of
religions and nationalities in a country, immigration and emigration
figures, and the number of aliens and of naturalizations. The
professionalization and scientification of state action progressed with
new technical methods. New scientific disciplines, the social
sciences, demography, and branch disciplines of medicine
interpreted and analysed the data gathered and participated in the
public political discourse on the major questions of the time: on the
“social question,” on the assessment and planning of demographic
development, and on designing health care.14 Citing their expert
knowledge, scientists adopted political positions, while politics
became more scientific by calling increasingly on scientific expertise,
processing this knowledge in internal decision-making. These
developments were often determined by profound changes in the
institutional machinery of the state or were accompanied by such
changes. Greater precision in the knowledge about societal
developments gained from statistics had to do with new boundaries
drawn by the national and social state to allow the more purposive
distribution of resources. The “legal and material consolidation of
national borders”15 proceeded on several levels. On the one hand,
the distinction between internal and external, between belonging
and not belonging, was juridified in a period of growing national and
territorial demarcation.16 On the other hand, legality as a functional
mode of the constantly expanding bureaucracy (Max Weber) of the
modern industrial state became even more important precisely
where the boundaries of the internal authority of the interventionist
state and the external authority of the nation-state needed to be
drawn.
At the very intersection of the critical lines of development in
modernized statehood in the nineteenth century lay the legal
institution of citizenship. It embodied the need for precise,
bureaucratized definition of membership in the interventionist and
military state. The issues were to determine the number and
treatment of the poor and of the military; to characterize belonging
to the nation and thus to the nation-state; and finally, to endow
citizens of the nation-state with special rights and duties
distinguishing them from non-members. The nineteenth differed
from preceding centuries by establishing increasingly strict
boundaries in the interest of demarcating state and nation in two
regards: in territorializing state authority and defining who was
subject to it.17 Citizenship became the pre-eminent legal tool for
marking the bounds of nation-state authority over persons.
At the turn of the twentieth century, this need of the nation-state
for legal demarcation and its administrative implementation was
followed by a wave of codifications on nationality in European
countries.18 Within administrative structures, naturalization was
handled centrally with growing precision and for ever larger
territories. New laws regulated immigration and emigration.
Permission for aliens to settle and work in the country became a
fraught political issue between competing interests that required
legal regulation. Official documents giving proof of nationality and
permission to travel, as well as passports and visas,19 played an
increasing role.20 This was accompanied by the expansion of state
institutions for controlling external borders, border facilities and
authorities, as well as the branches of the administration that
oversaw permission to reside and work within the territory of the
state and to receive state benefits.21 The liberality of the nineteenth
century,22 which had played down borders in favour of territorial
mobility and the free availability of labour, gradually gave way to a
system of state-controlled territorial mobility on the lines of
protectionist regimes in cross-border goods traffic.
These developments towards the nation-state, the interventionist
state, and the social state combined in the process of
constitutionalizing state power, which left a lasting mark on
European states during the nineteenth century.23 Borne politically by
liberal, and increasingly by democratic movements,
constitutionalization gained quite new political legitimacy and force
in binding state authority to a supreme legal norm. State authority
was bound constitutionally in different ways, depending on whether
the state was a monarchy or a republic, in the first case by
monarchical power binding itself or being bound to a constitution on
which the people had collaborated; in the second case by grounding
state authority solely in popular sovereignty. In both cases, the
exercise of power by the state in Europe found its objectives,
organization, and, above all, its limits spelled out in written
constitutions. The European states that reconstituted themselves
politically in the second half of the nineteenth century—such as Italy,
Germany, Bulgaria, and Romania—did so based on a constitution.
Even the autocratic Russian state committed itself to a constitution
at the beginning of the twentieth century.24 Almost all European
constitutions drawn up in the second half of the nineteenth century,
as well as all the constitutions of the nascent twentieth century,
defined nationality and the legal status of aliens.25 They took
reference to the nation and the properties ascribed to it. A key
objective of the liberal constitutional movement, to bind the
intervening and regulating state by fixed legal rules, was addressed
in often-compendious constitutional catalogues of fundamental
rights. They guaranteed the rights and liberties of citizens and
defined the duties of the citizen to the state. The key concern of
constitutions, to guarantee the equality and freedom of citizens vis-
à-vis the state, was addressed primarily in the form of civil rights.
Above all, they secured the right to freedom from unlawful
interference by the state, the protection of property and the private
sphere, the free expression of opinion, and the freedom of
association. Then there were political rights of participation in
elections and in representative bodies. No social rights had yet been
codified to protect individuals against the risks of working life and
their stake in the means of production. At any rate, a new,
constitutionally grounded relationship was emerging between the
state and the individual: the protection of the individual’s legal status
as developed by statute during the liberal age of the nineteenth
century had established a system of “subjective rights” in relations
between citizens—and increasingly in relation to the state—that
provided rule-of-law protection against unlawful interference in
liberties by the state itself or that the state guaranteed to sanction.
The constitutional entrenchment of these individual rights confirmed
them as civil rights with the outstanding rank of constitutional
guarantee. Once again, this shows the close temporal and
substantive links between the constitutionalization of state authority
and its nationalization. Individual rights at the constitutional level
were largely granted as rights of citizens of the state,
“Staatsbürger.”26 Several guarantees of civil liberties and all rights of
political participation were essentially granted to citizens of the state
concerned. They were not granted as human rights, and thus not
applicable to everyone under the authority of the state in whose
territory they were present.
Thus, at the turn of the twentieth century, all political and legal
elements of citizenship as an institution of the constitutional nation-
state were fully developed in Europe. Whether this tool was used
more to exclude people from or include them in a national or
imperial community was a question of national practice.
In what follows, we discuss how the constructs of belonging
developed between traditional “subjecthood” and modern citizenship
in four European empires that laid varying weight on the national or
imperial component in their policy on belonging within Europe.
Whereas the “belated nation-state” Germany developed citizenship
into an institution of closed (nation-) statehood by strengthening a
national community of descent (section 1), France developed a
specifically national form of citizenship through more intensive
territorialization (section 2). The continental Russian Tsarist Empire
clung to traditional, estatist, and regionally fragmented forms of
“subjecthood,” to be superseded in around 1900 only partially by
concepts of civil equality (section 3). In the British Empire, the
traditional blanket status of “subjecthood” was maintained for the
purpose of politically integrating a worldwide, culturally and
ethnically extremely heterogeneous empire. Under the surface of
common “subjecthood,” however, distinct hierarchies of belonging
became apparent. They were justified on grounds of origin from a
given territory, which in turn had specific ethnic connotations
(section 4).

1 An Institution of Closed Statehood:

Citizenship in the German Empire
Compared with France and Spain, both territorial states unified at an
early date, as well as the Netherlands and Greece, Germany was a
“belated nation-state.” Until 1871, the confederation of states and
cities that had emerged from the breakup of the Holy Roman Empire
at the beginning of the nineteenth century had no common external
borders. German states such as Bavaria and Prussia treated each
other as foreign countries, issued passports of their own, and
controlled their own borders. For this reason, belonging to the state
had, since the beginning of the nineteenth century, been defined as
belonging to the territorial state, whose origins were partly historical
and dynastic and partly the outcome of territorial redistribution in
the early nineteenth century. Although these territories were the
point of departure for the German national movement, which
originated in this period, the ultimate aim of the movement was to
unite them in one national whole. The genesis of citizenship as a
legal institution of all individual German states was hence pre-
national. It was rooted in special legislation passed since the
beginning of the nineteenth century in more and more states, and in
intergovernmental treaties dealing with residence and work permits
for cross-border migration.
Prussia, which—with Austria—was the leading political and
industrial power in the German Confederation of 1815, illustrates the
web of political and social reasons for the genesis of citizenship: in
1842, rules for Prussian citizenship were set for the first time in a
separate law, the Subjects Act.27 The background was the need to
harmonize the hotchpotch of rules of belonging in a territorially and
politically highly heterogeneous state, which had been pieced
Another random document with
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Fig. 35.—19 specimens of Purpura lapillus L., Great
Britain, illustrating variation.
(1) Felixstowe, sheltered coast; (2), (3) Newquay,
on veined and coloured rock; (4) Herm, rather
exposed; (5) Solent, very sheltered; (6) Land’s End,
exposed rocks, small food supply; (7) Scilly, exposed
rocks, fair food supply; (8) St. Leonards, flat mussel
beds at extreme low water; (9) Robin Hood’s Bay,
 sheltered under boulders, good food supply; (10)
Rhoscolyn, on oyster bed, 4–7 fath. (Macandrew);
(11) Guernsey, rather exposed rocks; (12) Estuary of
Conway, very sheltered, abundant food supply; (13),
(14) Robin Hood’s Bay, very exposed rocks, poor food
supply; (14) slightly monstrous; (15), (16), (17)
Morthoe, rather exposed rocks, but abundant food
supply; (18) St. Bride’s Bay; (19) L. Swilly, sheltered,
but small food supply. All from the author’s collection,
except (10).
The common dog-whelk (Purpura lapillus) of our own coasts is an
exceedingly variable species, and in many cases the variations may
be shown to bear a direct relation to the manner of life (Fig. 35).
Forms occurring in very exposed situations, e.g. Land’s End, outer
rocks of the Scilly Is., coasts of N. Devon and Yorkshire, are stunted,
with a short spire and relatively large mouth, the latter being
developed in order to increase the power of adherence to the rock
and consequently of resistance to wave force. On the other hand,
shells occurring in sheltered situations, estuaries, narrow straits, or
even on open coasts where there is plenty of shelter from the waves,
are comparatively of great size, with a well-developed, sometimes
produced spire, and a mouth small in proportion to the area of shell
surface. In the accompanying figure, the specimens from the
Conway estuary and the Solent (12, 5) well illustrate this latter form
of shell, while that from exposed rocks is illustrated by the
specimens from Robin Hood’s Bay (13, 14). Had these specimens
occurred alone, or had they been brought from some distant and
unexplored region, they must inevitably have been described as two
distinct species.
 Fig. 36.—Valves of Cardium edule from the four upper
terraces of Shumish Kul, a dry salt lake adjacent to the
Aral Sea. (After Bateson.)

Mr. W. Bateson has made[195] some observations on the shells of

Cardium edule taken from a series of terraces on the border of
certain salt lakes which once formed a portion of the Sea of Aral. As
these lakes gradually became dry, the water they contained became
salter, and thus the successive layers of dead shells deposited on
their borders form an interesting record of the progressive variation
of this species under conditions which, in one respect at least, can
be clearly appreciated. At the same time the diminishing volume of
water, and the increasing average temperature, would not be without
their effect. It was found that the principal changes were as follows:
the thickness, and consequently the weight, of the shells became
diminished, the size of the beaks was reduced, the shell became
highly coloured, and diminished considerably in size, and the
breadth of the shells increased in proportion to their length (Fig. 36).
Shells of the same species of Cardium, occurring in Lake Mareotis,
were found to exhibit very similar variations as regards colour, size,
shape, and thickness.
Unio pictorum var. compressa occurs near Norwich at two similar
localities six or seven miles distant from one another, under
circumstances which tend to show that similar conditions have
produced similar results. The form occurs where the river, by
bending sharply in horse-shoe shape, causes the current to rush
across to the opposite side and form an eddy near the bank on the
outside of the bend. Just at the edge of the sharp current next the
eddy the shells are found, the peculiar form being probably due to
the current continually washing away the soft particles of mud and
compelling the shell to elongate itself in order to keep partly buried at
the bottom.[196]
The rivers Ouse and Foss, which unite just below York, are rivers
of strikingly different character, the Ouse being deep, rapid, with a
bare, stony bottom, and little vegetable growth, and receiving a good
deal of drainage, while the Foss is shallow, slow, muddy, full of
weeds and with very little drainage. In the Foss, fine specimens of
Anodonta anatina occur, lustrous, with beautifully rayed shells. A few
yards off, in the Ouse, the same species of Anodonta is dull brown in
colour, its interior clouded, the beaks and epidermis often deeply
eroded. Precisely the same contrast is shown in specimens of Unio
tumidus, taken from the same rivers, Ouse specimens being also
slightly curved in form. Just above Yearsley Lock in the Foss, Unio
tumidus occurs, but always dwarfed and malformed, a result
probably due to the effect of rapidly running water upon a species
accustomed to live in still water.[197] Simroth records the occurrence
of remarkably distorted varieties in two species of Aetheria which
lived in swift falls of the River Congo.[198]
A variety of Limnaea peregra with a short spire and rather strong,
stoutly built shell occurs in Lakes Windermere, Derwentwater, and
Llyn-y-van-fach. It lives adhering to stones in places where there are
very few weeds, its shape enabling it to withstand the surf of these
large lakes, to which the ordinary form would probably succumb.[199]
Scalariform specimens of Planorbis are said to occur most
commonly in waters which are choked by vegetation, and it has been
shown that this form of shell is able to make its way through masses
of dense weed much more readily than specimens of normal shape.
Continental authorities have long considered Limnaea peregra
and L. ovata as two distinct species. Hazay, however, has
succeeded in rearing specimens of so-called peregra from the ova of
ovata, and so-called ovata from the ova of peregra, simply by placing
one species in running water, and the other in still water.
According to Mr. J. S. Gibbons[200] certain species of Littorina, in
tropical and sub-tropical regions, are confined to water more or less
brackish, being incapable of living in pure salt water. “I have met,”
says Mr. Gibbons, “with three of these species, and in each case
they have been distinguished from the truly marine species by the
extreme (comparative) thinness of their shells, and by their colouring
being richer and more varied; they are also usually more elaborately
marked. They are to be met with under three different conditions—
(1) in harbours and bays where the water is salt with but a slight
admixture of fresh water; (2) in mangrove swamps where salt and
fresh water mix in pretty equal volume; (3) on dry land, but near a
marsh or the dry bed of one.
“L. intermedia Reeve, a widely diffused E. African shell, attaches
itself by a thin pellicle of dried mucus to grass growing by the margin
of slightly brackish marshes near the coast, resembling in its mode
of suspension the Old World Cyclostoma. I have found it in vast
numbers in situations where, during the greater part of the year, it is
exposed to the full glare of an almost vertical sun, its only source of
moisture being a slight dew at night-time. The W. Indian L. angulifera
Lam., and a beautifully coloured E. African species (? L. carinifera),
are found in mangrove swamps; they are, however, less independent
of salt water than the last.”
Mr. Gibbons goes on to note that brackish water species
(although not so solid as truly marine species) tend to become more
solid as the water they inhabit becomes less salt. This is a curious
fact, and the reverse of what one would expect. Specimens of L.
intermedia on stakes at the mouth of the Lorenço Marques River,
Delagoa Bay, are much smaller, darker, and more fragile, than those
living on grass a few hundred yards away. L. angulifera is unusually
solid and heavy at Puerto Plata (S. Domingo) among mangroves,
where the water is in a great measure fresh; at Havana and at
Colon, where it lives on stakes in water but slightly brackish, it is
thinner and smaller and also darker coloured.
(c) Changes in the Volume of Water.—It has long been known that
the largest specimens, e.g. of Limnaea stagnalis and Anodonta
anatina, only occurred in pieces of water of considerable size.
Recent observation, however, has shown conclusively that the
volume of water in which certain species live has a very close
relation to the actual size of their shells, besides producing other
effects. Lymnaea megasoma, when kept in an aquarium of limited
size, deposited eggs which hatched out; this process was continued
in the same aquarium for four generations in all, the form of the shell
of the last generation having become such that an experienced
conchologist gave it as his opinion that the first and last terms of the
series could have no possible specific relation to one another. The
size of the shell became greatly diminished, and in particular the
spire became very slender.[201]
The same species being again kept in an aquarium under similar
conditions, it was found that the third generation had a shell only
four-sevenths the length of their great grandparents. It was noticed
also that the sexual capacities of the animals changed as well. The
liver was greatly reduced, and the male organs were entirely lost.
[202]

K. Semper conducted some well-known experiments bearing on

this point. He separated[203] specimens of Limnaea stagnalis from
the same mass of eggs as soon as they were hatched, and placed
them simultaneously in bodies of water varying in volume from 100
to 2000 cubic centimetres. All the other conditions of life, and
especially the food supply, were kept at the known optimum. He
found, in the result, that the size of the shell varied directly in
proportion to the volume of the water in which it lived, and that this
was the case, whether an individual specimen was kept alone in a
given quantity of water, or shared it with several others. At the close
of 65 days the specimens raised in 100 cubic cm. of water were only
6 mm. long, those in 250 cubic cm. were 9 mm. long, those in 600
cubic cm. were 12 mm. long, while those kept in 2000 cubic cm.
attained a length of 18 mm. (Fig. 37).
An interesting effect of a sudden fall of temperature was noticed
by Semper in connection with the above experiments. Vessels of
unequal size, containing specimens of the Limnaea, happened to
stand before a window at a time when the temperature suddenly fell
to about 55° F. The sun, which shone through the window, warmed
the water in the smaller vessels, but had no effect upon the
temperature of the larger. The result was, that the Limnaea in 2000
cubic cm., which ought to have been 10 mm. long when 25 days old,
were scarcely longer, at the end of that period, than those which had
lived in the smaller vessels, but whose water had been sufficiently
warm.

Fig. 37.—Four equally old shells

of Limnaea stagnalis,
hatched from the same mass
of ova, but reared in different
volumes of water: A in 100, B
in 250, C in 600, and D in
2000 cubic centimetres.
(After K. Semper.)
 CHAPTER IV
USES OF SHELLS FOR MONEY, ORNAMENT, AND FOOD—CULTIVATION OF
THE OYSTER, MUSSEL, AND SNAIL—SNAILS AS MEDICINE—PRICES GIVEN
FOR SHELLS

The employment of shells as a medium of exchange was

exceedingly common amongst uncivilised tribes in all parts of the
world, and has by no means yet become obsolete. One of the
commonest species thus employed is the ‘money cowry’ (Cypraea
moneta, L.), which stands almost alone in being used entire, while
nearly all the other forms of shell money are made out of portions of
shells, thus requiring a certain amount of labour in the process of
formation.
One of the earliest mentions of the cowry as money occurs in an
ancient Hindoo treatise on mathematics, written in the seventh
century a.d. A question is propounded thus: ‘the ¼ of 1/16 of ⅕ of ¾
of ⅔ of ½ a dramma was given to a beggar by one from whom he
asked an alms; tell me how many cowry shells the miser gave.’ In
British India about 4000 are said to have passed for a shilling, but
the value appears to differ according to their condition, poor
specimens being comparatively worthless. According to Reeve[204] a
gentleman residing at Cuttack is said to have paid for the erection of
his bungalow entirely in cowries. The building cost him 4000 Rs.
sicca (about £400), and as 64 cowries = 1 pice, and 64 pice = 1
rupee sicca, he paid over 16,000,000 cowries in all.
Cowries are imported to England from India and other places for
the purposes of exportation to West Africa, to be exchanged for
native products. The trade, however, appears to be greatly on the
decrease. At the port of Lagos, in 1870, 50,000 cwts. of cowries
were imported.[205]
A banded form of Nerita polita was used as money in certain parts
of the South Pacific. The sandal-wood imported into the China
market is largely obtained from the New Hebrides, being purchased
of the natives in exchange for Ovulum angulosum, which they
especially esteem as an ornament. Sometimes, as in the Duke of
York group, the use of shell money is specially restricted to certain
kinds of purchase, being employed there only in the buying of swine.
Among the tribes of the North-West coasts of America the
common Dentalium indianorum used to form the standard of value,
until it was superseded, under the auspices of the Hudson’s Bay
Company, by blankets. A slave was valued at a fathom of from 25 to
40 of these shells, strung lengthwise. Inferior or broken specimens
were strung together in a similar way, but were less highly esteemed;
they corresponded more to our silver and copper coins, while the
strings of the best shells represented gold.
The wampum of the eastern coast of North America differed from
all these forms of shell money, in that it required a laborious process
for its manufacture. Wampum consisted of strings of cylindrical
beads, each about a quarter of an inch in length and half that
breadth. The beads were of two colours, white and purple, the latter
being the more valuable. Both were formed from the common clam,
Venus mercenaria, the valves of which are often stained with purple
at the lower margins, while the rest of the shell is white. Cut small,
ground down, and pierced, these shells were converted into money,
which appears to have been current along the whole sea-board of
North America from Maine to Florida, and on the Gulf Coast as far as
Central America, as well as among the inland tribes east of the
Mississippi. Another kind of wampum was made from the shells of
Busycon carica and B. perversum. By staining the wampum with
various colours, and disposing these colours in belts in various forms
of arrangement, the Indians were able to preserve records, send
messages, and keep account of any kind of event, treaty, or
transaction.
Another common form of money in California was Olivella
biplicata, strung together by rubbing down the apex. Button-shaped
disks cut from Saxidomus arata and Pachydesma crassatelloides, as
well as oblong pieces of Haliotis, were employed for the same
purpose, when strung together in lengths of several yards.
 “There is a curious old custom,” writes Mr. W. Anderson Smith,
[206] “that used formerly to be in use in this locality [the western coast
of Scotland], and no doubt was generally employed along the sea-
board, as the most simple and ready means of arrangement of
bargains by a non-writing population. That was, when a bargain was
made, each party to the transaction got one half of a bivalve shell—
such as mussel, cockle, or oyster—and when the bargain was
implemented, the half that fitted exactly was delivered up as a
receipt! Thus a man who had a box full of unfitted shells might be
either a creditor or a debtor; but the box filled with fitted shells
represented receipted accounts. Those who know the difficulty of
fitting the valves of some classes of bivalves will readily
acknowledge the value of this arrangement.”
Shells are employed for use and for ornament by savage—and
even by civilised—tribes in all parts of the world. The natives of Fiji
thread the large Turbo argyrostoma and crenulatus as weights at the
edge of their nets, and also employ them as sinkers. A Cypraea tigris
cut into two halves and placed round a stone, with two or three
showy Oliva at the sides, is used as a bait for cuttles. Avicula
margaritifera is cut into scrapers and knives by this and several other
tribes. Breast ornaments of Chama, grouped with Solarium
perspectivum and Terebra duplicata are common among the Fijians,
who also mount the Avicula on a backing of whales’ teeth sawn in
two, for the same purpose. The great Orange Cowry (Cypraea
aurantiaca) is used as a badge of high rank among the chieftains.
One of the most remarkable Fijian industries is the working of
whales’ teeth to represent this cowry, as well as the commoner C.
talpa, which is more easily imitated.
Among the Solomon islanders, cowries are used to ornament their
shields on great field days, and split cowries are worn as a necklace,
to represent human teeth. Small bunches of Terebellum subulatum
are worn as earrings, and a large valve of Avicula is employed as a
head ornament in the centre of a fillet. The same islanders ornament
the raised prows of their canoes, as well as the inside of the stern-
post, with a long row of single Natica.
 The native Papuans employ shells for an immense variety of
purposes. Circlets for the head are formed of rows of Nassa
gibbosula, rubbed down till little but the mouth remains. Necklaces
are worn which consist of strings of Oliva, young Avicula, Natica
melanostoma, opercula of Turbo, and valves of a rich brown species
of Cardium, pendent at the end of strings of the seeds known as
Job’s tears. Struthiolaria is rubbed down until nothing but the mouth
is left, and worn in strings round the neck. This is remarkable, since
Struthiolaria is not a native Papuan shell, and indeed occurs no
nearer than New Zealand. Sections of Melo are also worn as a
breast ornament, dependent from a necklace of cornelian stones.
Cypraea erosa is used to ornament drinking bowls, and Ovulum
ovum is attached to the native drums, at the base of a bunch of
cassowary feathers, as well as being fastened to the handle of a
sago-beater.
In the same island, the great Turbo and Conus millepunctatus are
ground down to form bracelets, which are worn on the biceps. The
crimson lip of Strombus luhuanus is cut into beads and perforated for
necklaces. Village elders are distinguished by a single Ovulum
verrucosum, worn in the centre of the forehead. The thick lip of
Cassis cornuta is ground down to form nose pieces, 4½ inches long.
Fragments of a shell called Kaïma (probably valves of a large
Spondylus) are worn suspended from the ears, with little wisps of
hair twisted up and thrust through a hole in the centre. For trumpets,
Cassis cornuta, Triton tritonis, and Ranella lampas are used, with a
hole drilled as a mouthpiece in one of the upper whorls. Valves of
Batissa, Unio, and Mytilus are used as knives for peeling yams.
Spoons for scooping the white from the cocoa-nut are made from
Avicula margaritifera. Melo diadema is used as a baler in the
canoes.[207]
In the Sandwich Islands Melampus luteus is worn as a necklace,
as well as in the Navigator Islands. A very striking necklace, in the
latter group, is formed of the apices of a Nautilus, rubbed down to
show the nacre. The New Zealanders use the green opercula of a
Turbo, a small species of Venus, and Cypraea asellus to form the
eyes of their idols. Fish-hooks are made throughout the Pacific of the
shells of Avicula and Haliotis, and are sometimes strengthened by a
backing made of the columella of Cypraea arabica. Small axe-heads
are made from Terebra crenulata ground down (Woodlark I.), and
larger forms are fashioned from the giant Tridacna (Fiji).
Shells are used to ornament the elaborate cloaks worn by the
women of rank in the Indian tribes of South America. Specimens of
Ampullaria, Orthalicus, Labyrinthus, and Bulimulus depend from the
bottom and back of these garments, while great Bulimi, 6 inches
long, are worn as a breast ornament, and at the end of a string of
beads and teeth.[208]
The chank-shell (Turbinella rapa) is of especial interest from its
connexion with the religion of the Hindoos. The god Vishnu is
represented as holding this shell in his hand, and the sinistral form of
it, which is excessively rare, is regarded with extraordinary
veneration. The chank appears as a symbol on the coins of some of
the ancient Indian Empires, and is still retained on the coinage of the
Rajah of Travancore.
The chief fishery of the chank-shell is at Tuticorin, on the Gulf of
Manaar, and is conducted during the N. E. monsoon, October-May.
In 1885–86 as many as 332,000 specimens were obtained, the net
amount realised being nearly Rs.24,000. In former days the trade
was much more lucrative, 4 or 5 millions of specimens being
frequently shipped. The government of Ceylon used to receive
£4000 a year for licenses to fish, but now the trade is free. The shells
are brought up by divers from 2 or 3 fathoms of water. In 1887 a
sinistral specimen was found at Jaffna, which sold for Rs.700.[209]
Nearly all the shells are sent to Dacca, where they are sliced into
bangles and anklets to be worn by the Hindoo women.
Perhaps the most important industry which deals only with the
shells of Mollusca is that connected with the ‘pearl-oyster.’ The
history of the trade forms a small literature in itself. It must be
sufficient here to note that the species in question is not an ‘oyster,’
properly so called, but an Avicula (margaritifera Lam.). The ‘mother-
of-pearl,’ which is extensively employed for the manufacture of
buttons, studs, knife-handles, fans, card-cases, brooches, boxes,
and every kind of inlaid work, is the internal nacreous laminae of the
shell of this species. The most important fisheries are those of the
Am Islands, the Soo-loo Archipelago, the Persian Gulf, the Red Sea,
Queensland, and the Pearl Islands in the Bay of Panama. The shell
also occurs in several of the groups of the South Pacific—the
Paumotu, Gambier and Navigator Islands, Tahiti being the centre of
the trade—and also on the coasts of Lower California.[210]
Pearls are the result of a disease in the animal of this species of
Avicula and probably in all other species within which they occur.
When the Avicula is large, well formed, and with ample space for
individual development, pearls scarcely occur at all, but when the
shells are crowded together, and become humped and distorted, as
well as affording cover for all kinds of marine worms and parasitic
creatures, then pearls are sure to be found. Pearls of inferior value
and size are also produced by Placuna placenta, many species of
Pinna, the great Tridacna, the common Ostrea edulis, and several
other marine bivalves. They are not uncommon in Unio and
Anodonta, and the common Margaritana margaritifera of our rapid
streams is still said to be collected, in some parts of Wales, for the
purpose of extracting its small ‘seed-pearls.’ Pink pearls are obtained
from the giant conch-shell of the West Indies (Strombus gigas), as
well as from certain Turbinella.
In Canton, many houses are illuminated almost entirely by
skylights and windows made of shells, probably the semitransparent
valves of Placuna placenta. In China lime is commonly made of
ground cockle-shells, and, when mixed with oil, forms an excellent
putty, used for cementing coffins, and in forming a surface for the
frescoes with which the gables of temples and private houses are
adorned. Those who suffer from cutaneous diseases, and
convalescents from small-pox, are washed in Canton with the water
in which cockles have been boiled.[211]
A recent issue of the Peking Gazette contains a report from the
outgoing Viceroy of Fukhien, stating that he had handed over the
insignia of office to his successor, including inter alia the conch-shell
bestowed by the Throne. A conch-shell with a whorl turning to the
right, i.e. a sinistral specimen, is supposed when blown to have the
effect of stilling the waves, and hence is bestowed by the Emperor
upon high officers whose duties oblige them to take voyages by sea.
The Viceroy of Fukhien probably possesses one of these shells in
virtue of his jurisdiction over Formosa, to which island periodical
visits are supposed to be made.[212]
Shells appear to be used occasionally by other species besides
man. Oyster-catchers at breeding time prepare a number of imitation
nests in the gravel on the spit of land where they build, putting bits of
white shell in them to represent eggs.[213] This looks like a trick in
order to conceal the position of the true nest. According to
Nordenskjöld, when the eider duck of Spitzbergen has only one or
two eggs in its nest, it places a shell of Buccinum glaciale beside
them. The appropriation of old shells by hermit-crabs is a familiar
sight all over the world. Perhaps it is most striking in the tropics,
where it is really startling, at first experience, to meet—as I have
done—a large Cassis or Turbo, walking about in a wood or on a hill
side at considerable distances from the sea. A Gephyrean
(Phascolion strombi) habitually establishes itself in the discarded
shells of marine Mollusca. Certain Hymenoptera make use of dead
shells of Helix hortensis in which they build their cells.[214] Magnus
believes that in times when heavy rains prevail, and the usual
insects do not venture out, certain flowers are fertilised by snails and
slugs crawling over them, e.g. Leucanthemum vulgare by Limax
laevis.[215]
Mollusca as Food for Man.—Probably there are few countries in
the world in which less use is made of the Mollusca as a form of food
than in our own. There are scarcely ten native species which can be
said to be at all commonly employed for this purpose. Neighbouring
countries show us an example in this respect. The French, Italians,
and Spanish eat Natica, Turbo, Triton, and Murex, and, among
bivalves, Donax, Venus, Lithodomus, Pholas, Tapes, and Cardita, as
well as the smaller Cephalopoda. Under the general designation of
clam the Americans eat Venus mercenaria, Mya arenaria, and
Mactra solidissima. In the Suez markets are exposed for sale
Strombus and Melongena, Avicula and Cytherea. At Panama Donax
and Solen are delicacies, while the natives also eat the great Murex
and Pyrula, and even the huge Arca grandis, which lives embedded
in the liquid river mud.
The common littoral bivalves seem to be eaten in nearly all
countries except our own, and it is therefore needless to enumerate
them. The Gasteropoda, whose habits are scarcely so cleanly, seem
to require a bolder spirit and less delicate palate to venture on their
consumption.
The Malays of the East Indian islands eat Telescopium fuscum
and Pyrazus palustris, which abound in the mangrove swamps. They
throw them on their wood fires, and when they are sufficiently
cooked, break off the top of the spire and suck the animal out
through the opening. Haliotis they take out of the shell, string
together, and dry in the sun. The lower classes in the Philippines eat
Arca inaequivalvis, boiling them as we do mussels.[216] In the
Corean islands a species of Monodonta and another of Mytilus are
quite peppery, and bite the tongue; our own Helix revelata, as I can
vouch from personal experience, has a similar flavour. Fusus
colosseus, Rapana bezoar, and Purpura luteostoma are eaten on
the southern coasts of China; Strombus luhuanus, Turbo
chrysostomus, Trochus niloticus, and Patella testudinaria, by the
natives of New Caledonia; Strombus gigas and Livona pica in the
West Indies; Turbo niger and Concholepas peruvianus on the Chilian
coasts; four species of Strombus and Nerita, one each of Purpura
and Turbo, besides two Tridacna and one Hippopus, by the natives
of British New Guinea. West Indian negroes eat the large Chitons
which are abundant on their rocky coasts, cutting off and swallowing
raw the fleshy foot, which they call ‘beef,’ and rejecting the viscera.
Dried cephalopods are a favourite Chinese dish, and are regularly
exported to San Francisco, where the Chinamen make them into
soup. The ‘Challenger’ obtained two species of Sepia and two of
Loligo from the market at Yokohama.
The insipidity of fresh-water Mollusca renders them much less
desirable as a form of food. Some species of Unionidae, however,
are said to be eaten in France. Anodonta edulis is specially
cultivated for food in certain districts of China, and the African
Aetheriae are eaten by negroes. Navicella and Neritina are eaten in
Mauritius, Ampullaria and Neritina in Guadeloupe, and Paludina in
Cambodia.
The vast heaps of empty shells known as ‘kitchen-middens,’ occur
in almost every part of the world. They are found in Scotland,
Denmark, the east and west coasts of North America, Brazil, Tierra
del Fuego, Australia and New Zealand, and are sometimes several
hundred yards in length. They are invariably composed of the edible
shells of the adjacent coast, mixed with bones of Mammals, birds,
and fish. From their great size, it is believed that many of them must
have taken centuries to form.
Pre-eminent among existing shell-fish industries stands the
cultivation of the oyster and the mussel, a more detailed account of
which may prove interesting.
The cultivation of the oyster[217] as a luxury of food dates at least
from the gastronomic age of Rome. Every one has heard of the
epicure whose taste was so educated that

“he could tell

At the first mouthful, if his oysters fed
On the Rutupian or the Lucrine bed
Or at Circeii.”[218]

The first artificial oyster-cultivator on a large scale appears to

have been a certain Roman named Sergius Orata, who lived about a
century b.c. His object, according to Pliny the elder,[219] was not to
please his own appetite so much as to make money by ministering to
the appetites of others. His vivaria were situated on the Lucrine
Lake, near Baiae, and the Lucrine oysters obtained under his
cultivation a notoriety which they never entirely lost, although British
oysters eventually came to be more highly esteemed. He must have
been a great enthusiast in his trade, for on one occasion when he
became involved in a law-suit with one of the riparian proprietors, his
counsel declared that Orata’s opponent made a great mistake if he
expected to damp his ardour by expelling him from the lake, for,
sooner than not grow oysters at all, he would grow them upon the
roof of his house.[220] Orata’s successors in the business seem to
have understood the secret of planting young oysters in new beds,
for we are told that specimens brought from Brundisium and even
from Britain were placed for a while in the Lucrine Lake, to fatten
after their long journey, and also to acquire the esteemed “Lucrine
flavour.”
Oysters are ‘in season’ whenever there is an ‘r’ in the month, in
other words, from September to April. ‘Mensibus erratis,’ as the poet
has it, ‘vos ostrea manducatis!’ It has been computed that the
quantity annually produced in Great Britain amounts to no less than
sixteen hundred million, while in America the number is estimated at
five thousand five hundred million, the value being over thirteen
million dollars, and the number of persons employed fifty thousand.
Arcachon, one of the principal French oyster-parks, has nearly
10,000 acres of oyster beds, the annual value being from eight to ten
million francs; in 1884–85, 178,359,000 oysters were exported from
this place alone. In the season 1889–90, 50,000 tons of oysters were
consumed in London.
Few will now be found to echo the poet Gay’s opinion:

“That man had sure a palate covered o’er

With brass or steel, that on the rocky shore
First broke the oozy oyster’s pearly coat,
And risq’d the living morsel down his throat.”

There were halcyon days in England once, when oysters were to

be procured at 8d. the bushel. Now it costs exactly that amount
before a bushel, brought up the Thames, can even be exposed for
sale at Billingsgate (4d. porterage, 4d. market toll), and prime
Whitstable natives average from 3½d. to 4d. each. The principal
causes of this rise in prices, apart from the increased demand, are
(1) over-dredging; (2) ignorant cultivation, and to these may be
added (3) the effect of bad seasons in destroying young oysters, or
preventing the spat from maturing. Our own principal beds are those
at Whitstable, Rochester, Colchester, Milton (famous for its ‘melting’
natives), Faversham, Queenborough, Burnham, Poole, and
Carlingford in Co. Down, and Newhaven, near Edinburgh.
The oyster-farms at Whitstable, public and private, extend over an
area of more than 27 square miles. The principal of these is a kind of
joint-stock company, with no other privilege of entrance except birth
as a free dredgeman of the town. When a holder dies, his interest
dies with him. Twelve directors, known as “the Jury,” manage the
affairs of the company, which finds employment for several thousand
people, and sometimes turns over as much as £200,000 a year. The
term ‘Natives,’ as applied to these Whitstable or to other English
oysters, requires a word of explanation. A ‘Native’ oyster is simply an
oyster which has been bred on or near the Thames estuary, but very
probably it may be developed from a brood which came from
Scotland or some other place at a distance. For some unexplained
reason, oysters bred on the London clay acquire a greater delicacy
of flavour than elsewhere. The company pay large sums for brood to
stock their own grounds, since there can be no certainty that the spat
from their own oysters will fall favourably, or even within their own
domains at all. Besides purchases from other beds, the parks are
largely stocked with small oysters picked up along the coast or
dredged from grounds public to all, sometimes as much as 50s. a
bushel being paid for the best brood. It is probably this system of
transplanting, combined with systematic working of the beds, which
has made the Whitstable oyster so excellent both as to quality and
quantity of flesh. The whole surface of the ‘layings’ is explored every
year by the dredge, successive portions of the ground being gone
over in regular rotation, and every provision being made for the well-
being of the crop, and the destruction of their enemies. For three
days of every week the men dredge for ‘planting,’ i.e. for the
transference of suitable specimens from one place to another, the
separation of adhering shells, the removal of odd valves and of every
kind of refuse, and the killing off of dangerous foes. On the other
three days they dredge for the market, taking care only to lift such a
number as will match the demand.
 The Colne beds are natural beds, as opposed to the majority of
the great working beds, which are artificial. They are the property of
the town of Colchester, which appoints a water-bailiff to manage the
concern. Under his direction is a jury of twelve, who regulate the
times of dredging, the price at which sales are to be made, and are
generally responsible for the practical working of the trade. Here,
and at Faversham, Queenborough, Rochester, and other places,
‘natives’ are grown which rival those of Whitstable.
There can be no question, however, that the cultivation of oysters
by the French is far more complete and efficient than our own, and
has reached a higher degree of scientific perfection combined with
economy and solid profits. And yet, between 40 and 50 years ago,
the French beds were utterly exhausted and unproductive, and
showed every sign of failure and decay. It was in 1858 that the
celebrated beds on the Ile de Ré, near Rochelle, were first started.
Their originator was a certain shrewd stone-mason, by name Boeuf.
He determined to try, entirely on his own account, whether oysters
could not be made to grow on the long muddy fore-shore which is
left by the ebb of the tide. Accordingly, he constructed with his own
hands a small basin enclosed by a low wall, and placed at the
bottom a number of stones picked out of the surrounding mud,
stocking his ‘parc’ with a few bushels of healthy young brood. The
experiment was entirely successful, in spite of the jeers of his
neighbours, and Boeuf’s profits, which soon began to mount up at an
astonishing rate, induced others to start similar or more extensive
farms for themselves. The movement spread rapidly, and in a few
years a stretch of miles of unproductive mud banks was converted
into the seat of a most prosperous industry. The general interests of
the trade appear to be regulated in a similar manner to that at
Whitstable; delegates are appointed by the various communities to
watch over the business as a whole, while questions affecting the
well-being of oyster-culture are discussed in a sort of representative
assembly.
At the same time as Boeuf was planting his first oysters on the
shores of the Ile de Ré, M. Coste had been reporting to the French
government in favour of such a system of ostreiculture as was then
practised by the Italians in the old classic Lakes Avernus and
Lucrinus. The principle there adopted was to prevent, as far as
possible, the escape of the spat from the ground at the time when it
is first emitted by the breeding oyster. Stakes and fascines of wood
were placed in such a position as to catch the spat and give it a
chance of obtaining a hold before it perished or was carried away
into the open sea. The old oyster beds in the Bay of St. Brieuc were
renewed on this principle, banks being constructed and overlaid with
bundles of wood to prevent the escape of the new spat. The attempt
was entirely successful, and led to the establishment or re-
establishment of those numerous parcs, with which the French coast
is studded from Brest to the Gironde. The principal centres of the
industry are Arcachon, Auray, Cancale, and la Teste.
It is at Marennes, in Normandy, that the production of the
celebrated ‘green oyster’ is carried out, that especial luxury of the
French epicure. Green oysters are a peculiarly French taste, and,
though they sometimes occur on the Essex marshes, there is no
market for them in England. The preference for them, on the
continent, may be traced back as early as 1713, when we find a
record of their having been served up at a supper given by an
ambassador at the Hague. Green oysters are not always green, it is
only after they are placed in the ‘claires,’ or fattening ponds, that they
acquire the hue; they never occur in the open sea. The green colour
does not extend over the whole animal, but is found only in the
branchiae and labial tentacles, which are of a deep blue-green.
Various theories have been started to explain the ‘greening’ of the
mollusc; the presence of copper in the tanks, the chlorophyll of
marine algae, an overgrowth of some parasite, a disease akin to liver
complaint, have all found their advocates. Prof. Lankester seems to
have established[221] the fact,—which indeed had been observed 70
years before by a M. Gaillon,—that the greening is due to the growth
of a certain diatom (Navicula ostrearia) in the water of the tanks. This
diatom, which is of a deep blue-green colour, appears from April to
June, and in September. The oyster swallows quantities of the
Navicula; the pigment enters the blood in a condition of chemical
modification, which makes it colourless in all the other parts of the