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The Crisis and Governance of Religious Pluralism in Europe

In recent years, religious pluralism has become the focus of intense debate in Europe – from controversies regarding religious clothing and symbols in the public sphere, to those related to limits on religious speech and the accommodation of religious practices – owing to the perception that pluralism has failed to contend with the purported incommensurability of Islam and European society. This article examines this purported crisis of religious pluralism in Europe and argues that while it is often depicted as resulting from the particularities of Islamic culture and theology, recent controversies point to a deeper crisis born of a historical failure to resolve the question of the governance of religious subjects.

The Crisis and Governance of Religious Pluralism in Europe
People who join to the march after the call from the Vaucluse Multicultural Federation of France to show their anger against the racist discourses and a swastika which is drawn on the wall of the Sorgues mosque on 13rd of February. (February 20, 2010). AF

For at least the past two decades, questions concerning the nature, value and parameters of religious pluralism have been the focus of intense debate within Europe. From controversies regarding the permissibility of religious clothing and symbols in the public sphere, to those related to limits on religious speech and speech that may offend religious sensibilities, and to those concerning the accommodation of religious practices, much of this questioning has concerned issues related to the migration of Muslims to Europe. For many, on both the right and the left, these controversies reveal a failure of religious pluralism in the face of a culture portrayed as inassimilable and incompatible with secular, democratic society. In this way, the crisis of religious pluralism appears to be rooted in an incommensurability of Islam and European society. Consequently, solutions to the crisis must be found in measures responding to the presence, and governing the practices of Muslim subjects. Below, I will discuss the purported crisis of religious pluralism in Europe and argue that while it is often depicted as a result of the particularities of Islamic culture and theology, recent controversies point to a deeper crisis born of an historical failure to resolve the question of the governance of religious subjects. 



Islam and the Crisis of Religious Pluralism

Since the early 1990s, the notion that Europe is in the midst of a crisis has been a growing refrain. This has been articulated as a crisis of a secular-democratic European society and the values that it is said to both promote and reflect. As I have written about extensively elsewhere, this crisis has arisen from and relates to Europe’s encounter with two immanent others – the Muslim migrant and the Turkish state – both portrayed as representatives of the (actual or potential) destabilizing and corrosive religious otherness of Islam.1 It is only within a context of immanence – the presence of Muslim migrants in the “diaspora zone”2 of Europe – or potential immanence (future Muslim migration to Europe or Turkish accession to the European Union) that particular features of Islamic culture, society and subjectivity, long-identified as troubling within Orientalist scholarship, came to be seen as an issue for the governance of European states. 

Within this discourse of a crisis of religious pluralism, the foremost concern is an ostensible incommensurability of Islam and secular, democratic society. This concern is articulated in two related ways. The first identifies elements of Islamic theology that are said to be directly incompatible with secular society. Primary among these is an understanding of Islam as an all-embracing religious system for which, as Charles Taylor asserts, “there is no question of separating politics and religion the way we have come to expect in Western liberal society.”3 Islam, therefore, appears as a system lacking the separation of civil and religious spheres fundamental to a secular society. The second points to a variety of social and political problems found in regions with majority Muslim populations and attributes these to Islam. Of these problems, the most routinely mentioned are those related to: a) patriarchal gender relations, such as gender segregation, sexual violence, honor killings and female genital mutilation; b) the mistreatment of religious and sexual minorities – pointing to discrimination, violence and the lack of legal rights and protections for these groups; c) a lack of respect for freedom of expression – as epitomized by the protests and violent reactions to the publication of cartoons depicting the prophet Mohammed in a Danish newspaper in 2005, and the release of films critical of Islam, such as The Innocence of Muslims in 2012 and the 2004 film Submission, whose director, Theo Van Gogh, was later murdered; and d) a lack of democracy in the Muslim world, both historically and in the contemporary times. These events, practices and interpretations of theology are said to be demonstrative of the essential incommensurability of Islam and secular democracy and, consequently, of the incompatibility of Muslims with European society. 

In this discourse of incommensurability, the above-mentioned problematic practices and attitudes are depicted as being rooted in the teachings, values and ‘culture’ of Islam. As such, they are not seen as spatially limited to Muslim societies. Instead, they are attributed to all Muslim subjects. Said to be rooted in Islamic values, these practices and attitudes are assumed to be held by all who adhere to Islam. Given this deterministic and essentialist understanding of Islam and the Muslim subject, the phenomenon of migration becomes particularly troubling. The Muslim migrant, as a carrier of Islamic values, allows for the troubling features of Islamic societies to, in the words of Samuel Huntington, escape their “bloody boundaries.”4 

For adherents of the notion of the Islamization of Europe, Muslim immigration amounts to a “jihad by other means.”5 Policies permitting immigration and pluralism are portrayed as contributing to Islam’s cultural and demographic conquest of Europe. These measures are seen as allowing for the transformation of secular Europe into a society “subservient” to Islam.6 In fact, it is argued that European practices of immigration, religious pluralism and minority rights, and ideals of tolerance and openness – often derided as exemplary of the rise of relativism – serve to undermine European culture and society by providing a Trojan horse for Islamization. This discourse has been incorporated into the program of far-right political actors in Europe, who have called for the introduction of a variety of measures aimed at buttressing Europe against this threat, including banning the Koran, the institution of a ‘headscarf tax,’ the elimination of institutional accommodation for religious practices, a cessation of Muslim immigration and even the deportation of Muslims already residing in Europe. 

The focus of contemporary European debates about the nature, value and limits of religious pluralism is related to issues regarding Muslim immigration

Such sentiments are not only present on the fringes of European politics. As José Pedro Zúquete has demonstrated, they have increasingly infiltrated mainstream European politics.7 The parties of the far-right that espouse notions of the incompatibility of Islam and European society have attained increased support and electoral success in some recent elections. Moreover, similar ideas are often advocated by traditionally mainstream political actors. Within mainstream political discourse, the threat of Muslim immigration is generally presented as an issue of social cohesion. Articulated in this way, the main challenge posed by migration is one of integration, seen as an exceptionally arduous undertaking given the aforementioned understanding of the nature of Islamic theology and society, and the deterministic and essentialist understanding of Muslim subjectivity. Muslims, defined by an essential and unalterable religiosity, are understood to pose a particular challenge for social cohesion due to their inability or unwillingness to integrate into secular European society. 

The primary concern with regard to governance relates to the previously mentioned view that Islam does not recognize a division of religious and secular authority or identity. The apparent absence of social differentiation is deemed problematic because it is said to permit the dominance of religious authority and identity in the public sphere. This often-repeated interpretation of Islamic theology has led to a questioning of whether religious authority will always override secular authority for Muslims. In other words, mainstream European political discourse reveals reservations regarding the willingness of Muslims to abide by laws that conflict with religious teachings and commandments. In debates concerning recent controversies related to religious pluralism, Muslims have been depicted as unwilling to abide by state regulations concerning appearance, freedom of expression, gender relations and violence against women. Moreover, the loyalty of Muslims to a particular nation or state is often seen as compromised by a primary allegiance to the supra-national Ummah.8 This question of loyalty has been given particular attention and has even been considered an issue of security for European states engaged in military operations within majority Muslim countries. 

Such apprehension regarding the ability of Muslim migrants to integrate into European society is apparent in various measures concerning migration that have recently been instituted in a number of European states. In the past decade, several European states have altered requirements for attaining residency and citizenship. For instance, as part of the “Nationality, Immigration and Asylum Act” of 2005, the government of the United Kingdom instituted the Life in the United Kingdom test, which includes 24 questions related to employment, government and society. The stated purpose of this test is not only to assess English language proficiency and candidates’ knowledge of British culture and society, but also, in the words of former Home Secretary David Blunkett, to “protect the rights and duties of all citizens and confront practices and beliefs that hold them back.”9 

Given this deterministic and essentialist understanding of Islam and the Muslim subject, the phenomenon of migration becomes particularly troubling

The United Kingdom is not, however, the only European state to institute such policies. In 1997, the French government established the Ministry of Immigration and National Identity, tasked with ‘controlling migration,’ ‘favoring integration’ and ‘promoting our [French] identity.’10 In addition, in January 2012, the French Interior Ministry introduced a citizenship test that requires candidates to demonstrate proficiency in the French language equal to that of a 15-year old native speaker, as well as sufficient knowledge of French history, culture and Republican values. Furthermore, France has attempted to ensure the loyalty and integration of migrants by the institution of a ‘social integration charter.’ In explaining the purpose of the charter, the then-Interior Minister, Claude Guéant, placed special emphasis on the needs of migrants to recognize the secular nature of the French state and society, and equality between sexes. This statement was widely seen as specifically aimed at Muslims, who constitute a majority of new French citizens each year. 11 As such, the charter states, “becoming French is not a mere administrative step. It is a decision that requires a lot of thought.” Moreover, it declares, “applicants will no longer be able to claim allegiance to another country while on French soil.”12 Thus, candidates are informed that they must decide whether, in order to attain French citizenship, they are willing to accept French values and loyalty to the French nation-state. 

Perhaps the most renowned of the recently instituted measures concerning the integration of migrants in Europe is the Dutch civic integration exam, which has been obligatory for all potential migrants since 2006. Similar to the measures instituted in France and the United Kingdom, the aim of the Dutch examination is not only to assess an applicant’s knowledge of the country’s language, history, politics and geography; it also tests their compatibility with what is considered secular, liberal Dutch society. The aspect of this examination that has attracted the most attention is a two-hour long film that potential migrants are required to purchase and view, entitled Coming to the Netherlands. This film, which critics have argued is designed to offend and exclude devout Muslims,13 contains images of public nudity and two men kissing in a park. The inclusion of these scenes, depicting practices ostensibly common and universally accepted in the Netherlands, is meant to demonstrate to potential migrants the importance of tolerance, as well as to gauge their willingness and ability to integrate into what is considered liberal Dutch society. These changes to immigration practices, like those in France and the United Kingdom, reveal an anxiety concerning integration and a resultant need to demonstrate to migrants that they must put aside, or at least temper, their religious beliefs, practices and loyalties in order to be welcomed into secular, democratic European societies. 

Such measures are responses to the belief, prevalent since at least the early 1990s, that Europe is experiencing a crisis of religious pluralism. For both proponents of the Islamization thesis and more mainstream figures, it is the phenomenon of Muslim immigration and a belief in the incommensurability of Islam and European secular-democratic society that have necessitated a questioning of the value, nature and limits of pluralism and toleration. In this sense, the crisis is portrayed as resulting from the particularities of Islamic culture and theology, namely, that within Islam “everything pertains to religion.”14 This understanding not only suggests that Islam does not recognize a distinction between religious and secular spheres, but also that religious authority and identity dominate all areas of a Muslim’s life. Such an understanding of Islam and Muslim subjectivity has led to a questioning of Muslim immigrants’ allegiance to European nation-states and obedience to secular authority, which – particularly since the events of September 11, 2001 – has increasingly been portrayed as an issue not only of social cohesion but of personal and national security. Of principal concern are two related issues: a) whether the primary loyalty of Muslim immigrants lies with the nation-state or the globally-dispersed Muslim community; and b) whether Muslims will, in the case of conflict, follow the dictates of religious or secular authority.



Loyalty, Obedience and the Perennial Threat of Religious Difference

While the discourse outlined above attributes the crisis of religious pluralism to the particularities of Islam, the perceived threat to governance posed by the presence of religious differences within a political community has been a topic of recurrent consideration throughout European history. Moreover, the concerns about loyalty and obedience that animate the contemporary sense of crisis are also the focus of perennial apprehension regarding the threat of religious forces to secular rule. As such, the current crisis of religious pluralism should be seen as the contemporary materialization of a deeper crisis of governance resulting from a failure to resolve the question of the governance of religious subjects.

Since antiquity, there have been ongoing attempts to manage the threat of the presence of religious differences within the political community. Within the empires of ancient Greece and Rome, comprised of followers of various religions, the divine mandate of the state required the worship of the official gods of the state. Failure to engage in such worship was viewed as a sign of disloyalty. However, the syncretism of ancient Greek and Roman polytheism served as a form of religious pluralism, permitting the followers of diverse religions to worship their traditional gods, while simultaneously paying tribute to the gods of the official pantheon. This was made possible by the equation of the gods of other religions with those of the official pantheon or, at times, the incorporation of a new god. The limits to this form of proto-pluralism appeared in the form of atheism, which rejected the worship of deities, and, in the case of the Roman Empire, monotheistic religions (particularly Christianity and Judaism), which prohibited their followers from participating in the polytheistic state religion. Within the Roman Empire, both Christians and Jews faced severe persecution, including restrictions or at times outright prohibition of worship and proselytization. 

Muslims, defined by an essential and unalterable religiosity, are understood to pose a particular challenge for social cohesion due to their inability or unwillingness to integrate into secular European society

As in the case of Islam in Europe today, the measures enacted against Christians and Jews in the Roman Empire were reflective of anxieties related to their loyalty and obedience. The primary loyalty of these groups was seen as residing with their religious community, rather than the Empire. Moreover, owing to their rejection of the divinity of Imperial power and the eschatological aspects of their theologies, the obedience of Christians and Jews to Imperial rather than religious authority was always in doubt. The legalization of Christianity in the 313 Edict of Milan and its eventual establishment as the official religion of the Roman Empire by Theodosius I in 380 did not, however, introduce an era of religious pluralism. Rather, the persecution of Jews and Christian sects deemed heretical increased and in 392, all pagan cult worship was prohibited. 

The loyalty of Muslims to a particular nation or state is often seen as compromised by a primary allegiance to the supra-national Ummah

With the Protestant Reformation, religious difference once again emerged as an issue of governance in Europe. Despite being banned in 1521, Lutheranism was rapidly gaining adherents by the middle of the 16th century, including a number of Princes within the Holy Roman Empire. In order to contend with this problem, the doctrine of cuius regio, euis religio (whose realm, whose religion) was developed. With the inclusion of the ius reformadi (right to reform) in the Peace of Augsburg of 1555, rulers were permitted to enforce religious uniformity within their principality. Individuals living in a territory whose leader belonged to a denomination other than their own were also guaranteed the right to emigrate. 15 Thus, the Peace of Augsburg attempted to provide a solution to the presence of religious differences and the attendant problems of loyalty and obedience by introducing a system of interstate religious pluralism and intrastate religious uniformity. However, the extent of interstate pluralism permitted by this solution was limited, as only Catholicism and Lutheranism were recognized as state religions. 

The signing of the Treaties of Westphalia in 1648 marked the official end of this system and the emergence of new challenges related to religious pluralism. By abrogating the ius reformadi and guaranteeing certain rights to Christians living in territories where their denomination was not the established church, the Peace of Westphalia introduced the religious minority as a legal subject. With the recognition of religious minorities in law, a new problem arose for the state: namely, how to govern these subjects. Rulers could no longer legally resort to traditional policies of annihilation, forced conversion or expulsion. The legal acceptance of religious minorities led to a renewal of anxieties concerning loyalty and obedience to the ruler, leading, at times, to open conflict or the violent suppression of minorities. Thus, the Peace of Westphalia failed to offer a model of governance capable of resolving such issues without periodically resorting to policies aiming to restrict or eliminate religious differences. 

Since the emergence of liberal constitutionalism, questions regarding the governance of religious minorities have been complicated, as the right to religious difference is viewed as inalienable. Consequently, the governance of religious difference cannot take the form of an explicit exclusion of followers of particular religions. Nor, however, can this issue be ignored, given the threat it could pose to social and political cohesion. The task of democratic political philosophy, consequently, has been to formulate systems of governance through which the risks that religious differences pose to the nation-state can be managed without illegitimately constraining freedom of religion. 

A worshiper opens the door of a mosque where nazi graffiti had been sprayed, on December 20, 2011 in Décines, a neighboring suburb of the French southeastern city of Lyon. AFP / Jean-Philippe KsiazekA worshiper opens the door of a mosque where nazi graffiti had been sprayed, on December 20, 2011 in Décines, a neighboring suburb of the French southeastern city of Lyon. | AFP / Jean-Philippe Ksiazek

Two models of governance have emerged to contend with this dilemma. Influenced by John Locke’s theories of tolerance, the first of these models – the secular state – is characterized by the strict division of a privatized religious sphere and a neutral, secular public sphere. According to Locke, the problem of the loyalty and obedience of religious subjects is not simply the result of the presence of followers of different sects within the same political territory; rather, it is due to a lack of clearly demarcated and differentiated civil and religious jurisdictions. He suggests that as long as religion and the state recognize that the sources of their authority are distinct and belong to separate realms, the religious subject can “be a citizen of both sacred and secular realms — he could enjoy dual citizenship — with no conflict of obligations.”16 

Foreshadowing the recent questioning of the limitations of religious pluralism in Europe, Locke’s toleration only extends to those he judged willing and able to respect the separation of state and religious jurisdictions. Moreover, if particular religious practices had secular consequences, he declared that intervention would be justified and appropriate. Thus, while freedom of religion is protected by the secular state, the expression of beliefs must remain confined to the private sphere. Within the public sphere, secular reason and identities prevail. Only through the adoption of a secular reason and identity is the individual deemed able to legitimately engage in public discourse. As these limitations make evident, within the model of the secular state, dual citizenship can only be exercised by subjects capable of bracketing their religious identities and beliefs while in the secular public sphere. Consequently, the model of secular governance continues to operate with a logic of exclusion – an exclusion legitimized through the declared neutrality of the public sphere. 

The crisis of religious pluralism in Europe is reduced to a crisis of Europe’s engagement with Islam, a problem related solely to the particularities of Islam

The second model of the governance of religious difference – the religiously pluralistic state – attempts to escape the logic of exclusion at play in the secular model. Yet it too fails to resolve the question of loyalty and obedience. Rather than requiring the religious subject to transform their persona in order to conform to the supposedly neutral norms of the public sphere, the pluralistic model advocates the constitution of a public sphere that can accommodate religious subjects. Within this model, religious subjects may engage in public discourse and advocate positions that derive from religious teachings. Consequently, it is argued that they are free to maintain their religious identity in the public sphere. Unlike in the case of the secular model, agreement is not found in the common adoption of a universal citizen identity or a neutral public reason, but through the emergence of an overlapping consensus of various traditions and worldviews.17 However, despite this opening of the public sphere, religious subjects’ participation is still bounded by their capacity to engage in ‘reasonable’ and reciprocal discussion. Of question is the ability of the religious subject to: a) participate in public discourse, and b) abide by the judgements resulting from the political process.18 Given the perceived inerrancy of revealed truths and the potential for eternal rather than merely temporal reward and punishment, the religious subject is said to have difficulty engaging with positions that are contrary to religious dogma and accepting the burden of public judgement. As such, they are considered to have great difficulty adopting the persona of the citizen, engaging in the process of ruling and being ruled. 




The focus of contemporary European debates about the nature, value and limits of religious pluralism is related to issues regarding Muslim immigration and concerns about the incommensurability of Islam and European secular-democratic society. As such, the crisis of religious pluralism in Europe is reduced to a crisis of Europe’s engagement with Islam, a problem related solely to the particularities of Islam and the phenomenon of Muslim migration to Europe. Depicted as such, it masks the ways in which it is reflective of the historical anxieties about the governance of religious subjects. As discussed above, since antiquity, it is the very characteristics said to define religious subjects – their allegiance to an authority beyond the state and the force of their convictions – and related questions of loyalty and obedience that are deemed a barrier to their inclusion in the public sphere and, consequently, a threat to social cohesion and the state. Consequently, rather than stigmatizing Muslims as particularly threatening figures – which will only legitimize the rhetoric and feed into the popularity of Europe’s increasingly influential far-right anti-immigrant groups – it is necessary to work towards developing a model of community that can address the issues of religious pluralism without resorting to a logic of exclusion.  




  1. Ian Morrison, “Christianity, Secularism and the Crisis of Europe,” Agnes Czajka and Bora Isyar (eds.), Europe after Derrida: Crisis and Potentiality (Edinburgh: Edinburgh University Press, 2013), pp. 149-162.
  2. Avtar Brah, Cartographies of Diaspora: Contesting Identities (New York: Routledge, 1996).
  3. Charles Taylor, “The Politics of Recognition,” in Amy Gutmann (ed.), Multiculturalism (Princeton: Princeton University Press, 1994), p. 95.
  4. Samuel Huntington, “The Clash of Civilizations,” Foreign Affairs, Vol. 73, No. 3 (1993), p. 35.
  5. Bat Ye’Or, Eurabia: The Euro-Arab Axis, (Madison: Fairleigh Dickinson University Press, 2008), p. 9.
  6. Ye’Or, Eurabia, p. 9.
  7. José Pedro Zúquete, “The European Extreme-Right and Islam: New Directions?”, Journal of Political Ideologies, Vol. 13, No. 3 (1995).
  8. Cécile Laborde, “Secular Philosophy and Muslim Headscarves in Schools,” The Journal of Political Philosophy, Vol. 13, No. 3 (2005), p. 321.
  9. Zúquete, “The European Extreme-Right and Islam,” p. 336.
  10. Both this Ministry and the High Council for Integration, which has been in place since 1989, were disbanded by the Socialist government elected in June 2012.
  11. “France Makes it Harder to Become French,” France24 (December 30, 2011), retrieved November 18, 2013, from
  12. “France Makes it Harder to Become French.”
  13. Jeremy Bransten, “EU: Netherlands Leading Trend to More Stringent Immigration Rules,” Radio Free Europe/Radio Liberty (April 5, 2006), retrieved November 18, 2013, from
  14. Youssef al Qardawi, as quoted in Laborde, “Secular Philosophy and Muslim Headscarves in Schools,” p. 321.
  15. Benjamin Straumann, “The Peace of Westphalia as a Secular Constitution,” Constellations, Vol. 15, No. 2 (2008), p. 174. 
  16. Michael W. McConnell, “Believers as Equal Citizens,” Nancy L. Rosenblum (ed.), Obligations of Citizenship and Demands of Faith: Religious Accommodation in Pluralist Democracies, (Princeton: Princeton University Press, 2000), p. 93.
  17. McConnell, “Believers as Equal Citizens,” p. 106.
  18. Jeff Spinner-Halev, Surviving Diversity: Religion and Democratic Citizenship, (Baltimore: John Hopkins University Press, 2000), pp. 99-106; Eamonn Callan, Creating Citizens: Political Education and Liberal Democracy, (Oxford: Oxford University Press, 1997).

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