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162  Citizenship


                        sanguinis ). In practice, countries now have complicated criteria for grant-
                        ing citizenship, so that these ideal - types are not so clear cut. It is also
                        possible to achieve citizenship as an adult through naturalization. All
                        countries allow naturalization, though some encourage it, while others
                        actively discourage foreigners from applying for citizenship and decisions
                        are discretionary. In all cases, applicants have to prove their commitment
                        to the country of choice. As a minimum, this almost always involves
                        real or effective residence in the state ’ s territory ( jus domicili ) (Hammar,
                          1990 : 72 – 7).
                            New World states are often described as  “ countries of immigration ”
                        because a large proportion of citizens were born elsewhere or are descended
                        from people who came to the country relatively recently.  “ Countries of
                        immigration ”  typically grant citizenship to all babies born within the ter-
                        ritory of the state, as the US does, as well as to the children of citizens
                        born abroad, and they also have relatively easy procedures for naturaliza-
                        tion. Western European states all now contain large minorities from
                        elsewhere, but they differ in their attribution of citizenship according to
                        the model of the relation between nation and state they embody.
                        Colonialism has been an important factor in labor migration since many
                        people have come from ex - colonies to the over - developed metropolitan
                        centers. In the British case, those who arrived before 1962 from ex -
                        colonies had the full citizenship rights attributed to all those born on
                        British territory. Since then, however, British citizenship has moved closer
                        to  jus sanguinis  and it is now limited to those with a parent or grandpar-
                        ent born in the country  –  mostly whites. Immigrants who arrived after
                        the 1970s have a status closer to that of migrant workers in other European
                        countries: short - term contracts as workers and no long - term rights of
                        settlement. Citizenship in France, which has long been seen as exemplary
                        of civic nationalism in Europe, although still based on  jus soli , has also
                        become relatively more closed. Until recently, second - generation migrants
                        were all attributed French citizenship at birth and naturalization was
                        actively encouraged as a policy to assist assimilation and to increase the
                        French population. In recent years, however, rights of automatic citizen-
                        ship have been brought into question in relation to second - generation

                        Algerians, apparently because of the difficulty of assimilating Muslims
                        into a secular society (Oommen,  1997 : 165). In contrast, Germany has
                        been taken as exemplary of an ethnic nation and citizenship has been
                        traditionally based on  jus sanguinis : traditionally, it is blood rather than
                        the law that makes the German nation. This led to the anomalous situa-
                        tion in which Eastern Europeans of German descent were legally citizens
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