Nationality is often used as a synonym for citizenship in English – notably in international law – although the term is sometimes understood as denoting a person's membership of a nation (a large ethnic group). In some countries, e.g. the United States, the United Kingdom, nationality and citizenship can have different meanings (for more information, see Nationality versus citizenship).
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Each country has its own policies, regulations and criteria as to who is entitled to its citizenship. A person can be recognized or granted citizenship on a number of bases. Usually citizenship based on the place of birth is automatic, but in other cases an application may be required.
Many thinkers point to the concept of citizenship beginning in the early city-states of ancient Greece, although others see it as primarily a modern phenomenon dating back only a few hundred years and, for mankind, that the concept of citizenship arose with the first laws. Polis meant both the political assembly of the city-state as well as the entire society. Citizenship has generally been identified as a western phenomenon. There is a general view that citizenship in ancient times was a simpler relation than modern forms of citizenship, although this view has come under scrutiny. The relation of citizenship has not been a fixed or static relation, but constantly changed within each society, and that according to one view, citizenship might "really have worked" only at select periods during certain times, such as when the Athenian politician Solon made reforms in the early Athenian state.
It can be argued that this growth of slavery was what made Greeks particularly conscious of the value of freedom. After all, any Greek farmer might fall into debt and therefore might become a slave, at almost any time ... When the Greeks fought together, they fought in order to avoid being enslaved by warfare, to avoid being defeated by those who might take them into slavery. And they also arranged their political institutions so as to remain free men.— Geoffrey Hosking, 2005
Slavery permitted slaveowners to have substantial free time, and enabled participation in public life. Polis citizenship was marked by exclusivity. Inequality of status was widespread; citizens had a higher status than non-citizens, such as women, slaves or barbarians. The first form of citizenship was based on the way people lived in the ancient Greek times, in small-scale organic communities of the polis. Citizenship was not seen as a separate activity from the private life of the individual person, in the sense that there was not a distinction between public and private life. The obligations of citizenship were deeply connected into one's everyday life in the polis. These small-scale organic communities were generally seen as a new development in world history, in contrast to the established ancient civilizations of Egypt or Persia, or the hunter-gatherer bands elsewhere. From the viewpoint of the ancient Greeks, a person's public life was not separated from their private life, and Greeks did not distinguish between the two worlds according to the modern western conception. The obligations of citizenship were deeply connected with everyday life. To be truly human, one had to be an active citizen to the community, which Aristotle famously expressed: "To take no part in the running of the community's affairs is to be either a beast or a god!". This form of citizenship was based on obligations of citizens towards the community, rather than rights given to the citizens of the community. This was not a problem because they all had a strong affinity with the polis; their own destiny and the destiny of the community were strongly linked. Also, citizens of the polis saw obligations to the community as an opportunity to be virtuous, it was a source of honour and respect. In Athens, citizens were both ruler and ruled, important political and judicial offices were rotated and all citizens had the right to speak and vote in the political assembly.
In the Roman Empire, citizenship expanded from small-scale communities to the entire empire. Romans realized that granting citizenship to people from all over the empire legitimized Roman rule over conquered areas. Roman citizenship was no longer a status of political agency, as it had been reduced to a judicial safeguard and the expression of rule and law. Rome carried forth Greek ideas of citizenship such as the principles of equality under the law, civic participation in government, and notions that "no one citizen should have too much power for too long", but Rome offered relatively generous terms to its captives, including chances for lesser forms of citizenship. If Greek citizenship was an "emancipation from the world of things", the Roman sense increasingly reflected the fact that citizens could act upon material things as well as other citizens, in the sense of buying or selling property, possessions, titles, goods. One historian explained:
The person was defined and represented through his actions upon things; in the course of time, the term property came to mean, first, the defining characteristic of a human or other being; second, the relation which a person had with a thing; and third, the thing defined as the possession of some person.
Roman citizenship reflected a struggle between the upper-class patrician interests against the lower-order working groups known as the plebeian class. A citizen came to be understood as a person "free to act by law, free to ask and expect the law's protection, a citizen of such and such a legal community, of such and such a legal standing in that community". Citizenship meant having rights to have possessions, immunities, expectations, which were "available in many kinds and degrees, available or unavailable to many kinds of person for many kinds of reason". The law itself was a kind of bond uniting people. Roman citizenship was more impersonal, universal, multiform, having different degrees and applications.
During the European Middle Ages, citizenship was usually associated with cities and towns, and applied mainly to middle class folk. Titles such as burgher, grand burgher (German Großbürger) and bourgeoisie denoted political affiliation and identity in relation to a particular locality, as well as membership in a mercantile or trading class; thus, individuals of respectable means and socioeconomic status were interchangeable with citizens.
During this era, members of the nobility had a range of privileges above commoners (see aristocracy), though political upheavals and reforms, beginning most prominently with the French Revolution, abolished privileges and created an egalitarian concept of citizenship.
During the Renaissance, people transitioned from being subjects of a king or queen to being citizens of a city and later to a nation.:p.161 Each city had its own law, courts, and independent administration. And being a citizen often meant being subject to the city's law in addition to having power in some instances to help choose officials. City dwellers who had fought alongside nobles in battles to defend their cities were no longer content with having a subordinate social status, but demanded a greater role in the form of citizenship. Membership in guilds was an indirect form of citizenship in that it helped their members succeed financially. The rise of citizenship was linked to the rise of republicanism, according to one account, since independent citizens meant that kings had less power. Citizenship became an idealized, almost abstract, concept, and did not signify a submissive relation with a lord or count, but rather indicated the bond between a person and the state in the rather abstract sense of having rights and duties.
The modern idea of citizenship still respects the idea of political participation, but it is usually done through "elaborate systems of political representation at a distance" such as representative democracy. Modern citizenship is much more passive; action is delegated to others; citizenship is often a constraint on acting, not an impetus to act. Nevertheless, citizens are usually aware of their obligations to authorities, and are aware that these bonds often limit what they can do.
From 1790 until the mid-twentieth century, United States law used racial criteria to establish citizenship rights and regulate who was eligible to become a naturalized citizen. The Naturalization Act of 1790, the first law in U.S. history to establish rules for citizenship and naturalization, barred citizenship to all people who were not of European descent, stating that "any Alien being a free white person, who shall have resided within the limits and under the jurisdiction of the United States for the term of two years, may be admitted to become a citizen thereof."
Under early U.S. laws, African Americans were not eligible for citizenship. In 1857, these laws were upheld in the US Supreme Court case Dred Scott v. Sandford, which ruled that "a free negro of the African race, whose ancestors were brought to this country and sold as slaves, is not a 'citizen' within the meaning of the Constitution of the United States," and that "the special rights and immunities guarantied to citizens do not apply to them."
It was not until the abolition of slavery following the American Civil War that African Americans were granted citizenship rights. The 14th Amendment to the U.S. Constitution, ratified on July 9, 1868, stated that "all persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside." Two years later, the Naturalization Act of 1870 would extend the right to become a naturalized citizen to include "aliens of African nativity and to persons of African descent".
Despite the gains made by African Americans after the Civil War, Native Americans, Asians, and others not considered "free white persons" were still denied the ability to become citizens. The 1882 Chinese Exclusion Act explicitly denied naturalization rights to all people of Chinese origin, while subsequent acts passed by the US Congress, such as laws in 1906, 1917, and 1924, would include clauses that denied immigration and naturalization rights to people based on broadly defined racial categories. Supreme Court cases such as Ozawa v. United States (1922) and U.S. v. Bhagat Singh Thind (1923), would later clarify the meaning of the phrase "free white persons," ruling that Japanese, Indian, and other non-European people were not "white persons", and were therefore ineligible for citizenship under U.S. law.
Native Americans were not granted full US citizenship until the passage of the Indian Citizenship Act in 1924. However, even well into the 1960s some state laws prevented Native Americans from exercising their full rights as citizens, such as the right to vote. In 1962, New Mexico became the last state to enfranchise Native Americans.
It was not until the passage of the Immigration and Nationality Act of 1952 that the racial and gender restrictions for naturalization were explicitly abolished. However, the act still contained restrictions regarding who was eligible for US citizenship, and retained a national quota system which limited the number of visas given to immigrants based on their national origin, to be fixed "at a rate of one-sixth of one percent of each nationality's population in the United States in 1920". It was not until the passage of the Immigration and Nationality Act of 1965 that these immigration quota systems were drastically altered in favor of a less discriminatory system.
The 1918 constitution of revolutionary Russia granted citizenship to any foreigners who were living within Russia, so long as they were "engaged in work and [belonged] to the working class." It recognized "the equal rights of all citizens, irrespective of their racial or national connections" and declared oppression of any minority group or race "to be contrary to the fundamental laws of the Republic." The 1918 constitution also established the right to vote and be elected to soviets for both men and women "irrespective of religion, nationality, domicile, etc. [...] who shall have completed their eighteenth year by the day of election." The later constitutions of the USSR would grant universal Soviet citizenship to the citizens of all member republics in concord with the principles of non-discrimination laid out in the original 1918 constitution of Russia.
National Socialism or "Nazism", the German variant of twentieth century fascism whose precepts were laid out in Adolf Hitler's Mein Kampf, classified inhabitants of the nation into three main hierarchical categories, each of which would have different rights and duties in relation to the state: citizens, subjects, and aliens. The first category, citizens, were to possess full civic rights and responsibilities. Citizenship would be conferred only on males of German (or so-called "Aryan") heritage who had completed military service, and could be revoked at any time by the state. The Reich Citizenship Law of 1935 established racial criteria for citizenship in the German Reich, and because of this law Jews and others who could not prove "German" racial heritage were stripped of their citizenship.
The second category, subjects, referred to all others who were born within the nation's boundaries who did not fit the racial criteria for citizenship. Subjects would have no voting rights, could not hold any position within the state, and possessed none of the other rights and civic responsibilities conferred on citizens. All women were to be conferred "subject" status upon birth, and could only obtain "citizen" status if they worked independently or if they married a German citizen (see women in Nazi Germany).
The final category, aliens, referred to those who were citizens of another state, who also had no rights.
"The People's State will classify its population in three groups: Citizens, subjects of the State, and aliens.
The principle is that birth within the confines of the State gives only the status of a subject. It does not carry with it the right to fill any position under the State or to participate in political life, such as taking an active or passive part in elections. Another principle is that the race and nationality of every subject of the State will have to be proved. A subject is at any time free to cease being a subject and to become a citizen of that country to which he belongs in virtue of his nationality. The only difference between an alien and a subject of the State is that the former is a citizen of another country.
The young boy or girl who is of German nationality and is a subject of the German State is bound to complete the period of school education which is obligatory for every German. Thereby he submits to the system of training which will make him conscious of his race and a member of the folk-community. Then he has to fulfil all those requirements laid down by the State in regard to physical training after he has left school; and finally he enters the army. The training in the army is of a general kind. It must be given to each individual German and will render him competent to fulfil the physical and mental requirements of military service. The rights of citizenship shall be conferred on every young man whose health and character have been certified as good, after having completed his period of military service. This act of inauguration in citizenship shall be a solemn ceremony.
And the diploma conferring the rights of citizenship will be preserved by the young man as the most precious testimonial of his whole life. It entitles him to exercise all the rights of a citizen and to enjoy all the privileges attached thereto. For the State must draw a sharp line of distinction between those who, as members of the nation, are the foundation and the support of its existence and greatness, and those who are domiciled in the State simply as earners of their livelihood there.
On the occasion of conferring a diploma of citizenship the new citizen must take a solemn oath of loyalty to the national community and the State. This diploma must be a bond which unites together all the various classes and sections of the nation. It shall be a greater honour to be a citizen of this Reich, even as a street-sweeper, than to be the King of a foreign State.
The citizen has privileges which are not accorded to the alien. He is the master in the Reich. But this high honour has also its obligations. Those who show themselves without personal honour or character, or common criminals, or traitors to the fatherland, can at any time be deprived of the rights of citizenship. Therewith they become merely subjects of the State.The German girl is a subject of the State but will become a citizen when she marries. At the same time those women who earn their livelihood independently have the right to acquire citizenship if they are German subjects."
Citizenship status, under social contract theory, carries with it both rights and duties. In this sense, citizenship was described as "a bundle of rights -- primarily, political participation in the life of the community, the right to vote, and the right to receive certain protection from the community, as well as obligations." Citizenship is seen by most scholars as culture-specific, in the sense that the meaning of the term varies considerably from culture to culture, and over time. In China, for example, there is a cultural politics of citizenship which could be called "peopleship".
How citizenship is understood depends on the person making the determination. The relation of citizenship has never been fixed or static, but constantly changes within each society. While citizenship has varied considerably throughout history, and within societies over time, there are some common elements but they vary considerably as well. As a bond, citizenship extends beyond basic kinship ties to unite people of different genetic backgrounds. It usually signifies membership in a political body. It is often based on, or was a result of, some form of military service or expectation of future service. It usually involves some form of political participation, but this can vary from token acts to active service in government.
Citizenship is a status in society. It is an ideal state as well. It generally describes a person with legal rights within a given political order. It almost always has an element of exclusion, meaning that some people are not citizens, and that this distinction can sometimes be very important, or not important, depending on a particular society. Citizenship as a concept is generally hard to isolate intellectually and compare with related political notions, since it relates to many other aspects of society such as the family, military service, the individual, freedom, religion, ideas of right and wrong, ethnicity, and patterns for how a person should behave in society. When there are many different groups within a nation, citizenship may be the only real bond which unites everybody as equals without discrimination—it is a "broad bond" linking "a person with the state" and gives people a universal identity as a legal member of a specific nation.
Modern citizenship has often been looked at as two competing underlying ideas:
Scholars suggest that the concept of citizenship contains many unresolved issues, sometimes called tensions, existing within the relation, that continue to reflect uncertainty about what citizenship is supposed to mean. Some unresolved issues regarding citizenship include questions about what is the proper balance between duties and rights. Another is a question about what is the proper balance between political citizenship versus social citizenship. Some thinkers see benefits with people being absent from public affairs, since too much participation such as revolution can be destructive, yet too little participation such as total apathy can be problematic as well. Citizenship can be seen as a special elite status, and it can also be seen as a democratizing force and something that everybody has; the concept can include both senses. According to sociologist Arthur Stinchcombe, citizenship is based on the extent that a person can control one's own destiny within the group in the sense of being able to influence the government of the group.:p.150 One last distinction within citizenship is the so-called consent descent distinction, and this issue addresses whether citizenship is a fundamental matter determined by a person choosing to belong to a particular nation––by his or her consent––or is citizenship a matter of where a person was born––that is, by his or her descent.
Some intergovernmental organizations have extended the concept and terminology associated with citizenship to the international level, where it is applied to the totality of the citizens of their constituent countries combined. Citizenship at this level is a secondary concept, with rights deriving from national citizenship.
Citizenship of the Union is hereby established. Every person holding the nationality of a Member State shall be a citizen of the Union. Citizenship of the Union shall be additional to and not replace national citizenship.
An agreement known as the amended EC Treaty established certain minimal rights for European Union citizens. Article 12 of the amended EC Treaty guaranteed a general right of non-discrimination within the scope of the Treaty. Article 18 provided a limited right to free movement and residence in Member States other than that of which the European Union citizen is a national. Articles 18-21 and 225 provide certain political rights.
Union citizens have also extensive rights to move in order to exercise economic activity in any of the Member States which predate the introduction of Union citizenship.
The concept of "Commonwealth Citizenship" has been in place ever since the establishment of the Commonwealth of Nations. As with the EU, one holds Commonwealth citizenship only by being a citizen of a Commonwealth member state. This form of citizenship offers certain privileges within some Commonwealth countries:
Although Ireland was excluded from the Commonwealth in 1949 because it declared itself a republic, Ireland is generally treated as if it were still a member. Legislation often specifically provides for equal treatment between Commonwealth countries and Ireland and refers to "Commonwealth countries and Ireland". Ireland's citizens are not classified as foreign nationals in the United Kingdom.
Canada departed from the principle of nationality being defined in terms of allegiance in 1921. In 1935 the Irish Free State was the first to introduce its own citizenship. However, Irish citizens were still treated as subjects of the Crown, and they are still not regarded as foreign, even though Ireland is not a member of the Commonwealth. The Canadian Citizenship Act of 1947 provided for a distinct Canadian Citizenship, automatically conferred upon most individuals born in Canada, with some exceptions, and defined the conditions under which one could become a naturalized citizen. The concept of Commonwealth citizenship was introduced in 1948 in the British Nationality Act 1948. Other dominions adopted this principle such as New Zealand, by way of the British Nationality and New Zealand Citizenship Act of 1948.
Citizenship most usually relates to membership of the nation state, but the term can also apply at the subnational level. Subnational entities may impose requirements, of residency or otherwise, which permit citizens to participate in the political life of that entity, or to enjoy benefits provided by the government of that entity. But in such cases, those eligible are also sometimes seen as "citizens" of the relevant state, province, or region. An example of this is how the fundamental basis of Swiss citizenship is citizenship of an individual commune, from which follows citizenship of a canton and of the Confederation. Another example is Åland where the residents enjoy a special provincial citizenship within Finland, hembygdsrätt.
The United States has a federal system in which a person is a citizen of their specific state of residence, such as New Jersey or California, as well as a citizen of the United States. State constitutions may grant certain rights above and beyond what are granted under the United States Constitution and may impose their own obligations including the sovereign right of taxation and military service; each state maintains at least one military force subject to national militia transfer service, the state's national guard, and some states maintain a second military force not subject to nationalization.
"Active citizenship" is the philosophy that citizens should work towards the betterment of their community through economic participation, public, volunteer work, and other such efforts to improve life for all citizens. In this vein, citizenship education is taught in schools, as an academic subject in some countries. By the time children reach secondary education there is an emphasis on such unconventional subjects to be included in academic curriculum. While the diagram on citizenship to the right is rather facile and depth-less, it is simplified to explain the general model of citizenship that is taught to many secondary school pupils. The idea behind this model within education is to instill in young pupils that their actions (i.e. their vote) affect collective citizenship and thus in turn them.
It is taught in the Republic of Ireland as an exam subject for the Junior Certificate. It is known as Civic, Social and Political Education (CSPE). A new Leaving Certificate exam subject with the working title 'Politics & Society' is being developed by the National Council for Curriculum and Assessment (NCCA) and is expected to be introduced to the curriculum sometime after 2012.
Citizenship is offered as a General Certificate of Secondary Education (GCSE) course in many schools in the United Kingdom. As well as teaching knowledge about democracy, parliament, government, the justice system, human rights and the UK's relations with the wider world, students participate in active citizenship, often involving a social action or social enterprise in their local community.
There are two kinds of criticism of citizenship education in schools. Firstly, some philosophers of education argue that most governments and mainstream policies stimulate and advocate questionable approaches of citizenship education. These approaches aim to develop specific dispositions in students, dispositions conducive to political participation and solidarity. But there are radically different views on the nature of good citizenship and education should involve and develop autonomy and open-mindedness. Therefore, it requires a more critical approach than is possible when political participation and solidarity are conceived of as goals of education. Secondly, some educationalists argue that merely teaching children about the theory of citizenship is ineffective, unless schools themselves reflect democratic practices by giving children the opportunity to have a say in decision making. They suggest that schools are fundamentally undemocratic institutions, and that such a setting cannot instill in children the commitment and belief in democratic values that is necessary for citizenship education to have a proper impact. Some educationalists relate this criticism to John Dewey (see critical comments on this interpretation of Dewey: Van der Ploeg, 2016).
... The concept of 'citizenship' has long acquired the connotation of a bundle of rights... .
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