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)

Since conflicts of human rights can be translated into conflicts of values, this article looks into the sources and extension of value pluralism for a better understanding of the sort of conflicts of human rights that women face in multicultural contexts. Furthermore, a proper understanding of personal autonomy as a founding value underlying individual rights can contribute to an interpretation of women's human rights that takes account of both their untouchable core as well as their contextual meaning. As conflicts of (...) fundamental rights most often take place in a scenario of strong pluralism, the article considers cases of conflicts of rights in multicultural societies focusing on the overlapping values to be balanced. Religious freedom, education, neutrality, equality or toleration are some of the issues to be addressed: all of these are important and should be evaluated considering their further implications for women as well as for the other individuals involved. (shrink)