Developing a framework for a global comparative analysis of the governance of religious diversity

ABSTRACT

Between and within different world regions today religious diversity remains a significant challenge and researchers have identified a wide variety of church-state relations as well as of legal, institutional, and political arrangements related to state-religion connections. These variations in type and degree owe something to distinctive political, institutional, theological, and historical inheritances and have led to different normative conceptions of secularism and of state-religion relations and connections. This first contribution begins by mapping the ground of existing conceptions of secularism and state-religion connections. Our discussion first assesses normative approaches that emanate from ‘the West’ as well as from perspectives outside of ‘the West’ (such as India), and which might directly challenge the former. It then turns to outline a new framework of five modes of governance of religious diversity, presenting each in relation to a series of constitutive features or norms that characterise it and which distinguish it from other modes. This typology of modes forms the basis of the intra- and inter-regional comparative analyses presented in the regionally focused contributions to this collection. We finally provide an overview of these contributions and their application of the typology.

KEYWORDS:

• Secularism
• religious diversity
• freedom of religion
• state-religion connections

Introduction

Debates and controversies around the governance of religious diversity have become, and in fact have long been, important features of the social and political landscape in different regions and countries across the world. The contemporary circumstances provoking these debates, and the significant aspects of historical legacies and how these influence and shape present-day conditions vary between contexts, and accordingly there have been a range of state as well as scholarly responses to how, and why, particular understandings and arrangements of state-religion relations should be preferred.

This collection presents a framework for a global comparative analysis of the governance of religious diversity developed as part of the Horizon 2020-funded GREASE project. The analyses presented throughout the contributions to this collection are based on extensive review of secondary literature, of legal and policy landscapes, and in some cases on interviews, in each country case. Our use of governance here, as will become apparent throughout the contributions to this collection, includes legal and policy measures as well as connections and cooperation between state and civil society actors. The contributions apply this framework to present comparative analyses of different modes of the governance of religious diversity and state-religion connections and relations covering 23 countries in five world regions: Western Europe, Southern and Southeastern Europe, Central and Eastern Europe, the MENA region, South and Southeast Asia and, finally, Australia (which we here analyse with Western Europe, with which it shares many key characteristics). While any form of clustering of this kind will have its drawbacks, and the choice of these regional clusters has a geographical and presentational function, the groupings also have a certain analytical purchase. There is, we suggest, sufficient commonality between the country cases to warrant their grouping, though we will also note that each regional cluster has a notable exception. Following the focused discussions based on regional comparative cases, the final contribution to this collection reflects on these points further as part of an inter-regional comparative analysis.

This first contribution to the collection begins by mapping the ground of existing conceptions of secularism and state-religion connections. Our discussion first assesses normative approaches that emanate from Europe, especially Western Europe, before turning to perspectives from outside of the West, and which might directly challenge them. It then turns to outline a new framework of five modes of governance of religious diversity, presenting each in relation to a series of constitutive features or norms. This typology of modes forms the basis of the intra-regional comparative analyses presented in the regionally focused contributions to the collection. We finally provide an overview of the contributions and their application of the typology.

New accommodationist responses

In Europe, especially Western Europe, decline in religious belief and in the importance of religion in society shows no sign of reversing. Many Europeans are happy to think of their countries and their continent as post-Christian. It is important to note here, though, the variation within Europe. Countries in Eastern and Southern Europe report higher degrees of religiosity and higher levels of importance for religion as a core part of national identity than do Western European countries (Pew Research 2018), while also exhibiting early stages of the secularisation that characterises Western Europe. Alongside this trend, it is clear that many European states are now highly exercised by the challenges posed by post-immigration ethno-religious diversity. Although issues in European regions relate to different religious traditions, questions that have been raised throughout Europe share a common reference to their Muslim minority populations, and often it is the new Muslim settlements of the last 50 years or so that are at the centre of it. For some the pivotal date is 9/11, but 1988–89 better marks its origins. This was the period of The Satanic Verses Affair in the UK and l’affaire du foulard in France (Modood 2012), which brought Muslims – and in many ways the issue of public religion, oriented around non-Christian religious minorities – to the foreground of public and political, and subsequently scholarly, debate. Occurring between 1989 and 1991 depending on the state, this also marks the beginning of the fall of communism in Europe and of Soviet-bloc state secularisms imposed from above. Since that collapse, in parts of Central and Eastern Europe states and resurgent dominant religions have grappled with both the ‘old’ religious diversity of historic communities and minorities alongside ‘new’ minorities from more recent immigration flows.

The rethinking of secularism in Europe, then, is largely due to the fact of newer, and especially non-Christian, religious diversity. In response, some have (re)asserted a strong or muscular secularism, a position prominent, for example, in some political discourse and among some neo-laïcité and New Atheist movements, while others have emphasised the Christian history and character of these countries that must be protected.

Liberal theorists have, by contrast, at least in part accepted critiques of secularist pre-eminence and that this pre-eminence is not merely a political ambition but built into the very concepts of liberalism (Rawls 1997; Habermas 2006). More recent liberal accounts of secularism have also sought to rethink liberalism’s ideas of neutrality and state-religion separation or connections. ‘Open secularism’ (Bouchard and Taylor 2008; Maclure and Taylor 2011) makes an important distinction. On the one hand are the ends of secularism (its ‘essential outcomes’, according to Bouchard and Taylor 2008, 21]), referring to the moral equality of persons, and freedom of conscience and religion. On the other hand are the means of secularism, referring to the separation of church and state and state neutrality in respect of religious and deep-seated secular convictions. It does so to argue that the latter pair might not be necessary for the realisation of the former pair.

In her important 2017 book, Cécile Laborde has allowed that some state-religion connections (SRCs) are compatible with liberalism. Yet, in arguing against SRCs, Laborde contends that these will inevitably lead to the alienation of minorities. For Laborde this entails two things: that governments express objective attitudes (2017, 135), and that this ‘objective social meaning is context-dependent but not individual-dependent; it turns on how a reasonable (and reasonably well-informed) member of a community would understand the actions of public officials who undertake to display material that has religious content’ (Laborde 2017, 85). The reference to the reasonable person being reasonably informed suggests that (s)he needs to take into account some empirical data, and presumably it would be reasonable that this should include the view of Muslims (and others) rather than an abstract ‘reasonable’ person (Modood and Thompson 2022).

Furthermore, Laborde’s position presumes that the negative status of minority religious identity is sustained by symbolic establishment and not, for example, by racialisation, cultural ‘othering’, or muscular forms of liberal secularism that would squeeze religion from the public sphere. If we look for empirical evidence of the alienation of Muslims in Britain as an example, it is the case that they do seem to feel excluded and alienated by certain aspects of British, and indeed European, society (Murad 2020). Yet there is no record of any criticism by a Muslim group against the establishment of the Church of England (on these points see Modood 2019; also Martin 2017). However, many Muslims complain that Britain is too unreligious and anti-religious, too hedonistic, too consumerist, too materialist, and so on (Murad 2020; something they share with many Christians). Muslims protest far more vigorously about secularist bans on modest female clothing than they do about ‘establishment’ or Christian privileges. When Prime Minister David Cameron, during the 2011 Christmas season, said that it should be asserted that Britain is ‘a Christian country’ (BBC 2015) – the first time a British prime minister had spoken like that in a long time – it was welcomed by Ibrahim Mogra, then the chairman of the Mosque Committee of the Muslim Council of Britain, and later its assistant secretary general.¹ These matters do not support the mistaken view that Islamophobia is not an issue in Britain, or that Muslims do not feel alienated in Britain, but highlight that religious minorities such as Muslims are more likely to be alienated by the kind of secular state that Laborde argues for, and that their concerns make very little reference to Christianity, let alone the establishment of the Church of England.

So, we should not assume that state recognition of one or some religions is the only potential source of alienation on this matter; strict state-religion separation can also alienate or aggrieve those whose religious identity is especially important, and subjectively and objectively diminish their civic standing. Indeed, that calls for disestablishment come overwhelmingly from secularists rather than from minority faith groups is telling, as is that some Christians can also feel alienated from the secular state.

Notable in these liberal accounts is that, in order to ensure and protect the liberty of sovereign individuals within a state struggling to be neutral, equality is principally conceived to mean equality of individuals. In contrast to these liberal positions, Modood (2019) has argued that a rethinking of liberalism is necessary to ensure equality and recognition not just of individuals but also of ethno-religious groups, and his arguments in relation to moderate secularism emphasise the public good of religion and SRCs (Modood 2017). As a matter of fact, models that argue for church-state separation do not approximate particularly closely to church-state relations among Western European countries beyond France, and a variety of patterns of legal-constitutional and non-legal constitutional regulation and relations can be found. It is forms of connection between state and religions that emphasise the public good of religion, such as institutional connections in areas such as welfare provision and education for instance, that constitute the ‘moderate’ of this form of secularism in contrast to those which emphasise stricter forms of separation or state interference. Moreover, despite institutional connections between state and religion, one could only dispute that Western European states such as the UK, Germany, Belgium, and Denmark are secular if one had some narrow, abstract model of secularism that one insisted on applying to the varieties of empirical cases.

From this it is clear that we are already talking about multiple secularisms, but this gains extra traction when we look outside of the West, and some thinkers situated in non-western contexts have also entered these Anglophone debates in both commenting on secularism in Europe as well as furthering the debates through considering non-western forms of secularism and SRCs.

Deep diversity: non-European responses

Outside of Europe, in quite different historical and contemporary contexts, states have also faced questions of the governance of religious diversity. In the MENA region, debates between secularists and Islamists over the relationship between religion and state, law and politics again resurfaced with the Arab Spring, and Turkey under Erdoğan has seen a renewed centrality for religion in the political sphere. In South and Southeast Asia also, questions over the secular or religious character of the state and of relations between majority and minority religions have loomed large in several countries since gaining independence from European colonial powers in the mid-twentieth century.

With the re-emergence of debates over secularism in Western Europe, from the 1990s political theorists from outside the West or originating in the South began to make prominent contributions to political thinking and theorising on debates about secularism, many bringing an alternative perspective to western debates and issues. These contributions themselves were provoked by both issues arising in the West as well as in the country or region of the writer. This can be seen in the work of Talal Asad, whose genealogical interest was as much in the colonial secularism of Egypt as with how countries like Britain and France were managing their new Muslim populations (Asad 1993, 2003). Bhargava (1998) was one of the first to spark these normative debates. His intervention was provoked by considerations and debates in India, notably the Shah Bano case in 1985 and the demolition of Babri Masjid in Ayodha in 1992 (marked in India as major blows to its state secularism). But he also addressed the perceived ‘crisis’ of secularism in the West and highlighted its supposed lack of capacity to accommodate extra-Christian religious diversity (see also Mahajan 2007), and this idea of a crisis of secularism in the West underpins his contributions to Anglophone debates.

The West, Bhargava insists, is better served by looking sideways to India in order to view secularism’s future than by looking at its own past (2009, 2014, 2015). It is along these lines that Bhargava seeks to rehabilitate secularism drawing on the Indian experience. Bhargava’s (2009) model of secularism is based on his conception of ‘principled distance’ and is comprised of three characteristics: 1) a disconnection between state and religion at the levels of ends and institutions such that the relationship is guided by shared motives and values (he names the French tripartite liberty, fraternity, and equality), but not the same disconnection at the level of law and policy; 2) a differentiated citizenship; and 3) state interference in religion (where it may actively support or be hostile to different aspects of religion).

In contrast to both those who would seek an alternative to secularism (Madan 1998; Nandy 1998; Bader 2007) as well as those who would universalise a particular model and understanding of secularism, Bhargava seeks a form of contextual secularism, both in the sense of varying from place to place as well as in forms of moral reasoning (2009, 106). He notes, for example, that western conceptions of political secularism ‘do not appear to have travelled all that well in other societies’ (2013, 71). A problem here, however, is that Bhargava argues for a contextual approach, but simultaneously asserts the travelability of the Indian model.

An alternative position is that described by Gurpreet Mahajan, also with reference to the case of India and its ‘long history of living with religious differences and the absence of a homogeneous public sphere’ (2017, 80). Mahajan argues that a moderate form of secularism (as that in most of Western Europe) is certainly preferable to the US or French models, at least as an ‘enabling condition’ (Mahajan 2017, 85). Yet for Mahajan, moderate secularism is not sufficient for accommodating and valuing religious and cultural diversity if it does not embrace the idea that the state assist (often by making necessary arrangements for) the collective observance of religious practices for all communities, including the majority.

Subsequently, Mahajan argues that 'while [western secular states] help to secure freedom of belief and conscience for all, their attitude towards religious practices is, at best, ambiguous […] they consider them to be like any other lifestyle preference or set of freely chosen beliefs, ignoring that religious observances are closely tied to a person’s sense of dignity and respect, a constitutive element of their very self, and hence [experienced as] something more than [merely] an infringement of one’s basic freedom [of ‘choice’]' (Mahajan 2017, 76–77, emphasis added). In India, by contrast, differentiated legal and policy outcomes for different religious groups and their individual members mean that rather than individual freedom liberating the individual from the group, ‘individuals enjoyed the liberty to live in accordance with the customs and practices of their community. In fact, the state was expected to ensure that facilities necessary for the exercise of this liberty were provided’ (Mahajan 2007, 331). This emphasis, therefore, falls much more on group-related rights and freedoms.

These normative analyses of the distinctive nature of the Indian case can be considered not necessarily as exemplary but as illustrative of the issues involved once religious diversity rather than individual freedom sets the challenge for political secularism. Stepan’s (2011) pioneering work points to a set of multiple secularisms of alternative arrangements and pictures of secularism owing to different historical and demographic contexts, including legacies of European colonialism. The one which interests us here is the ‘Respect All, Positive Cooperation, Principled Distance’ model, which he outlines from the contextual cases of Indonesia, Senegal, and India and their responses of ‘innovative formulas of accommodation’ (Stepan 2011, 140) to the circumstances and challenges of governing newly independent and religiously heterogenous states.

As with moderately secular countries, Stepan’s ‘Respect All, Positive Cooperation, Principled Distance’ model is based on ‘mutual autonomy’, yet, as with Mahajan, it contrasts with moderate secularism in important ways in that it represents a more pronounced form of religion and religious diversity occupying a more emphasised position in the public sphere. Three features distinguish the model. The first is respect for minority and majority religions in the public sphere, through official recognition of multiple religions which the state positively supports and protects in the public sphere, which contrasts with the patterns of majority privilege found in moderately secular Europe. The second feature, positive cooperation, denotes not just positive accommodation, but forms of policy cooperation (Stepan 2011, 131). This promotes the multivocality of religions, which in turn provides scope for religious reasons and religious arguments in public debates. This contrasts with the absence of religious language and reasoning in political debate in European contexts; as an example, in relation to the UK we can note that the arguments for ‘religious clauses’, advocated for and gained as part of the Equality Act 2010 by a range of faith groups, adopted a rights-based discourse rather than religious discourse (Hunt 2012). The third feature is that of principled distance, which Stepan borrows from Bhargava, and which posits both support for all religions alongside legitimate state interference to contend with both interreligious and intrareligious domination. A further recent concept that has been analysed in relation to South and Southeast Asia is ‘covenantal pluralism’ (Stewart et al. 2020), which again reflects the deep diversity of the region. It emphasises, in contrast to above, legal equality along with recognition and respect for cultural difference. Covenantal pluralism, while contextually inspired, nevertheless remains to date normatively abstract and aspirational.

These positions are not without their own problems, however, as recent events in India, Indonesia, and Malaysia show trends of increasing majoritarianism, even state and communal persecution, which is putting religious diversity and freedom of religion in the region under severe strain. What is noteworthy about those trends is not just that they consist of forms of majoritarianism that go beyond the majoritarianism of the contemporary moderate secularism of Western Europe, but also that they are occurring despite the diversity-friendliness and group accommodation of political secularism and constitutional provision in countries such as India. Not only can political frameworks be more idealistic than what happens in practice – communal, religious, caste discrimination, and violence were features even in the heyday of ‘secular’ India – but secular modes of governance can be rendered inoperable or be radically deformed in the light of social dynamics and forces such as racism, nationalism, and populism (Sikka 2022). Analysis of a mode of secularism therefore must attend to both its normative aspiration as well as to the political practice and social reality, and be alert to changes taking place at each of these levels: the normative, political practice, and societal dynamics.

Throughout this collection we are concerned with normative questions of secularism and state-religion connections. Yet, we are also deeply exercised by contextualism. In this way, covenantal pluralism or the minimalist secularism of Laborde fall short of being able to outline and explain actual empirical cases and, moreover, challenges and shifts within concrete contexts. As well as contextualist, our concern is also comparative, and so we do not (as, for instance, Bhargava does) propose a one model outline that we suggest other contexts should follow. Our approach is rather to highlight what can be said about secularism in a minimalist sense, that is, what our different contexts can be said to share, and then work up to develop a contextual framework of how religious diversity is governed. This allows us to identify key similarities and differences as well as to account for shifts occurring as a result of challenges and debates in different contexts. The following sections outline our approach.

What is political secularism?

From the discussion above, it is clear we are talking of ‘multiple secularisms’ both by widening our scope outside the West, but also within the West (Taylor 1998; Casanova 2009; Calhoun, Juergensmeyer, and Van Antwerpen 2011; Stepan 2011). Taking this point further, we recognise that multiple secularisms are an aspect of the wider theoretical and sociological understanding; and in this sense are related to ‘multiple modernities’ (Eisenstadt 2000).

Accordingly, we adopt a minimalist definition of political secularism. This minimalist definition offers two distinct advantages. Others tend to start with freedom of religion or toleration, but they then cannot explain in what ways plainly secularist regimes like the former USSR and China are secularist states. Moreover, too thick a definition of secularism with, for instance, a focus on a strict church-state separation may fail to see states with state-religion connections of various extents and types as ‘properly’ secular. This is significant not least because 'no country worldwide can be classified as adopting the pure, theorised ”separation” model' (Perez and Fox 2018, 2). It is better, then, to start with what all secularisms have in common and then build up towards a normative account. This also allows us to observe the variety of political secularisms – both normatively and across the world – and the ways in which they differ. The minimalist definition of political secularism we work with is:

The core idea of political secularism is the idea of political autonomy, namely that politics or the state has a raison d’etre of its own and should not be subordinated to religious authority, religious purposes or religious reasons (Modood 2017, 354).

To this minimal secularism, liberal states have extended political autonomy to mutual autonomy (or something more akin to Stepan’s ‘twin tolerations’ [2000]), namely, not just the non-subordination of the political to the religious, but vice-versa too, the non-subordination of the religious to the state. Similarly, such states make equally central the idea that religion is a matter of personal choice or conscience, indeed this becomes a core principle of liberalism. For many theorists and publics, this liberal secularism becomes ‘secularism’ as such and the platform for all discussion. However, as will be evident from this collection, this is not the universal meaning and practice of secularism and the exercise of political autonomy or the state governance of religion. To begin with, liberal democratic secularism may be appropriate in some political and normative contexts but it is a Eurocentric bias as far as a global study of the governance of religion is concerned. We therefore begin with the above minimalist definition of secularism and develop a framework of different modes of the governance of religious diversity, which we outline in the following section.

Towards a comparative framework

The framework we develop, following the discussion above, differs in important ways from existing typologies. Different approaches for understanding how religious diversity in Europe is managed have highlighted, for example, a distinctly European model (in contrast with the United States) (Madeley 2009; Ferrari 1999, 2012), historical-confessional character (Madeley 2003; Knippenberg 2007; also Minkenberg 2008), immigration and cultural integration (Minkenberg 2008; Koenig 2009), disaggregating different types of establishment (see Bader 2007, 203; Stepan 2011; Minkenberg 2008), and the two-way relations between institutions and actors (Bader 2009). There are also those edited collections that bring together country case studies, such as those that focus on the varying forms of secularism outside the West (for example, Künkler, Madeley, and Shankar 2018; van der Vyver and Witte 1996; Burchardt, Wohlrab-Sahr, and Middell 2015), but without developing a comparative typology. Other studies have focused on religious repression or discrimination, whether more narrowly, such as in non-democracies (Sarkissian 2015), or more widely, and based on large data sets (Fox 2020). Fox’s (2008) is a truly global survey, taking in some 175 countries, and looking at government involvement in religion. Focused on debates of secularisation-modernisation and explaining government involvement, this study makes a number of interesting observations and identifies ‘patterns’, but again its focus is not in developing a typology of governance.

As well as the reasons outlined in the previous section, there are further reasons that also lead us to a separate and new framework. We suggest that there is not a ‘European model’ (cf Ferrari, Madeley) despite some commonalities (see Sealy and Modood; Magazzini, Triandafyllidou and Yakova; and Vekony, Iliyasov and Račius in this collection). Whilst we are alert to historical legacies, we also seek to avoid being trapped by path dependency (Enyedi 2003); because of notable comparative overlaps we find and that, as Bader puts it, ‘history is not destiny’ (2007, 875). Whilst we might characterise our approach as ‘inductive generalisation’, we seek to avoid an over proliferation of modes and patterns (Bader 2007, 876). Our framework also extends the focus beyond Europe or Europe-United States comparisons (cf Madeley, Koenig, Bader, Minkenberg, and Ferrari) to provide a comparative global framework. This set of groupings and country cases we discuss of course has omissions, both ‘regional’ as well as individual countries. The study is necessarily limited in the number of country cases it could include, but we hope that what we develop will have wider applicability than we are able to cover here (and might indeed be developed further in light of this).

Nevertheless, in developing our typology, our approach is closest to Stepan (2011), although we differ in how we draw our distinctions. Our focus is also distinct: we are not just focused on technical matters of state-church connections (established/not established, levels of separation or the fact of connections), although these are important. Based on the fact of state-religion connections in states regardless of where they would fall under such typologies, our focus is more on the qualitative character of state-religion connections and the norms of governance of religion and religious diversity. That is to say, our typology and the analytical strategy it employs focus not just on the fact of state-religion connections and relations, but on the character of these, the levels of control or support, for instance. It is this factor that we argue requires greater emphasis and attention.

In developing a framework to comparatively analyse the aspects and trends we have begun to discuss above, along with our empirical country cases, we identify five ‘modes’ of the governance of religious diversity. These are designed to capture different modes of governance and they relate to and reflect the minimalist definition of political secularism outlined above in different ways. This will be explored in more detail in the final contribution to this collection; for now we outline our five modes. While these modes identify and delineate distinct general approaches to the governance of religious diversity, approximating ideal types, they are insufficient for comparatively analysing the overlaps and distinctions between and within regions as well as capturing trends, developments, and changes or gaps and shifts between formal arrangements and practices. As such, each mode is broken down into constituent norms that distinguish them. In this way, while a dominant mode could be identified for different cases, it also allows us the flexibility to capture the dynamic character of how religious diversity is governed and how responses to present challenges are being shaped. The five modes and their associated disaggregated norms are presented in Table 1.

Table 1. Modes and norms for the governance of religious diversity.

1. Incorporated within Majoritarian Nationalism	Strong state identification with one religion May or may not include toleration for other religions May or may not include personal religious laws In radical cases the state takes over or controls the institutions and followers of one or more religions (e.g. Diyanet) The state may come to be controlled by religious parties (e.g. AKP, Muslim Brotherhood)
2. Secularist Statism	State control of religion The state excludes religion from the political and the civic, confining religious freedom largely to the private sphere This mode of secularism may be self-defined as part of the national identity. May include some support of some religions, but religion mainly seen as belonging to the private sphere
3. Liberal Neutralism	Moral individualism – freedom of conscience Anti-assimilation and equal civic standing of all religions Religions are officially and socially tolerated Active ‘de-othering’ but no ‘recognition’
4. Moderate Secularism	Moral individualism – freedom of conscience Religions may enjoy equal or unequal status but all are officially and socially tolerated Religion seen as a public good in need of support (e.g. funding of faith schools) Religion might also be seen as in need of regulation (to match some prevailing values e.g. issues of women bishops/single sex marriage) e.g. social attitudes that undermine tolerance and respect for religion and religious diversity (in interfaith relations and beyond religion) Mutual autonomy but restricted neutrality, including ‘weak’ establishment and unequal recognition Religious and non-religious citizens give each other generally accessible/dialogical reasons in politics
5. Pluralistic (‘unity in diversity’) Nationalism	Multiculturalising moderate secularism Difference-sensitive identity recognition Institutional accommodation of religious diversity ‘Respect All, Positive Cooperation, Principled Distance’ Religion active and present in public and political life Policy cooperation – religious reasons in political sphere Accommodative of differentiated legal status, religious personal laws Primacy of group autonomy and social support for deep diversity

While noting no country is a perfect match with any one mode and in some countries more than one mode will be at work, we can make a few important initial observations about these modes. Modes 1 and 2 can be characterised as anti-diversity approaches (or at least not pro-diversity in any public sense). It is worth noting that our mode of secularist statism might only be present as a dominant mode in one country (from the case studies here), this being France (see Sealy and Modood in this collection). But its inclusion reflects also that more countries would have been characterised by it until the past few decades, particularly several in Central and Eastern Europe, and we cannot discount the possibility of its future (re)occurrence and so our framework must be able to capture this particular form.

Mode 3 emphasises a conception of public neutrality (even if restricted in some way). It is not anti- or pro-diversity and might emphasise either way, often depending on how it is modified or qualified by norms from other modes. Modes 3 and 4 are both founded on political liberalism and give primacy to individual liberty and equality, although mode 4, developed from Modood (2017), goes furthest in extending this to groups. This feature of balancing or alternatively emphasising group rights as well as individual rights becomes an important point of difference for modes 4 and 5.

Modes 4 and 5 can be characterised as pro-diversity approaches, although exactly how this diversity looks and how it might also be limited is modified by features from the other modes. Both give some emphasis to group liberty and differentiated group equality, with neutrality much weaker, although mode 5 goes considerably further in including a range of cases from some group recognition to moral groupism.

We should also note that we do not include a mode to capture theocratic countries, such as Iran, not because we don’t recognise the distinction of these types of connections, but because none of our country case studies reflect these kinds of arrangements.

Applying the framework: an outline of the collection

Each mode of governance is unpacked by highlighting a number of constituent norms (some of which may overlap with one or more other modes of governance, as in the case of freedom of conscience). In applying these norms to an analysis of the governance of religious diversity, we make a further important distinction. Firstly, we designate the constituent norms of each mode (those in the right-hand column) as operative norms. Following what Parekh calls ‘operative public values’, this means that they are the norms that provide the ‘context and point of orientation’ (2000 [2006], 267) for discussions and debate over public religion. Our further distinction here, however, is to identify and distinguish between what we call dominant operative norms (DONs) and qualifying operative norms (QONs) in each given country context. DONs are those norms that we can see as operating at a more basic and underpinning level, they provide the ‘centre of gravity’ for the discussions and debates in a particular context, they are more pervasive and do most of the work in terms of how religion is governed. Often these are found in basic constitutional articles, but this is not necessarily or rigidly definitional of DONs. What is significant is that they are operative in how religion is governed. If norms or principles are stated in constitutional documents but are not actually effective in how religion is governed, for instance, they would not constitute DONs.

QONs are equally important and serve to limit, adjust, or modify how DONs function. They are present in a way that is significant for a state’s approach to diversity and serve to highlight important differences between country contexts that cannot be explained by reference to a single mode, and without seeing how other norms interact with it. QONs are not as prominent as DONs, but serve to qualify how DONs operate in important ways. Thus, in cases where two country cases might have the same DONs but different QONs, we would see a marked difference in governance. To be clear, the distinction between DONs and QONs is not that between de jure and de facto norms, or ideal and practice; it is between norms that do most of the work and norms that are also present and operative but not so powerfully, so they moderate the way that the dominant norms work. As such, the norms in the table above are not dominant or qualifying in any essential sense, rather they are contingent, potentially variable, and what norms are dominant or qualifying in any particular case is a matter of analysis of that case. This in turn is an important way in which our typology avoids static interpretations, as the norms, and whether they operate as DONs or QONs, have the potential to change.

Our modes then represent ideal types, each with a collection of norms that serve to constitute each mode and distinguish it from others. As we have seen above, our position is that context matters when it comes to conceiving secularism and its effects, and each of the contributions demonstrates this in relation to our five regions and their country case studies. As contextually derived, these modes can be said to roughly reflect empirical cases. Yet, as ideal types they also do not necessarily reflect all important aspects of any given context. As a result, what is centrally important in our framework, and central to its analytical innovation, is how norms may interact not just within, but also across modes, and how this can track as well as indicate directions of travel and shifts in governance of religious diversity. We are then not simply interested in a static ‘model’ view of state-religion relations, but in developing a comparative framework that allows us to analyse changes and developments in ways that might lean towards measures and arrangements that are diversity enhancing or equalising upwards, on the one hand, or towards diversity restricting or equalising downwards, on the other hand.

Making this distinction provides two analytical advantages reflected in each of our regional-based contributions to this collection. Firstly, it allows us to identify and specify intra-regional similarity and difference when countries may reflect the same general mode at a regional level, but have significant differences between countries below the regional level. In this way, it allows us to assess how the norms travel in a way which is contextually sensitive (and reflects a method of ‘iterative contextualism’, Modood and Thompson 2018).

Fahmi and Lahlou, for instance, show how overall, the MENA region represents majoritarian nationalism through the strong control exerted by the state whilst it promulgates religious identity as a core aspect of citizenship. This, moreover, is despite features of legal and institutional pluralism as well as legal frames that insist on the freedom of conscience, but which are not particularly operative. A general exception in the region, however, is Lebanon, which has institutionalised (limited) diversity. Sealy and Modood likewise show how Western European states and Australia share a basic conception of freedom of religion based in freedom of conscience, moral individualism, and toleration. However, important distinctions in the region revolve around the character of state-religion institutional connections, which mark France out as an exceptional case in the region. Looking at Central and Eastern Europe, the contribution by Vekony, Iliyasov and Račius shows that despite a common formal foundation of freedom of religion, in many countries the state identifies with one denomination and only the institutionalised forms of religion (registered religious organisations) are allowed to operate publicly. This is restrictive of diversity and there has been a rise of religious nationalism of an identitarian nature throughout much of the region, and where Lithuania stands out as an exception.

A second analytical advantage of our approach is that it allows us to see how different countries, despite being predominantly captured by one of our five modes, also include norms from other modes that have a significant bearing on the governance of religious diversity in that country. The contribution by Magazzini, Triandafyllidou and Yakova shows that Southern and Southeastern Europe as a whole also rests on moral individualism, freedom of conscience, and toleration for all religions. Yet how these regional points of similarity look and contrast within the region is shaped by the variance and emphasis of other norms that operate in each country, with aspects of moderate secularism and majoritarian nationalism making significant qualifications in different countries.

This, furthermore, allows us to look at how shifts and changes take place in directions that might be diversity enhancing or restricting as one or more norms become more pronounced and salient in contrast to others, again in ways that may not affect the overall mode that a country could be seen to reflect. We are then able to identify the factors that can explain the evolution in the different countries and the current challenges posed to or by how religious diversity is governed. For example, Sealy et al. identify in relation to South and Southeast Asia that while, on the whole, the region may be considered an example that reflects pluralistic nationalism (in line with Stepan’s position), the region is also (increasingly) characterised by qualifying norms of strong currents of diversity-limiting ethno-religious nationalism, and which might operate through the legal system and political processes, including policymaking, and be argued to have constitutional grounding. Also in this vein, in relation to Western Europe, Sealy and Modood show that countries that reflect a mode of moderate secularism might also have important operative norms from other modes, and which might be diversity-enhancing norms (such as institutional accommodation) or diversity-restricting norms (such as state control of religion), particularly in contexts marked by responses to threats of (violent) radicalisation.

The separate contributions apply the framework to intra-regional analyses of each of our five regions. The final, concluding contribution then draws some comparative threads from across our regional case studies. Through analysing the norms, institutional arrangements, policies, and practices, these contributions present comparative studies of selected country case studies within each region, which seek to identify both intra-regional differences as well as what can be said about the region as a whole. Each contribution presents an historical overview of state-religion connections and secularism, outlines key contemporary challenges, and analyses developments and shifts in relation to how religion and religious diversity are governed. As a collection, these contributions represent a comparative analysis of the governance of religious diversity with a global scope.

Acknowledgments

We are grateful to two anonymous reviewers and the journal editors for their comments on this contribution; and to all the contributors for their participation in this collection, as well as in the project, GREASE, which is the basis of this collection.

Disclosure statement

No potential conflict of interest was reported by the author(s).

Additional information

Funding

The GREASE project, on which this contribution is based, has received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement number 770640.

Notes on contributors

Tariq Modood

Tariq Modood is Professor of Sociology, Politics and Public Policy and founding Director of the Centre for the Study of Ethnicity and Citizenship at the University of Bristol, and the co-founder of the journal Ethnicities. He was made a Fellow of the Academy of Social Sciences (UK) in 2004 and elected a Fellow of the British Academy in 2017. His latest books include Essays on Secularism and Multiculturalism (2019), Multiculturalism: A Civic Idea (2nd ed. 2013); and as co-editor The Problem of Religious Diversity: European Problems, Asian Challenges (2017). He has a website (www.tariqmodood.com/) and a YouTube channel.

Thomas Sealy

Thomas Sealy is Lecturer in Ethnicity and Race in the School of Sociology, Politics and International Studies at the University of Bristol, UK. He has published journal articles and book chapters on multiculturalism, the governance of religious diversity, Islamophobia, forms of racism, converts to Islam, and Simmel. His monograph, Religiosity and Recognition: Multiculturalism and British Converts to Islam, is published with Palgrave.

Notes

1. See BBC (2011) ‘David Cameron Says the UK is a Christian Country’. 16 December. Online at https://www.bbc.co.uk/news/uk-politics-16224394; also WWRN (2014) ‘David Cameron Christianity claim backed by religious groups’. 21 April. Online at https://wwrn.org/articles/42235/.