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Thin and thick conceptions of citizenship

Citizenship is often described as having three dimensions: 1) membership/status, 2) rights and 3) identity or citizenship as a practice. In addition, the literature identifies the following conceptions of citizenship, ranging from thin to thick: legal positivism and libertarianism; civic republicanism; and nationalism and communitarianism. Rainer Bauböck has provided the following insightful table visualizing these dimensions and conceptions:

As the table shows, the thinnest conception of citizenship is that of nationality as a legal status under international law. Indeed, nationality is often considered an ‘empty notion’ which only acquires substantial meaning as a result of the legal consequences which individual national legal systems connect with it. This view is wholly compatible with the fact that international law requires a ‘genuine link’ between an individual and a State for a nationality to have effect on the international plane, and the idea of nationality as an empty notion seems confirmed in the statement by the International Court of Justice in the Nottebohm judgment that ‘nationality serves above all to determine that the person upon whom it is conferred enjoys the rights and is bound by the obligations which the law of the State in question grants to or imposes on its nationals’.

On the thick end of the spectrum, citizenship represents a collective cultural identity. This is characteristic for nationalist ideologies, be they of an ethnic or civic kind. For ethnic nationalists the nation is first and foremost a cultural community, while for civic nationalists it is a political community. Civic nationalism was therefore espoused mainly by liberal states invoking Enlightenment values. Both forms of nationalism could lead to human rights violations, however, in the form of ethnic cleansings and genocide (ethnic nationalism) or enforced assimilations and oppressed minority cultures (civic nationalism). Republicanism differs from nationalism in emphasizing the political rather than cultural nature of membership. According to Bauböck, ‘for civic republicans citizenship is a common bond that must be strong in order to unite the members of a liberal democracy who are thoroughly divided by their private interests and affiliations but need not be thick with cultural particularity’.

What this shows is that the terms ‘nation’ and ‘nationality’ can be used to describe both the thinnest and thickest conceptions of citizenship. As a result, terms such as ‘citizenship’ and ‘nationality’ have traditionally been surrounded by a considerable degree of confusion. This also follows from the fact that different meanings may be attached to them depending on the legal tradition in a particular country or the academic discipline. A similar problem arises in respect of the terms ‘Nation’ and ‘State’. These concepts are sometimes used as synonyms, but authors such as David Miller argue for the sake of conceptual clarity that a distinction should be made: ‘“Nation” must refer to a community of people with an aspiration to be politically self-determining, and “State” must refer to the set of political institutions that they may aspire to possess for themselves’.

In the continental European tradition the distinction between nationality and citizenship is fairly straightforward. Nationality (French: nationalité; Spanish: nacionalidad) is normally used to indicate a formal, legal bond between an individual and a State; the term citizenship (French: citoyenneté; Spanish: ciudadanía) is used to denote political membership of a State.

There are, however, exceptions to this basic distinction between nationality and citizenship. In Germany, Italy, Poland, and Sweden the terms Staatsangehörigkeit, cittadinanza, obywatelstwo, and medborgarskap are employed to describe a legal link; all these countries except for Germany also use this term to denote ‘political’ citizenship. The words Nationalität, nazionalità, narodowosc, and nationalitet are less frequently used because of their ethnic connotation, although a trend can be observed that – clearly under the influence of the English language – some of these terms are also used as a translation of ‘nationality’ in the legal sense.

Author: Dr. Olivier Vonk

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