As the increased threat of terrorism fuels the debate over the concept of 'citizenship' and its role in society, Adrian Mourby ponders whether a person can become 'British'.

The government's tentative steps towards creating a nation of citizens, rather than subjects, received a significant boost after the events of September 11 when the age-old fear of an enemy within resurfaced and the home secretary addressed himself to the idea of giving everyone resident in Britain a greater stake in being British. But, as a number of academics have pointed out, before we can create a nation of model citizens we first have to clarify what citizenship might be.

Simon Blackburn, professor of philosophy at Cambridge, says citizenship implies the subjugation of individuals to the laws of the state but also confers specific rights, including traditional liberal concepts such as the freedom of association and freedom of speech, "particularly in political matters". It also embraces "freedom of economic activity, subject to deductions necessary to keep the apparatus of the state functioning, the right to sufficient education to enable the citizen to function as a member of participatory democracy, various equality rights, and so on".

In Blackburn's view, citizenship is not just a matter of residing within a specific territory. "Such residence may be enough to render a person liable to the legal powers of the state but not, for instance, enough to determine a right to vote or give rights to welfare. Birth within an area, or parental birth, or free choice, subject to various undertakings, may also be necessary in order to participate in the democratic process," he says.

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That third category - individuals who choose to become members of a particular state - is what is so exercising politicians at the moment. To what extent can a would-be citizen write his or her own contract with the state? Alternatively, if the state is to define what it expects of a would-be citizen, as David Blunkett would wish, what can it reasonably prescribe for newcomers?

Two countries that have admitted few qualms over either defining and testing for citizenship are Canada and the United States. The US, particularly, imposes a strict definition of citizenship.

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Gargi Bhattacharyya, lecturer in cultural politics and religion at Birmingham University, takes the view that "belonging" can neither be defined nor taught. But she recognises the rationale behind what happens in America.

"The American system works because anyone can become American. One cannot become British. America has a different framework."

Even so Bhattacharyya makes the distinction between a living national culture and the criteria used for testing citizenship. In the US, for example, the emphasis is on knowledge of the political system. "Lived reality doesn't necessarily relate closely to constitutional politics," she says.

Sandford Levinson, professor of law at Texas University, is sceptical of the criteria employed by the US Immigration and Naturalisation Service. "It is hard to believe that a 'civics book' test can have much to do with ascertaining citizenship if by that term we mean some sense of deep identification and loyalty. One of the things that interests me is that birthright citizens are not required to display any particular knowledge about American history or institutions, how many senators and representatives there are, how long their terms are, the three branches of government. The assumption, presumably, is that children pick it up through civics courses in their schools. This is probably true for most children, but there is, so far as I know, no requirement that, for example, home-schooled children display such knowledge. So in this sense, more is asked of immigrants than of the indigenous population."

Levinson claims to see no harm in teaching a rudimentary knowledge of the political system to all citizens. "It could, conceivably, do a modicum of good. But ultimately, serious citizenship is a mindset not a test, and it is hard to see how one teaches that."

But those countries that have initiated citizenship tests more recently have ended up modifying rather than rejecting the American model. Donald Galloway, professor of law at the Canadian University of Victoria, believes such a test enforces a useful myth about the existence of a social contract.

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Canada's citizenship test, based on information contained in a booklet supplied by the government, focuses mainly on the system of governance and the legal system, but the constitutional rights and freedoms of citizens are also outlined. "It thereby stresses that one of the important dimensions of citizenship is the relationship between the government and the citizen," Galloway says. "If you like, the myth of a contract is being propagated and the prospective citizen is being tested on his or her knowledge of its terms." The responsibilities of citizenship emphasised, he says, "range from the ingenuous - throwing garbage in garbage containers - to the overwhelming - helping eliminate discrimination and injustice".

The booklet also stresses the diversity of Canadian society, although inevitably it has to simplify. "The politics of multiculturalism is reduced to the need to respect difference and everyone is encouraged to develop the Canadian virtues of lawfulness, peacefulness and tolerance. While the booklet looks like it might come from an 11-year-old's social studies class and has a hokey quality to it, the government's message deserves commendation for attempting to draw out general structural values while not imposing uniformity as a social virtue. It also remains quite low-key as far as patriotism goes while simultaneously attempting to engender the feeling that the status of citizenship is something of which one can be proud."

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But many academics disagree with the whole concept of moulding immigrants to fit a pre-existing national concept. Heidi Safia Mirza, professor of racial equality studies at Middlesex University, believes strongly that classical notions of citizenship require rethinking.

"Given the context of globalisation, of diversity and changing national identities, 'citizenship tests' that rely on a concept of a 'common public culture' will be too narrow to embrace the diverse ways in which belonging to a community or social group are now expressed," she says, citing how many black and ethnic minority women in Britain have challenged a system that marginalises them by setting up black supplementary schools for their children.

Mirza says that such radical action - what she calls "acts of 'real'

citizenship" that attempt to positively transform the women's lives and those of their children, will not be seen as acts of civic responsibility. "They will go unrecognised in comparison with tests based on national anthems, historical trivia and the Queen's English," she says.

Bhattacharyya agrees. "I do not see the need for a test of citizenship. Rather there is a need in this country to revisit the terms of political engagement between all communities and the state and to take time to look at ways people in this country are not engaged with the state."

Bhattacharyya believes that any lack of social cohesion in Britain should be tackled by redressing social injustice rather than by providing those in need with lessons in good citizenship. "It is about creating new kinds of public fora, in addition to elected representation," she says.

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"This idea of defining what it is to feel British is ducking the issues. Blunkett is playing to the soft racist vote. You can only educate people if you engage with other aspects of life as well. Citizenship cannot be taught in isolation. It is something that affects majority communities and minority communities equally, but the minority communities are the ones who don't feel that Britain hears them. They need first to be recognised. Belonging is multifaceted and cannot be taught - even if we all agreed on what citizenship was."