03.22
putut joko utomo
Abstract
A synthesis of rights and participatory approaches to citizenship, linked throughthe notion of human agency, is proposed as the basis for a feminist theory of citizen-ship. Such a theory has to address citizenship’ s exclusionary power in relation toboth nation-state ‘ outsiders’ and ‘ insiders’ . With regard to the former, the articleargues that a feminist theory and politics of citizenship must embrace an interna-tionalist agenda. With regard to the latter, it offers the concept of a ‘ differentiateduniversalism’ as an attempt to reconcile the universalism which lies at the heart ofcitizenship with the demands of a politics of difference. Embracing also the recon-struction of the public– private dichotomy, citizenship, reconceptualized in this way,can, it is argued, provide us with an important theoretical and political tool.
Keywords
agency; citizenship; difference; exclusion; obligations; political participation;rights; synthesis
1This paperis divided into two main parts. The rst reviews the differentmeanings of citizenship in order to argue for a synthesis of the rights andparticipatory traditions, linked through the notion of human agency. Thesecond considers citizenship’ s exclusionary tensions which have served toexclude women and minority groups from full citizenship, both fromwithin and from without the nation state. In doing so, it addresses the chal-lenge of diversity and difference for citizenship to argue the case for a‘ differentiated universalism’ with regard to both participation and rights-based conceptions of citizenship.
What is citizenship?A contested concept
The impossibility of arriving at an exhaustive and comprehensive de nitionof citizenship, commented on even by Aristotle, is a common refrain28
running through the literature. Rather than attempt such a de nition of this‘ slippery concept’ (Riley, 1992: 180), many today fall back on that providedby T. H. Marshall: ‘ Citizenship is a status bestowed on those who are fullmembers of a community. All who possess the status are equal with respectto the rights and duties with which the status is endowed’ (1950: 28– 9).The key elements here are membership of a community (itself an increas-ingly contested concept); the rights and obligations which ow from thatmembership and equality. In each case, we are talking about not simply aset of legal rules governing the relationship between individuals and thestate in which they live but also a set of social relationships between indi-viduals and the state and between individual citizens (the latter receivingparticular emphasis in the Scandinavian literature). The Scandinavianliterature also attaches especial importance to the participatory meaningof membership in a community. This provides a bridge between Marshal-lian rights and more republican approaches to citizenship which stand intwo competing traditions: the liberal rights and the civic republican, con-ceptualized by Adrian Old eld (1990) as citizenship as a status vs citizen-ship as a practice.
Rights or obligations?
Rights Marshall’s tripartite formulation of the civil, political and social is usually
2taken as the starting point for any discussion of citizenship rights.However, the legitimacy of social rights has been subject to renewed chal-lenge with the renaissance of classical liberalism in the form of the NewRight. Two key arguments for social rights are, rst, that they help topromote the effective exercise of civil and political rights by groups whoare disadvantaged in terms of power and resources (Lister, 1990a, 1993);and, second, that they are essential to the promotion of individual auton-omy. This, according to Doyal and Gough’ s theory of human needs, con-stitutes one of the preconditions for action in any culture and as such oneof the ‘ most basic human needs – those which must be satis ed to somedegree before actors can effectively participate in their form of life toachieve any other valued goals’ (Doyal and Gough, 1991: 54). Doyal andGough maintain that their theory of human needs provides a justi cationnot only for civil and political rights but also for social rights of citizen-ship as critical to The work of Doyal and Gough exempli es a growing willingness on theBritish Left to engage in a rights discourse in contrast with the traditionalMarxist approach which tended to dismiss the idea of citizenship rights asan individualistic bourgeois charade, designed to obscure fundamentaleconomic and social class divisions behind a veneer of equality. Doyal andGough (1991: 224) reject such an approach as ‘ counterproductive anddangerous’ for it ignores the ways in which rights can help protect humanneeds, thereby (although they do not nish the argument) mitigating econ-omic and social inequalities.
Feminist attitudes towards rights stretch from their embrace by liberalfeminists as central to any reform programme to their dismissal by radicalfeminists as merely the expression of male values and power (for a dis-cussion, see Bryson, 1992). Those writing in a socialist tradition are waryof the individualistic nature of rights; a number of feminist theorists havecounterpoised an ethic of care against an ethic of justice or rights andfeminist legal theorists tend to caution against placing too much faith inrights, while also counselling against outright rejection. Feminist scepti-cism about citizenship rights overlaps with that of the radical Left whohave highlighted ‘ the failure of citizenship rights vested in liberal demo-cratic institutions to meet the needs of women and racialised groups andthe socially and economically marginalised’ (Taylor, 1989: 29).
In part, this re ects citizenship’ s exclusionary tensions, which I will discussin the next section. At the same time, it also suggests another avenue whichis the ‘ radical extension’ (Doyal and Gough, 1991) of Marshall’s triad toembrace other categories of rights which have been demanded by socialmovements, in particular reproductive rights. To the extent that the latterare now recognized, it represents a triumph for feminist ‘ needs discourses’in the ‘ politics of needs interpretation’ (Fraser, 1987). David Held (1995),who has made the case for such a ‘ radical extension’ , identi es seven clus-ters of rights corresponding to key sites of power – health, social, cultural,civil, economic, paci c and political – which, he contends, are key to theentrenchment of the principle of autonomy and to the facilitation of freeand equal political participation.
In similar vein, Carol Gould (1988: 212) argues that ‘ the right of partici-pation in decision-making in social, economic, cultural and political life’should be included in the nexus of basic rights. Her approach is echoed inattempts on the left to develop a more dynamic Beresford and Croft, 1993). This is not to be confused with the recastingof the citizen as consumer of welfare services under the Citizen’s Charterintroduced by the Conservatives.ObligationsThe market-oriented conceptualization of social citizenship rights exempli-
ed by the Citizen’s Charter is nicely complemented by the political Right’sgrowing emphasis on citizenship obligation and in particular the obli-gation to undertake paid employment. This re ects what Maurice Roche(1992) has dubbed a ‘ duties discourse’ , which is becoming increasinglyin uential in Western European and US social policy. Roche points to thein uence of new social movements (in particular greens and feminists) inthe development of this duties discourse. A key issue for feminists is howcare ts into any con guration of citizenship obligations (Bubeck, 1995;Lister, 1997). However, it is, as Roche points out, the Right (in particularneo-conservatives) who have deliberately challenged the existing ‘ rightsdiscourse’ and who have done most to shift the fulcrum of the citizenshipparadigm which dominates contemporary politics in countries such as theUK and US.
3Most of the key texts contributing to this shift originate in the US, includ-ing in uential works by Mead (1986) and Novak et al . (1987) whichidentify engagement in paid work by welfare recipients to support theirfamilies as the prime obligation. The key policy issue – of whether this obli-gation should apply to those caring for children, and in particular loneparents – underlines its gendered nature.More generally, a number ofBritish politicians across the political spectrum, together with in uentialcommentators, have embraced the communitarian message of AmitaiEtzioni’s The Spirit of Community. Etzioni calls for ‘ a moratorium on theminting of most, if not all, new rights’ , together with the re-establishmentof the link between rights and responsibilities and recognition that thelatter do not necessarily entail the former. His goal is correction of ‘ thecurrent imbalance between rights and responsibilities’ (1993: 4).
Few would dispute that responsibilities as well as rights enter into thecitizenship equation. The question is: what is the appropriate balance andrelationship between the two and how does that balance re ect gender andother power relations (an aspect of the question which is particularly per-tinent when considering the obligation to take paid work)? One helpfulformulation, which attempts to encapsulate a reciprocal relationshipbetween rights and obligations, is that put As I shall argue below, the notion of agency helps knit together the differ-ent approaches to citizenship. It can also be found implicitly in notions of‘ active citizenship’ which have been promoted in the British context, fromvery different standpoints. The term was rst coined by government min-isters as an exhortation to discharge the responsibilities of neighbourliness,voluntary action and charity, largely discredited because of the context ofthe rundown of public sector services and the privatization programmewithin which it was advanced. Nevertheless, in both the UK and the USideas for citizens’ or community service have been put forward and somehave argued that community service should equate with paid work as ameans of discharging the general obligations of citizenship (Leisink andCoenen, 1993).
There is, too, a more radical conception of active citizenship on offer,re ected in an alternative de nition provided by Ray Pahl as ‘ local peopleworking together to improve their own quality of life and to provide con-ditions for others to enjoy the fruits of a more af uent society’ (1990). Thisis a form of active citizenship which disadvantaged people, often women,do for themselves, through for example, community groups, rather thanhave done for them by the more privileged; one which creates them as sub-jects rather than objects. A vivid example of this kind of active citizenshipcan be found among the myriad of women’ s groups in Northern Ireland(Lister, 1994a; WCRG, 1995: Fearon, 1996). The notion of active citizen-ship duty has also been broadened out to encompass ideas of ecologicalcitizenship obligations which stretch beyond the geographical and tem-poral boundaries of the citizen’s community (Weale, 1991; Twine, 1994;van Steenbergen, 1994).
Citizenship as political obligationIt is in the civic republican tradition that we nd the source of today’ s
duties discourse. Originating in the classical Graeco-Roman world, itappeals to the values of civic duty, the submission of individual interest tothat of the common good and the elevation of the public sphere in whichthe citizen is constituted as political actor. The renaissance of civic repub-licanism, particularly in the US, the appeal of which is not con ned to anyone point in the political spectrum, represents a reaction against the indi-vidualism of the previously dominant liberal citizenship paradigm. This, itis argued, represents an impoverished version of citizenship in which indi-vidual citizens are reduced to atomized, passive bearers of rights whosefreedom consists in being able to pursue their individual interests. of citizenship ispivotal to contemporary civic republicanism and in particular to its appro-priation, suitably modi ed, by some feminist writers, most notably Mary
Dietz. For Dietz, it is only ‘ through active engagement as citizens in thepublic world’ and the recognition of the activity of citizenship as itself avalue that feminists will ‘ be able to claim a truly liberatory politics as theirown’ (1987: 15). Others have been attracted by the portrayal of citizen-ship as active political participation, while remaining critical of some of itsother key tenets (see, for instance, Young, 1989, 1990; Phillips, 1991,1993). Potentially problematic for feminists are: the demanding nature ofrepublican citizenship which has particular implications for women, dis-advantaged by the sexual division of time; its narrow conception of the‘ political’ built on a, generally, rigid separation of public and privatespheres; and its uncritical appeal to notions of universalism, impartialityand the common good. Without pursuing all the arguments here (see Lister,1995, 1997), it is possible, I would argue, to develop a modi ed modelwhich draws on the civic republican tradition but in a way which promotesthe interests of women’ s citizenship.4In particular, an important element of any feminist citizenship project is toquery establishment understandings of the ‘ common good’ and to de neboth citizenship and the ‘ political’ in broad terms so as to encompass thekind of informal politics in which women often take the lead and thestruggles of oppressed groups generally. Under such a de nition (whichdiffers from that espoused by traditional civic republicanism), citizenshippolitics can be oppositional and disruptive. Thus, for instance, non-violentdirect action of the kind being taken by anti-road protesters in the UK,even though sometimes crossing the boundaries of what is deemed lawful,represents a form of citizenship which is implicitly appealing to an alterna-tive version of the common good. Likewise, traditional civic republican-ism’ s dictum that citizenship requires impartiality and the transcendenceof group differences is rejected on the grounds that it serves to reinforcethe very exclusion against which disadvantaged groups are ghting, in thename of a common good which has subordinated their interests to thoseof more powerful groups (Young, 1989, 1990; Phillips, 1991, 1993).
It is the local rather than the national which provides the arena for manycitizenship struggles of this kind. As a process, community action can bothstrengthen deprived communities and, through collective action, promotethe citizenship of individuals within those communities. Such action canboost individual and collective self-con dence, as individuals and groupscome together to see themselves as political actors and effective citizens.This is especially true for women for whom involvement in communityorganizations can be more personally fruitful anthropologist, Sue Hyatt, who worked with women on a Bradfordcouncil estate, as ‘ accidental activism’ , through which ‘ women who previ-ously did not see themselves as in any way political are becoming advo-cates for social change’ (1992: 6). Similarly, a Northern Ireland study bythe Women and Citizenship Research Group (1995) underlines the senseof personal power or effectiveness that women, previously inexperiencedin political action, have gained as a result of such activism. This contrastswith their exclusion from the formal political system. Placing value oninformal politics as an expression of citizenship does not, however, meanignoring the continuing need both to open up formal political arenas towomen and also to make formal politics more accountable to informal.
Synthesis
Recognizing the limitations of both the main citizenship traditions, weneed, as Chantal Mouffe argues, ‘ to go beyond the conceptions of citizen-ship of both the liberal and the civic republican traditions while buildingon their respective strengths’ (1992: 4). This conception would, she sug-gests, draw on both the liberal formulation of free and equal rights-bearingcitizens and the richer republican conceptualization of active political par-ticipation and civic engagement (but based on a radical, pluralist refram-ing of the ‘ common good’ ). A reading of the literature suggests that, whilethe rights and participatory approaches to citizenship remain conceptuallydifferent, they do not necessarily have to con ict; instead, they can be seenas mutually supportive, even if tensions between them remain.
An example of how the two coalesce is provided by the process of negoti-ation with welfare state institutions, by individuals as well as groups, themain responsibility for which tends to fall to women (Nelson, 1984; Jones,1990). This perspective on citizenship is exempli ed by the work of Scan-dinavian feminist scholars such as Helga Hernes and Birte Siim. Hernes,for example, writes:
The welfare state literature, to the extent that it deals with individual citizens,deals with those aspects of citizenship that are related to social policy entitle-ments. Democratic theories and empirical studies of democratic politics empha-sise the participatory aspects of citizenship. Any adequate account ofcontemporary citizenship in Scandinavia must include all these dimensions ifthe interplay between material rights, multi-level participation, and 1992; Koven and Michel, 1993; Lewis, 1994). The nature of the socialrights that have emerged has, in part, been a re ection of the extent towhich women have been involved in their construction. Conversely, theextent of women’ s political involvement has, in part, been a re ection ofthe nature of the social and reproductive rights they have achieved andtheir mobilization has been, in part, a function of their relationship withthe welfare state.5This helps to underline the importance for a feminist theory of citizenshipof a ‘ synthetic’ approach, which embraces elements of the two main his-torical citizenship traditions. A rounded and fruitful theorization ofcitizenship, which can be of potential value to women, has to embrace bothindividual rights (and, in particular, social and reproductive rights) andpolitical participation and also has to analyse the relationship between thetwo (Sarvasy and Siim, 1994). At the core of this conceptualization lies theidea of human agency.Citizenship as participation represents an expres-sion of human agency in the political arena, broadly de ned; citizenshipas rights enables people to act as agents. Moreover, citizenship rights arenot xed. They remain the object of political struggles to defend, reinter-pret and extend them. Who is involved in these struggles, where they areplaced in the political hierarchy and the political power and in uence theycan yield will help to determine the outcomes. Citizenship thus emerges asa dynamic concept in which process and outcome stand in a dialecticalrelationship to each other. Such a conceptualization of citizenship is par-ticularly important in challenging the construction of women (and especi-ally minority group women) as passive victims, while keeping sight of thediscriminatory and oppressive male-dominated political, economic andsocial institutions which still deny them full citizenship. People can be, atthe same time, both the subordinate objects of hierarchical power relationsand subjects who are agents in their own lives, capable of exercising powerin the ‘ generative’ sense of self-actualization (Giddens, 1991).
Finally, to tie up this discussion with the earlier one on obligation, I drawa distinction between, on the one hand, an emphasis on the importance forcitizenship of political participation, broadly de ned, and, on the other, aconstruction of active political participation as a citizenship obligation.Given the constraints on women’s lives and the obstacles they face, thereis a real danger of creating a measuring rod of citizenship against whichmany women might, yet again, fall short. Moreover, it is one which coulddeny the citizenship of those constrained by severe disability, chronicillness or frailty (Meekosha and the rights necessary for agency and social and political participation. Toact as a citizen involves ful lling the full potential of the status. Those whodo not ful l that potential do not cease to be citizens. Moreover, in prac-tice, political participation tends to be more of a continuum than an all ornothing affair; it can uctuate during the individual’s life-course, re ect-ing, in part, the demands of caring obligations which can also be inter-preted as the exercise of citizenship obligations.
Citizenship’ s exclusionary tensions
The greater or lesser ability of certain groups to act as citizens and thedegree to which they enjoy both formal and substantive rights as citizensdepends on where they stand on a continuum of inclusion and exclusionwhich, at the extremes, represent the two sides of citizenship’ s coin.Whereas much of the citizenship literature has traditionally focused on itsin clusionary face, more radical contemporary writings tend to portraycitizenship as a force for ex clusion which creates non or partial citizens.These can be characterized as ‘ those who are excluded from without’ and‘ those who are excluded from within’ speci c citizenship communities ornation states (Yeatman, 1994: 80).
Exclusion from without
The exclusionary force of nation-state-bound citizenship has been throwninto relief in the West and North with the growth in the number ofmigrants and asylum-seekers in recent decades. Although generally notre ected in the mainstream migration literature, women form a signi cantproportion of migrants and of asylum-seekers and for them the exclusion-ary force is compounded by laws which construct them as economic depen-dants (Morokvasic, 1984, 1991, 1993; Kofman & Sales, 1992; Bhabhaand Shutter, 1994; Knocke, 1995). In Europe, this force is now beingstrengthened as members of the EU become European citizens behind theracialized ramparts of Fortress Europe.
The status of large numbers of peoples resident in states of which they arenot legally citizens raises a number of question marks over the meaning ofcitizenship in a world where migratory pressures are likely to intensify(Hammar, 1990; Castles and Miller, 1993). William Rogers Brubaker(1992) and Joseph Carens (1989) underline the symbolic importance ofthe stance taken by a state towards access to formal liberal-democratic ‘ principles of toleration and diversity’ (Carens 1989:38) and calls into question the equal status of existing minority groups.This, it has been suggested, points to a ‘ multicultural’ model of citizenship(Castles and Miller, 1993).The exact nature of such a model is, however, contested. In particular, itruns the risk of treating cultural groups as homogeneous, ignoring differ-ences such as gender, sexuality, age and class (Yuval-Davis, 1991; Ali,1993; Bhavnani, 1993). In his treatise on multicultural citizenship, WillKymlicka (1995) makes a helpful distinction between minority rightswhich promote the interests of minority groups in relation to the majorityand those which allow minority groups to impose restrictions on their ownmembers in the name of traditional authorities and practices. Support forthe former but not the latter, he argues, helps to ensure not just equalitybetween groups but freedom and equality within groups. As he acknow-ledges, maintaining such a distinction may be dif cult in practice. More-over, it still leaves open the question of whose interpretation of minorityrights is listened to. Nevertheless, Kymlicka does offer a possible frame-work for addressing claims for minority group rights while recognizingdifferent interests within groups.
6There is also a danger that the multi-cultural model essentializes andfreezes cultural differences (Ali, 1993). Conversely, it can represent mereliberal toleration of diversity, con ned to the ‘ private’ sphere, rather thangenuine acceptance and recognition of such diversity in the ‘ public’(Parekh, 1991; Galeotti, 1993). The notion of ‘ trans-culturalism’ , whichneither reduces people to cultural groups nor ignores cultural identities,has been put forward as a possible way of avoiding some of these pitfalls.Its implications, both theoretically and politically, would need furtherexploration.
From an international perspective, widening economic inequalities be-tween North and South fuel migration, on the one hand, and exclusionaryresponses, on the other. Paradoxically, there is an impetus to heighten thebarriers around nation-states (or groups of nation-states as in the EU) atthe very time when the nation-state is itself becoming less pivotal econ-omically and politically. The image of a weakened nation-state caught ina pincer movement between globalizing and localizing forces is a commonrefrain in the contemporary citizenship literature, although one should notexaggerate the demise of its power, not least its power still to exercisecontrol over membership and citizenship 1991) and to argue for the development of an analysis of citizenship at aglobal level (Turner, 1990; Held, 1995; Falk, 1994). This can incorporatenotions of rights and responsibilities as well as democratic accountabilityand political action, through both formal and informal channels. Argu-ably, we are today witnessing the emergence of a global civil society, inwhich women are playing a central role, witness the participation of thou-sands of women from all over the world in the Non-GovernmentalOrganisation Forum at Beijing and the wider electronic networks whichlinked up with it (Journal of International Communication, 1996).
Developments such as these have led to some recognition that a feministtheory and politics of citizenship must embrace an internationalist agenda(see, in particular, Jones, 1994). Conversely, it is crucial that the theoriza-tion of global citizenship is informed by feminist perspectives and does notrecreate the exclusionary tendencies which have typi ed much of the main-stream citizenship literature.
Exclusion from within
These exclusionary tendencies are inherently gendered, re ecting the factthat women’ s long-standing expulsion from the theory and practice ofcitizenship, in both its liberal and republican clothes, is far from acciden-tal and only partially recti ed by their formal incorporation in virtually allsocieties in the twentieth century. Gendered patterns of exclusion interactwith other axes of social division such as class, ‘ race’ , disability, sexualityand age in ways which can be either multiplicative or contradictory, andwhich shift over time (Brewer, 1993; Brah, 1996).
The de-construction of the unitary womanThanks to feminist scholarship, the veil of universalism which enshrouds
‘ malestream’ political theory has been lifted to make visible the femalenon-citizen who stood outside it and to reveal the male citizen lurkingbeneath it. This challenge to political theory’ s ‘ false universalism’(Williams, 1989: 118) has now been matched by a similar challenge to thefalse universalism of the category ‘ woman’ . This has come from both thetheoretical advance of post-structuralism and from Black and other groupsof women whose identities and interests have been ignored, marginalizedor subsumed. They have underlined how the category ‘ woman’ has, in fact,been representative of dominant groups of women in the same way thatthe abstract individual of Acknowledgement of the need to problematize the category ‘ woman’ inrecognition of the differences between women and the ways in which thesedifferences shape the economic, social and political relationships betweenwomen as well as between women and men and women and the state does,though, run into the danger that, if ‘ woman’ is simply deconstructed and leftin fragments, there is no woman left to be a citizen. The fact that the cat-egory ‘ woman’ is not unitary does not render it meaningless (Maynard,1994). Black feminists, such as bell hooks (1984), Audre Lorde (1984) andPatricia Hill Collins (1991) have argued that, provided the differencesbetween women are fully acknowledged, they do not preclude solidarity onthe basis of those interests still shared as women. Central to these interestsis women’s exclusion from full citizenship, as the patterns of entry to the gate-ways to the various sectors of the public sphere remain profoundly gendered.Thus, the project of engendering citizenship is not invalidated, but it has tobe conceived of as part of a wider project of differentiating citizenship.The challenge of diversity and difference for citizenshipFeminist theory’ s dual challenge to the false universalism of citizenship and
7the category ‘ woman’ has underlined the need for ‘ a conception of citizen-ship which would accommodate all social cleavages simultaneously’ (Leca,1992: 30). While attempts to elaborate such a conception demonstrate thedif culties,8it is my view that this is the direction which citizenship theoryhas to take, if it is to match up to its inclusionary and universalist claims.It is not a case, therefore, of abandoning citizenship as a universalistproject, for to do so is also to abandon the ‘ emancipatory potential’ whichstrikes such a political resonance for many people (Vogel, 1988; Riley,1992). Instead, our goal should be a universalism which stands in creativetension to diversity and difference and which challenges the divisions andexclusionary inequalities which can stem from diversity.9We might call thisa ‘ differentiated universalism’ , drawing on contemporary radical politicaltheory which is attempting to ‘ particularize’ the universal in the search for‘ a new kind of articulation between the universal and the particular’(Mouffe, 1993: 13; Yeatman, 1993: 229).Universalism is understood herenot as false impartiality but as a ‘ universality of moral commitment’ to theequal worth and participation of all (Young, 1990).
We can apply this theoretical stance to the question of both citizenshiprights and participation. Nira Yuval-Davis (1994, this issue) has exploredthe implications of these tensions for citizenship vocabulary of a ‘ politics of difference’ which involves ‘ a commitment to auniversalistic orientation to the positive value of difference within a demo-cratic political process’ (1994: 89). Such a politics of difference requires,she argues, both ‘ an inclusive politics of voice and representation’ and ‘ areadiness on the part of any one emancipatory movement to show how itsparticular interest in contesting oppression links into and supports theinterests of other movements in contesting different kinds of oppression’(1993: 231).
It is, as is so often the case, easier to envisage such a process in theory thanin practice. As Yuval-Davis warns, there are some situations in which con- icting positions are not reconcilable and, by and large, political systemsdo not provide the time and space for such dialogue. Moreover, there is atendency to underestimate the dif culties some groups, in particular thosein poverty, would have in entering the dialogue in the rst place. Never-theless, there are examples which indicate that such a transversal politicsis possible. To take just two from con ict areas: rst, during the period oftransition to the new South Africa, a Women’ s National Coalition wasformed which represented an ‘ extraordinary convergence of women acrossgeographical, racial, class, religious, and political lines’ and ‘ a forumthrough which women who harbored deep animosities could also identifycommon concerns’ (Kemp et al. , 1995: 150– 1). Through a process of dia-logue and negotiation and despite ssures and disagreements, the Coali-tion drafted a Women’ s Charter for Effective Equality which gave womenin their diversity a voice in the writing of the new constitution. Second, ina photo-essay called ‘ different together’ , Cynthia Cockburn describes howa form of transversal politics is being pursued by women’s centres inBelfast:
Individually women hold on to their political identities – some long for a unitedIreland, others feel deeply threatened by the idea. But they have identi ed a com-monality in being women, being community based and being angry at injusticeand inequality, that allows them to af rm and even welcome this and otherkinds of difference.
(Cockburn, 1996: 4)
Yeatman relates a politics of difference to questions of rights. It would, shesuggests, involve ‘ a new kind of rights talk’ in which ‘ rights are understoodas dialectical and relational in respect of opening debate and discussionabout how to positively alter relationships of oppression. They are dia-logical rights, predicated fundamentally on a right to give voice and be lis-tened to within the dialogical process of to distinguish two, complementary, approaches to the accommodation ofdiversity and difference in the conceptualization of citizenship rights.The rst is to recognize that rights can be particularized to take accountof the situation of speci c groups both in the ‘ reactive’ sense of counter-acting past and present disadvantages which may undermine their positionas citizens and in the ‘ proactive’ sense of af rming diversity, particularlywith regard to cultural and linguistic rights. Examples of the former areaf rmative action programmes and the kind of wide-ranging disability dis-crimination legislation enacted in the US. Examples of the latter are, rst,multicultural language policies, which give of cial recognition to the lan-guages of signi cant minority ethnic groups, as in Sweden and Australia(Castles, 1994), and, second, the speci c political, legal and collectiverights enjoyed by indigenous American Indians in parallel with their rightsas US citizens (Young, 1989, 1990, 1993). Such attempts to rearticulatethe relationship between the universal and the particular are, however,politically charged as can be seen in the US where the growth of the His-panic community has led to pressures for English to be declared the of ciallanguage and where there is a growing backlash against af rmative actionprogrammes (see also Bacchi, 1996).
10The second approach, advocated by David Taylor (1989), is to anchorcitizenship rights in a notion of need on the basis that need can be seen asdynamic and differentiated, as against the universal and abstract basis ofrights. This formulation is useful in opening up the political dynamics ofthe relationship between needs and rights in citizenship struggles, or ‘ thepolitics of needs interpretation’ (Fraser, 1987).However, Taylor’s dis-tinction between needs as differentiated and rights as abstract and uni-versal is, arguably, something of an oversimpli cation. As I have justsuggested, rights can be differentiated on a group basis and Doyal andGough’s theory of needs (1991), upon which Taylor draws is, as he himselfnotes, rooted in a universalistic understanding of basic human needs whichare then subject to different cultural and historical interpretations (Hewitt,1994). Likewise, from a feminist perspective, Zillah Eisenstein contendsthat ‘ a radicalised feminist rights discourse recognizes particularity andindividuality of need even as it calls upon the similarity (rather than iden-tity) of women’ (1991: 122). What this discussion suggests is that bothneeds and rights need to be understood as tiered, embracing both the uni-versal and the differentiated, and standing in a dynamic relationship toeach other Fraser (1987: 117– 18),
is the legitimization of ‘ women’s needs as genuine political issues as opposed to “ private” domestic or market matters’ , recognizing that needsand priorities will vary for different groups of women. The feministstruggles which this has entailed have involved the deconstruction of the‘ patriarchal separation’ (Pateman, 1989: 183) between the ‘ public’ and thedomestic ‘ private’ which underpins the very (gendered) meaning of citizen-ship as traditionally understood.
As a result, the public– private divide can be understood as a shifting politi-cal construction, under constant renegotiation, which re ects both his-torical and cultural contexts as well as the relative power of different socialgroups. The public and private de ne each other and take meaning fromeach other. We cannot, for instance, understand the gendered patterns ofentry to citizenship in the public sphere without taking into account thesexual division of labour within the private. Similarly, women’ s treatmentunder asylum laws, which tend to deny refugee status to women eeingsexual persecution, is governed by the public-private divide. The struggleto control the meaning and positioning of the divide is central to theproject of engendering citizenship. It is one of feminism’s achievements thatit has successfully challenged the positioning of the divide in relation to anumber of issues. Yet, its implications still tend to be ignored or discountedby male citizenship theorists, despite the fact that the link was madebetween women’ s exclusion from citizenship and their position in theprivate sphere by Mary Wollstonecraft and John Stuart Mill back in theeighteenth and nineteenth centuries.
Conclusion
The starting point of this paper has been the attempt to synthesize throughthe notion of human agency the two different historical traditions ofcitizenship in which citizenship is constructed both as a status and a prac-tice. This provides a framework for thinking about women’ s citizenshipwhich both recognizes the structural constraints which still diminish andundermine that citizenship while not reducing women to passive victims.
In examining the exclusionary tensions which serve to perpetuate women’sexile as a group from full citizenship, emphasis has been placed on the needto locate a gendered analysis within the wider framework of difference andthe divisions and exclusionary inequalities which ow from it. This pointsto a conception of citizenship grounded in a notion of ‘ differentiated uni-versalism’ which represents an 
dichotomy. Thus, recast on feminist lines, citizenship offers us both avaluable perspective on the position of women in their diversity and animportant political tool for women and other oppressed groups.Ruth Lister is Professor of Social Policy in the Department of Social Sciences,Loughborough University.
1 This is a revised version of the paper given at the Women and Citizenship Con-ference, Greenwich, and of an earlier paper given at the DIOTIMA Gender ofRights conference, Athens, February 1996. It is based on a forthcoming book(Lister, 1997). I am grateful to the Nuf eld Foundation for a personal fellow-ship which enabled me to write the bulk of the book.
2 The issue of autonomy and economic independence in the context of notionsof interdependence is key to the construction of women’s citizenship (see Lister1990b, 1994b, 1995).
3 The policy trend in both the US and Europe is to include lone parents in theobligation to undertake paid work. The clearest example in Europe is theNetherlands where the presumption that lone mothers are exempt from theobligation to undertake paid work is progressively being abandoned. In con-trast, the UK is one of very few countries which still permit lone parents toclaim social assistance until their youngest child is of school-leaving agewithout being required to register for paid work.
4 This does, though, as Phillips (1993) warns, raise dif cult questions as to wherethe dividing line is drawn between such a de nition of citizenship politics andsectional interest group politics.
5 My conceptualization of human agency is in uenced by the work of CarolGould and her articulation of the actions and choices of autonomous actors asa process of self-development: ‘ of concretely becoming the person one choosesto be through carrying out those actions that express one’ s purposes and needs’(1988: 47). In developing her self, the individual is also acting upon, andthereby potentially changing the world, a world which at the same time struc-tures the choices available (see also Twine, 1994). Moreover, individuals areunderstood to be ‘ social from the start, both in the fact that social relations arean essential mode of their individual self-development and that they character-istically engage in common activities, oriented to common and not merely indi-vidual ends’ (Gould, 1988: 71).
and peace held in Cork, the Republic of Ireland, November 1995.
7 See, for instance, the criticisms of Iris Marion Young’s ‘ politics of differenceand group assertion’ (1990) which attempts to incorporate difference into the theory and politics of political citizenship (e.g. Mouffe, 1992; Phillips,1993;Wilson, 1993).
8 I am here following Fiona Williams (1996) who distinguishes between diver-sity, difference and division, making clear that they are not xed categories.Diversity is used to refer to a shared collective experience which does notnecessarily imply relations of subordination, for example based on age, nation-ality, sexual identity. Division occurs where diversity is translated into relationsof subordination. Difference signi es a situation where diversity becomes thebasis for resistance against such subordination.
9 See also Benhabib (1992); Gunew and Yeatman (1993) and Judith Squires’edited collection, Principled Positions(1993), which attempts to resurrect anotion of social justice by means of bridge-building ‘ between the supposed uni-versalism of modernism and the fragmented particularities left behind by post-structuralist deconstructions’ (Harvey, 1993: 102).
10 The disability rights movement provides a good example of a political chal-lenge to orthodox needs interpretations. It has also underlined the dangers ofdisconnecting a needs from a rights discourse; in the UK, disability rightsactivists have argued that a shift of emphasis from the rights to the needs ofdisabled people has opened the way for the professional domination of welfareprovision and ‘ a retreat from active to passive citizenship’ (Oliver and Barnes,1991: 8).
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