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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

