Topic 3: Secularism in Comparative Perspective—The Hijab as Case Study in Three Countries


This lesson explores the issue of hijab, or the wearing of modest dress by Muslim women as a civic and religious matter, and uses three newspaper articles to compare policies and approaches to integrating Muslim women who wear the hijab into society. These articles help students to analyze the different approaches to secularism, and to assess which approaches are more democratic, and which represent the least government intervention in individual religious liberties. Other issues include the concept of accommodating religious practices as a burden on the state, and give the students the opportunity to evaluate the relative burden on the state of women’s wearing a head covering in each case. The lesson materials include a brief background piece on hijab in Islam.


The student will be able to:

    1. explain why Muslim women wear modest dress based on Islamic beliefs
    2. describe the general characteristics of Muslim hijab, or public mode of dress for women
    3. analyze approaches and policies described in three newspaper articles relating to hijab-wearing Muslim women in Turkey, France, and the United States (Michigan)
    4. discuss the content of the First Amendment to the U.S. Constitution (Bill of Rights) as it applies to religious liberty issues such as wearing of hijab in public.
    5. Procedure:

      1. As a class, read the historical essay on hijab in Handout 1. Address any comprehension issues in the explanation of Muslim women’s dress in the essay. Locate the countries mentioned on a map, and place the article in historical context in terms of world and US history concerning women’s dress and roles in society. Invite the class to discuss the questions that appear in the final paragraph of the essay, or assign a paragraph on one or more, or a 5-paragraph essay to discuss them as a whole.
      2. Distribute Handouts 2a, 2b, and 2c, which contain three newspaper articles on the public implications of wearing headscarves or hijab in public situations and contacts with government offices and functions such as administration, education and politics. The group of articles may be assigned to advanced students, but to save time and wear on students, it is probably advisable to divide the class into thirds, assigning each to read and discuss one article
      3. De-brief each group on their work with the articles by asking (a) for one member of the group to provide a summary of the article and (b) answers to the questions at the end of each article.
      4. Analysis: Using the articles, discuss the meaning of secularism as it relates to government, law and policy toward members of minority and majority faiths. Should secularism mean exclusion of religious expression from public life, or should it mean non-interference by the government in religious affairs of citizens? How does secularism relate to democracy and to modernization? Using the final paragraph of Handout 1 as a framework for discussion, relate these issues to personal expression and matters of conscience such as religiously motivated clothing, and to the role of the state in regulating matters of religion, conformity, and conscience. What other religious groups in US society are affected by such concepts and policies?
    6. To help guide discussion on the issues of defining and understanding secularism and democracy, separation of church and state, or religion and government, the following is a quotation of the The First Amendment to the U.S. Constitution, the first item in the Bill of Rights: "Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances." For more information on the First Amendment and civil liberties, see the Freedom Forum and the First Amendment Center web site at


Bob Ray Sanders, "One Woman Who Stood Her Ground," Dallas Fort Worth Star Telegram, August 3, 2003

Elaine Sciolino, "Letter from Europe: France Envisions a Citizenry of Model Muslims," New York Times, May 7, 2003

Ron French, "Michigan Tries to Accommodate Muslim Women," The Detroit News, June 11, 2003

Handout 1: Hijab! What’s in a Square of Cloth and a Little More Skirt?


Muslim women have been covering much or little of their heads with a piece of cloth for more than fourteen hundred years. They have also worn long, loose, modest clothing styles in public – that is, when they might be seen by men who are not not members of their immediate family. The styles and colors of Muslim women’s dress vary from region to region. Some styles are based on costumes from the time before Islam spread to these places.

The obligation to act modestly i in public is not merely applied to women, but to men as well, and it is based on several verses of the Qur’an. These verses describe dress in very general terms, but explain very clearly the purpose of protecting modesty:

"Tell the believing men to lower their gaze and be modest. That is purer for them. Lo! Allah is Aware of what they do."

"And tell the believing women to lower their gaze and be modest, and to display of their adornment only that which appears, and to draw their veils over their bosoms, and not to reveal their adornment save to their own husbands or fathers or husbands' fathers, or their sons or their husbands' sons, or their brothers or their brothers' sons or sisters' sons, or their women, or their servants, … or children ... And let them not stamp their feet so as to reveal what they hide of their adornment. And turn unto Allah together, O believers, in order that ye may succeed." (24:30-31)


"O Prophet! Tell thy wives and thy daughters and the women of the believers to draw their outer garments around them (when they go out in public). That will be better, that so they may be recognized and not annoyed. Allah is ever Forgiving, Merciful." (33:59)

The precedent of the early Muslim community was followed by later generations. Early Muslim women enjoyed freedom of movement in simple, modest dress, much like the example of working orders of Christian monks and nuns. As Islam spread to the wealthy cities of Africa and Asia, Muslim men’s and women’s dress was influenced by a rich offering of luxury fabrics. It was also influenced by the secluded urban lifestyles of wealthy upper class women of Byzantine and Persian society. Clothing became more restrictive of movement, and included many layers and elaborate face veils. Middle classes copied the rich as best they could, and women in who worked in fields, crafts and markets never covered as deeply as rich upper class women who had no need to work. In this way, the isolating qualities of dress became symbols of wealth and privelege, concepts not exactly aligned with modesty and humbleness.

The pattern of Muslim women’s dress was not challenged until the twentieth century. Then it was influenced by imperial attitudes about civilization vs. backwardness. It should be remembered, however, that European women were also rebelling against restrictive female dress in their own culture. Cinched waists with whalebone corsets, plunging necklines or choker collars, high-button, high heeled shoes, skirts made of yards of fabric, layers of petticoats, ribbons, ruffles and lace. By the end of World War I, European women and their colonized sisters had both begun to modify traditional ideas of what to wear.

European imperial powers were weakening, but they still occupied many Muslim countries. Newly independent Muslim rulers like Kamal Ataturk and the Shah of Iran tried to abolish traditional Muslim clothing, which they thought was necessary to modernize their countries. Why women’s appearance would be equated with building factories is a curious question, but the issue was raised to quite a level by the political actions surrounding the veil. Muslim women in Egypt, India, Algeria and Syria struggled against the double burden of colonialism and rigid customs against women’s education, and some of these women removed their veils and wore western dress. Reforming Muslim jurists wrote that it was Islamically appropriate to educate women, to let them participate in political, social and economic life, but they did not argue against the veil or modest dress.

In the course of the twentieth century, Muslim women’s dress, and particularly the symbolic headscarf, has become a lightning rod social issue. The hijab has become a subject of journalism and academic study boasting hundreds of books and articles. Muslim men and women have written countless books, articles and speeches on the pros and cons of women covering their heads and bodies. Some national leaders have insisted on removing women’s scarves with the help of police; others enforced its use with the help of police. In the Soviet Union and the Eastern Bloc, communist ideology railed against tradition and religion, and made conformity a patriotic virtue. Unless women of numerous religions could disguise religious dress in ethnic costume, it often vanished from public view.

Other Muslim societies, such as Egypt, Malaysia, Morocco and Indonesia (sometimes Turkey) have allowed women to choose according to their beliefs and conscience. As a result, a street scene in those places shows a wide range of options. In countries offering free choice, women have passed through several phases in which the majority of modernizing, educated women cast off and then returned to wearing modest Muslim dress. Rural women, watching their fashionable urban sisters, and often their modern, educated daughters, have followed their lead in wearing hijab. Muslim women living in the west have found that wearing hijab makes them immediately recognizable as practicing Muslims, even while Muslim men are usually camoflaged by their ordinary street clothes. And if a woman wears the face veil in western countries, it brings on stares, sometimes confrontations, and always curiosity.

Other transformations have taken place in Muslim women’s dress during the twentieth century. Muslim women a century or two ago – like their western sisters in Europe and the US – wore wide garments with lots of fabric and often loose, flowing shapes. The Iranian chador, the Afghan burqa, and the Sudanese and Indian sari are examples. In contrast, rural women had often worn simpler, closer-fitting but modest clothing – especially pants. It might surprise many westerners to know that it was the influence of Muslim dress that got women out of petticoats and into pants in civilized society. Indigo-dyed denim, cotton muslin and khaki are just a few of the fabrics that made their way across the Muslim lands to Europe and on to America. The demands of industrial urban life also played a role, of course, and the settlement of the western part of the US played a role in casual women’s clothing. Muslim women who chose to wear the hijab began to chose more tailored clothes, such as a trenchcoat-type outer garment traditionally called a jilbab, and instead of elaborate veils or headwraps, many chose to fold a simple square of silk fabric into a triangle and pin or tie it at the chin. Modern Muslim women, in other words, have been shopping the stores and catalogs of the global garment industry, choosing pieces suited to their styles and lives, and they have also been contributing their own styles to the global clothes closet, like sarongs, batiks, tie-dye, madras plaids, crepe, and colorful African designs. It is a two-way street.

It is worth thinking about why Muslim women’s dress – and perhaps women’s dress everywhere – is such a lightning rod issue. Banning the headscarf in French schools and Turkish universities, requiring it in Iran and Saudi Arabia, making legal cases out of it in Germany, the US and Canada when its use has been challenged by officials—all of these are interesting examples of individual conscience issues. They point up problems with the definition of secular government and democratic systems. They highlight issues of social conformity, minority or majority rule, and religious freedom. They beg an answer to the question: is women’s dress a symbol of oppression or liberation? What difference does a piece of cloth make? It can make a political firestorm, or an invitation to tolerance and mutual respect.

Handout 2a: Article #1

One woman who stood her ground

By Bob Ray Sanders
Star-Telegram Staff Writer

August 03, 2003 -- While many people in this country want to tear down the wall that rightfully separates state and religion, there is at least one nation in the world where that wall is almost impenetrable.

In Turkey, a nation that is 95 percent Muslim, the secular government established more than 75 years ago wants no infiltration of religion in its parliament, public universities or courtrooms.

Merve Kavakci, who was elected to the Turkish parliament in 1999, is living proof of that.

She was never allowed to take the oath of office or take her seat in the 550-member legislative body.

You see, she refused to remove the head scarf that many Muslim women are required to wear. She saw her headdress as her democratic right, while Turkish leaders saw it as a religious statement and an affront to the secular government.

She was called extremist, subversive and radical fundamentalist -- all labels she denies.

Kavakci was in the Fort Worth-Dallas area last month visiting her father, Yusuf Kavakci, the imam -- religious leader -- of the Richardson-based Islamic Association of North Texas.

I talked with her about the election, her continuing fight and her political plans.

Kavakci, who now lives in Washington, D.C., said that not only was she denied entry into the parliament, the Speaker of the House ordered any information about her election erased from the official records.

"You won't see my picture or my name anywhere," she said. "Any documentation of my election has been removed and placed in the archives."

Although she is definitely outspoken, remarkably independent and obviously a fighter, this "conservative" politician didn't strike me as extreme or subversive.

Understandably, she is still angry about being barred from her swearing-in ceremony, as well as the fact that she has been banned from running for office again for five years. Her Virtue Party, she said, has also been banned for supporting her.

Kavakci was one of two women elected that year who wore scarves as a matter of tradition and religious teachings. The other woman did not wear her scarf to the swearing-in and was permitted to take her place in the parliament -- to the applause of the mostly male legislative body.

At the time she was elected, Kavakci was 30 years old and felt she was setting an example for young people, women and her religious beliefs. But, she said, she did not see wearing the scarf as a threat to her government.

"I did not feel compelled to compromise my values," she said. "If I compromised about wearing my scarf, I would be compromising my values."

Kavakci said it is her constituents -- the people who voted for her -- who are being cheated. No one was chosen to replace her for that term, she said.

She is continuing to fight, having filed a case against the government before the European Court of Human Rights in Strasbourg, France.

"To stand up for what you believe in is very important to the democratization of Turkey," she said.

She has no regrets about her actions, but she also admits: "As a mother and a woman, I have some hurt feelings.

"As a mother of two, it is difficult to find yourself in the spotlight and have to deal with all the biases."

Kavakci said she is planning to run for office again "as soon as I can -- as soon as a new administration removes the impediments."

And, she says, she is not in this fight just for herself.

"I'm just one person," she said. "There are thousands of women who are not permitted to universities or who can't enter libraries."

To me -- and I'm sure to many in this country -- the wearing of a head scarf sounds like a minor thing to cause so much controversy. Yet people in Turkey are constantly reminded by other nearby countries just how repressive governments can be when religion has a stranglehold on them.

Still, I find Kavakci's fight an honorable one, the kind that helps keep democracies strong and, in some cases, helps them change.

By the way, Kavakci will return to North Texas later this month to speak to the Association of Muslim Social Scientists at the University of Texas at Arlington.

Bob Ray Sanders

© 2003 Star Telegram and wire service sources. All Rights Reserved.


Study questions:

  1. What percentage of the population of Turkey is Muslim?
  2. Why does Merva Kavacki wear a headscarf?
  3. What does the author give as the reason for the Turkish government’s refusal to allow Muslim women to wear the headscarf in government-owned public places?
  4. What were the consequences of Ms. Kavacki refusing to take off her headscarf in Parliament?
  5. Why does Merva Kavacki feel that it is important not to give up the fight against these consequences?
  6. Do you think that the Turkish government has struck a proper and just balance between freedom of religion and secularism?
  7. Why do you think that the Turkish government has taken such a harsh stand against the scarf? Do you think this stand is justified?

Handout 2b: Article #2


France Envisions a Citizenry of Model Muslims


PARIS, May 6, 2003 — The French interior minister, Nicolas Sarkozy, was booed and whistled at when he said at the annual conference of one of this country's most important Muslim groups last month that Muslim women would have to go bareheaded when posing for pictures for their identity cards.

He did not seem to notice — or perhaps chose to ignore — that a vast majority of the women in the audience were wearing head scarves. A few of them had even swathed their faces in black and hidden their hands under black gloves.

And perhaps the law-and-order interior minister can be forgiven for overlooking the shopping bags on sale at a score of kiosks, the ones with the silhouette of a woman wearing a veil and the phrase "I love my veil" in English and Arabic.

In a largely secular continent still trying to come to grips with Islam, France, with its large Muslim population and long colonial history with Algeria, is something of a bellwether. But even here, it is unclear how — or even whether — the tensions between secularism and Muslim piety will be resolved.

In a sense, France's center-right government is trying to create a model Muslim citizenry. President Jacques Chirac has spoken about his vision of a "tolerant" Islam. Mr. Sarkozy said recently, "There is no room for fundamentalism at the Republic's table."

For them, model Muslims would be French-speaking and law-abiding. They would celebrate the 1905 French law that requires total separation between church and state. They would attend mosques presided over by clerics who are French-trained and avoid politics in their sermons.

Model Muslim women would not try to wear head scarves in the workplace; model Muslim girls would not try to wear head scarves to school. Most important, model Muslims would call themselves French first and Muslim second.

The thinking goes something like this: Muslims must be integrated into French society to avoid a culture clash that could contribute to terrorism. So the French government has embarked on a two-pronged strategy that will give Muslims what French leaders call "a place at the table," but monitor and regulate their activities at the same time.

This strategy lay behind Mr. Sarkozy's campaign to put together an official Islamic council led by a "moderate," suit-and-tie-wearing mosque rector to interact with the French state. It also underlies Mr. Sarkozy's belief that the only way France can stop radical foreign clerics from preaching on French soil is to create a home-grown variety that identifies more with French culture and tradition. It is the reason French intelligence has assigned operatives to monitor sermons in mosques and prayer centers every Friday.

The idea of the French state regulating a religious community is rooted in Napoleon's bold concordat concluded with the papacy in 1802. While the concordat recognized Catholicism as the "preferred religion" of France, it also forced the pope to accept nationalization of church property in France, gave the state the right to appoint bishops, police all public worship and make the clergy "moral prefects" of the state.

A few years later, the French state sought to transform the Jewish population into better French citizens by controlling their behavior, going so far as to propose briefly that every two marriages between Jews be matched by a marriage between a Jew and a non-Jew.

But in an era in which the French state enjoys less and less direct control over its citizenry, transforming a Muslim population into an ideal citizenry may be too much of a stretch.

"It is very difficult to say it openly but this is a very troubling situation, a crossroads," said Pierre Birnbaum, professor of politics and philosophy at the Sorbonne and author of "The Idea of France."

"The state, which is no longer the center of the nation, may not be in a position to rule on religion from above," he said. "It may not have the power to integrate."

France is home to about five million Muslims, about 7 percent of the population. But that figure is hopelessly unreliable because under French law, people are not officially counted, polled or classified according to religion.

Officials say they do not know whether there are any Muslims among France's 577 members of the National Assembly, although a Muslim cultural organization affiliated with the Paris Mosque says there are none. There are no Muslim ministers, although there are two Muslim state secretaries, one for long-term development, another for veterans affairs.

The driving force behind France's campaign to make its Muslim citizens more French is to curb political radicalism and terrorism, both inside and outside the country. The problem is that mainstreaming Muslims into European society does not necessarily translate into an embrace of European ideals…

So even as France struggles to "integrate," as French officials call it, its Muslim population, the nightmare is that the strategy may fail. Radicalism and terrorism sometimes may have less to do with religion and more to do with an overwhelming sense of alienation and rage linked to economic and political realities, like discrimination, joblessness and the open-ended war between Israel and the Palestinians.

Handout 2c: Article #3

Michigan tries to accommodate Muslim women

Fla. ruling to ban face veil for driver's license picture poses little controversy in Metro area

Huda Sarah Mahmud, 16, of Dearborn wears a hijab, required by her religion when in public. Michigan allows the headdress for driver's license photographs, but not a face veil or niqab.


By Ron French / The Detroit News

DEARBORN, June 11, 2003 -- Customers at Secretary of State branches in Dearborn routinely are asked to move across the office, to provide privacy to Muslim women being photographed without their face veils. Women who by tradition cover their faces in public routinely take those veils off to be photographed for driver's licenses. Other Muslim women, who wear veils covering their hair, are allowed to keep their headdresses on for driver's license photos.

It's a compromise between the state and the city's large Muslim population that has worked for years, a rare accommodation of bureaucracy and religion in a world where the two often lock horns. A highly publicized court case in Florida ended Friday, with a judge ruling that a 35-year-old mother of two must remove her niqab, a veil covering most of her face, for a photograph if she wants a driver's license. The ruling caused little stir in the city with America's largest concentration of Arab Americans. Some in Florida saw the ruling as religious persecution. Malka Gellani in Dearborn sees common sense.

"Anyone could hide under those veils," said Gellani, 39, who wears the more common hajib, which covers her hair.

In Florida, Muslim women used to be allowed to have driver's license photographs with veils covering their faces. That changed after Sept. 11. Sultaana Freeman's license was revoked in January 2002, when she refused to have a new photograph taken that revealed her face.

In the ruling, Florida Circuit Judge Janet Thorpe said that while Freeman "most likely poses no threat to national security," others could hide identities behind the veils. Michigan hasn't faced a similar controversy because it has always required faces to be revealed, and long ago worked out compromises with the Arab community. The policy of the Secretary of State's office is for customers to remove all head coverings for driver's license photographs. Men are routinely asked to remove caps, for example. But Muslim women are allowed to wear their hajibs, which are required by their religion to be worn in public.

"If they asked me to take off my scarf, I would be angry. I'd make a scene," said Huda Mahmud, 16, of Dearborn. "My scarf is a part of me."

Mahmud does not wear a veil across her face, and says face veils are "more of a custom" than a religious requirement. Some of the teen's friends wear face veils, and they did not object to removing the veil to get a driver's license, Mahmud said. That may be because of the efforts taken by the Secretary of State to be sensitive to the group's religious views.

Janice Trimm, support manager for Secretary of State branches in the area, said women wearing face veils is "a daily occurence" in the Dearborn office. Women who call ahead can arrange to have a woman employee take their photograph at the office when the office is closed.

"They come in early or late, if they're really opposed to people seeing them," said Trimm. Those who come during regular hours can count on having other customers moved away from the camera area, so their faces aren't seen.

"We do our best to accommodate you," said Kelly Chesney, spokeswoman for Secretary of State Terri Lynn Land.

Zana Macki doesn't think it's enough. "That's a nice little gesture, but at the same time your face is still exposed on your driver's license," said Macki, executive director of the Council on Arab American and Islamic Relations. "What happens when you go to cash a check or show your ID? Are you going to have to take off your veil to show that it's you? The judge didn't understand ... it's a modesty issue. It's between her and God.

"We say women can drive now in Afghanistan. But here, we're putting up barriers," Macki said. It seems like an insignificant barrier to Gellani, when there are so many larger civil rights issues to be concerned about. "I think she can take it off (for a photograph) and still keep her privacy," Gellani said. "If she's stopped by police (and they want to confirm her identity), she can request a female officer." <>