This article focuses on public debates and public policy on the Islamic headscarf in the Netherlands and Germany. In the Netherlands the Islamic headscarf meets with an accommodating policy reaction, while in Germany some eight federal states have introduced legislation to ban the headscarf. This difference is explained, so I argue, by national differences in citizenship traditions. While the Netherlands represents a multicultural model, Germany used to be the paradigmatic example of an ethno‐cultural model of citizenship. Yet, the reaction of (...) the German left to the headscarf, while often non‐accommodating, is very differently inspired by German history than that of the right. A commonality is that in both countries the issue is framed as a conflict between public neutrality and religious freedom, not gender equality. An effect of the focus in the debate on neutrality is that it obscures the agency of Islamic women and the gender dynamics in Islamic communities. (shrink)

In this article, we scrutinize several arguments that are frequently used to legitimize a ban on religious symbols for civil servants. Most arguments, however, do not stand up to the test of Rawlsian political liberalism. One argument stands out as underpinning such a general ban: state neutrality. While this argument has the most potential, we argue why it is still not decisive for a ban on all religious symbols for all civil servants. We conclude that from a political liberal point (...) of view the discussion is inconclusive, and therefore advocate a context-sensitive and balanced approach to the matter of civil servants’ dress code with respect to religious symbols. By arguing that political liberalism is indecisive, our position is different from both ‘exclusive neutrality’ and ‘inclusive neutrality’. (shrink)