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Citizenship 149

demonstrate how existing citizenship, far from affording rights to indi-
viduals as such, depends on the position people occupy in relation to the
nuclear family.

The women ’ s movement

The most important point of the recent feminist critique of liberal citizen-
ship is that, developed from a male perspective, it has institutionalized a
male norm. Contemporary feminists see women as incorporated into
liberal democracy in a paradoxical and unjust way. As a result, they are
continually faced with what is known as “ the sameness – difference ”
dilemma. Should the women ’ s movement focus on rights for women to

be treated the same as men or on gender - specific rights, enabling women ’ s
differences from men to be valued and taken into account as the means
of gaining genuine equality between the sexes?
As it is, there are three, quite contradictory ways in which women are
excluded from full citizenship rights. First, women are discriminated
against when they should have the same rights as men. Second, on the
other hand, they are treated the same as men when only differential treat-
ment would make genuine equality possible. In such cases, physical and
historical differences are ignored which prevent women from actually
participating in institutions and practices developed to suit men, even
though they have the formal rights to do so. Third, however, some citi-
zenship rights, notably social rights, are accorded differently to women
and men and, in such cases, women are treated as inferior citizens. As
feminists see it, the paradoxes and inconsistencies of women ’ s citizenship
are linked to the way in which they have developed secondarily to men ’ s.
Historically, until very recently, citizens have been male heads of house-
holds and women ’ s citizenship has developed within the framework set
by rights developed on this basis.
The first and second cases are exemplified by civil rights. In the past,

feminists have put a good deal of energy into campaigns for equal rights
for women to be treated as identical to men, to remove the barriers to
women ’ s participation in public life, and to try to ensure their protection
in the private sphere. In the US in particular, many feminists continue to
see equal rights as the most important aim of the women ’ s movement. An
example is maternity rights. Until the 1960s, many American employers
had rules which compelled a pregnant woman to leave her job at a set
time and forbidding her to return to work before a certain date. Maternity
leave with pay was not provided and the right to return to work was not
guaranteed. The initial impetus of feminist campaigns was to overturn