The Legacies of History? - Middlebury College

The Legacies of History? Colonization and Immigrant Integration in Britain and FranceAuthor(s): Erik BleichSource: Theory and Society, Vol. 34, No. 2 (Apr., 2005), pp. 171-195Published by: SpringerStable URL: http://www.jstor.org/stable/4501720Accessed: 05/02/2010 15:07

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Theory and Society (2005) 34: 171-195 @ Springer 2005

The legacies of history? Colonization and immigrant integration in Britain and France

ERIK BLEICH Middlebury College

Abstract. This article scrutinizes the widely held belief that British and French colonial models have influenced each country's immigrant integration structures. It assesses the core assumptions underlying the argument: that British colonial and integration policies have relied on indirect rule of groups defined by race or ethnicity; and that corresponding French policies have emphasized direct rule and have been highly assimilationist. It demonstrates that the two countries are not as different as often portrayed. It also pinpoints the specific paths through which colonial legacies influenced integration policies, while rejecting the thesis that colonial institutions have broadly informed integration policies in Britain or France. The article thus challenges a series of re- ceived ideas, replacing them with a more precise assessment of the relations between the colonial past and the integration present.

During the colonial era, Britain and France established a host of administrative institutions and enacted a wide range of policies to facilitate rule beyond their borders. Through their actions overseas, the British and French states first gained experience governing ethnically, racially, and culturally diverse societies, making decisions about the status and rights accorded to different groups. They influenced millions ofpeople, structuring their education, work, and laws, and shaping their identities and interactions with each other and with outsiders. As decolonization proceeded in the post-war decades, this imperial diversity was increas- ingly transferred to British and French shores. As immigrants from former colonies arrived in significant numbers, policymakers in each country faced choices about how to administer ethnic diversity at home.

Britain and France's multi-ethnic pasts and presents raise questions about the extent to which colonial history has influenced contemporary practices of managing ethnic pluralism in each country. The most common argument for a strong connection is based on four assumptions: that Britain relied on indirect rule in its empire while cultivating ethnic and cultural differences; that Britain's integration institutions

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and policies have recognized ethnic differences and have replicated indirect rule on British soil; that France employed direct rule and tried to assimilate people in its colonies; and that France's policies to integrate post-war immigrants have been highly assimilationist. These four assumptions are widely held by educated non-specialists and are also frequently articulated by scholars of immigrant integration who, although they typically emphasize other factors in their analyses, reg- ularly nod in the direction of the similarities between colonization and integration in Britain and France. Early in his book Philosophies of Integration, for example, Adrian Favell (1998: 3-4) states:

The responses of France and Britain [to the issue of immigration], as befits their respective colonial reputations, appear to be almost reversed mirror images of one [an]other: France emphasizing the universalist idea of integration, of transforming immigrants into full French citoyens; and Britain seeing integration as a question of managing public order and relations between majority and minority populations, and allowing ethnic cultures and practices to mediate the process.

The juxtaposition of British and French approaches is also common among experts who specialize in one or the other country. In his work on race relations in Britain, Ira Katznelson (1976: 176-77) argues that "a key feature of classic colonial patterns of social control- indirect rule through a broker, native leadership - has been replicated in the mother country." More recently, Christian Joppke (1999: 224-25) followed in this vein by writing:

Britain's readiness to acknowledge immigrants as ethnic minorities has deep historical roots. ... [T]he empire provided a pluralistic model for dealing with post-imperial immigrants. If imperial France had tried to assimilate her colonies, imperial Britain never had such pretensions. ... When the "natives" moved from the periphery into the center of empire, there was no presumption of their becoming "British" or "English" in any way.

For its part, the French integration model is portrayed as highly assimilationist - far more so than the British, German, or American models, which are argued to embrace the concepts of multiculturalism and ethnic diversity (Todd 1994; Schnapper 1992). Egalitarian assimilation of immigrants is seen to bear a striking resemblance to France's colonial civilizing mission. Mich le Lamont (2000: 185) remarks upon the difference between British and French colonial models in her work comparing France and the United States:

This belief in the superiority of French culture has been maintained through colonialism via France's mission civilisatrice - its mission to carry civilization to such less-developed regions as North Africa. French culture was imposed on Asian and African elites at a time when France's empire

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was second only to Great Britain's. By contrast, the British colonial project supported the cultural autonomy of its subjects. For the French, barbarians could become part of humanity by assimilating.

Belief in the differences between British and French colonial structures, the differences between their integration structures, and the internal continuity within each country is, in short, extremely widespread. It hovers at the periphery of many expert analyses as a taken for granted proposition.

In spite of its generally accepted status, the relation between managing ethnically diverse societies in the colonies and managing them at home has rarely been carefully scrutinized.' This article therefore assesses the legacies of colonization on immigrant integration in Britain and France in order to confirm, disconfirm, or clarify a relationship widely believed to exist. It examines general philosophies, specific administrative institutions, and concrete public policies that each country created to rule its colonies and to integrate ethnic minority immigrants in the post-war era. The first and second sections of this article consider British and French colonial and integration policies respectively in order to get a clearer picture of their divergences but also of their similarities and ambiguities. The third section analyzes the nature and significance of the causal connections between colonial and integration policies in each country.

Two central findings emerge. First, British and French colonial and integration policies are not as internally consistent or as diametrically opposed as often portrayed. There are significant differences to be sure, but there is a much greater degree of policy similarity in both domains than admitted in the thumbnail sketches offered in many current scholarly works. Second, although there is evidence that the colonial era influenced elements of integration philosophies, institutions, and policies in concrete ways, there is no broad connection between the colonial past and the integration present implied by many observers. Actors formulating integration policies rarely looked to the colonies for inspiration. This article therefore serves to nuance a too-broad argument by replacing its sweeping version with more precise insights about the relationship between past and present.

British and French colonial policies: Consistent and coherent?

Britain and France each ruled millions of people through hundreds of policies in dozens of regions over centuries of history. In spite of the

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tremendous variation in each country's empire over place and time, it is common for non-specialists to summarize British colonial policies as indirect rule that preserved cultural and social differences among the natives, and to characterize France's as based upon direct rule and a civilizing mission designed to assimilate colonial subjects through French language and culture. Although the precise line distinguishing indirect from direct rule is sometimes blurry in practice, Wallerstein (1961: 40-41) has defined the former as "leaving in place the traditional system and often the traditional ruler, and operating as much as possible through that system," and the latter as "a rational bureaucratic hierarchy with all officials operating on a state payroll and within a single judicial framework." The fundamental distinction on the contin- uum from indirect to direct rule revolves around the extent to which the colonizer governs through pre-existing, "native" institutions versus through modes transplanted from the home country.

British decision-makers did favor indirect rule in parts of Africa where it "met the need to rule broad areas with millions of subjects of diverse races and levels of development with the least possible outlay and a minimum of British personnel" (von Albertini and Wirz 1982: 309; see also Wallerstein 1961: 41). It was carried out through policies that installed non-colonists at the head of bodies such as the Native Courts and Councils (Asiwaju 2001: 119) and that created Native Authority police forces to preserve order in many rural areas, not only in Africa, but also in India (Anderson and Killingray 1991: 8). Indirect rule also meant that indigenous people retained the power to collect taxes, to control budgets for local schools, markets and roads, and to legislate on "traditional" matters (Crowder and Ikime 1970: xxi-xxii).

France adhered to its colonial reputation most steadfastly in the vieilles colonies (Guyane, Guadeloupe, Martinique, and R6union), in parts of Senegal and India, and in Algeria. The 1848 Revolution brought French citizenship for former slaves in the Caribbean and in the four communes in Senegal, and voting rights for indigenous people in the five French cities of India (Weil 2002: 235; Perina 1997: 17). Algeria was also made an integral part of France in 1848 and was divided into three departments. Reforms between the 1860s and the 1880s extended French administrative structures and policies across Algeria (Lorcin 1995: 8-9). Advocates of assimilation in the nineteenth century presumed that natives would pass through an initial stage of being culturally civilized (France's mission civilisatrice) before being eligible to become naturalized Frenchmen (Lorcin 1995: 7).

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Further differences between British and French rule have been the subject of several comparative studies of colonialism. With respect to nineteenth and twentieth century Southeast Asia, for example, Furnivall ob- serves that "the individualism of [the] Dutch and English contrasts even more markedly with the strongly centralized and still more positive government congenial to the French" (Furnivall 1941: 6). In West Africa, whereas the British often delegated local governmental functions to legitimate native chiefs, the French administrators typically deprived local chiefs of their role in administering justice and in governing, using them simply to carry out centrally mandated tasks (Crowder and Ikime 1970: xvi). The French also oversaw education policies much more than the British in West Africa, taking responsibility for the building and administration of schools. Mission schools - the norm in British Africa - were strictly controlled in French colonies, reflecting the prevailing skepticism of religion in metropolitan France (Asiwaju 2001: 214-18). Even in the interwar Middle East (a region less central to each country's colonial history), scholars have argued that France assumed its mandates with an eye toward moral duties and to the mission civilisatrice, whereas the British had no such goals (Sluglett 2004).

These widely acknowledged distinctions between British and French colonialism are meaningful, but they should not be overstated. Taken to- gether, they represent a selective reading of history that picks the places, time periods, and policies that highlight the greatest differences between British and French colonial policies. As V Dimier (2004) showed, historians and practitioners of colonialism have disagreed about differences between the countries' practices. British observers tended to emphasize national divergence; French counterparts tended to see distinctions as just ones of degree. Without setting this, one can identify at least as many similarities as differences in British and French colonial policies. For example, there were important elements of direct rule in British colonial administrations in India, Ceylon, South Africa, parts of West Africa including Sierra Leone and Gambia, and in the West Indies (Fieldhouse 1981: 33). In East Asia, Furnivall characterizes British rule in Burma, Singapore, and the Malay Straits as direct rule, despite the fact that in the Malay Straits "it seemed unnecessary to incur the trou- ble and expense of direct administration" (Furnivall 1941: 15). Even India has been dubbed the classic example of direct rule (Fieldhouse 1981: 32).2 In 1858, the Crown officially took over Indian administration from the British East India Company. The Secretary of State for India became the "de facto Indian minister" and was responsible, along with the Viceroy who was appointed by Parliament, for the

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development of Indian laws and legislative powers (von Albertini and Wirz 1982: 13). The hierarchy of power thus flowed from the Secretary of State, as an extension of the British will, to the Governor General, to the Viceroy, to the district officers, who were responsible for the tax collection and maintenance of law, order, schools, roads, and hospitals within the basic administrative unit, the district (von Albertini and Wirz 1982: 14-15). Such a chain of command echoes the philosophy of direct rule more typically associated with French colonization.

Moreover, in many ways the British shared the notion of a civilizing mission with the French, letting themselves be guided by the idea that "less favored races needed supervision by advanced peoples in order to proceed to higher levels of civilization" (Heussler 1971: 574). This was particularly true in India, as emphasized by Fischer-Tine and Mann's edited volume (2004). In Mann's (2004: 4) analysis:

The idea of a civilizing mission rested upon the twin fundamental assumptions of the superiority of French culture and the perfectibility of humankind. Also, it implied that colonial subjects were too backward to govern themselves and that they had to be "uplifted." ... The same was true, of course, for British attitudes towards their Indian empire and the non-white colonies.

This perspective is supported not only by Kipling's notion of the white man's burden and Macaulay's desire to create a class of Indians "English in taste, in opinion, in morals and intellect" (cited in Mann 2004: 20), but also by the extension of the rule of law through the Civil and Crimi- nal Procedure Codes enacted in India in the 1860s (Mann 2004: 9-10).

French colonial policy, conversely, saw a move in the late nineteenth and early twentieth centuries away from assimilation and direct rule. By 1892, colonial policy objectives in Algeria that were geared toward subordinating the administration to Parisian ministries were "aban- doned in favour of a combination of parliamentary representation and local autonomy" (von Albertini 1982: 286). Even more dramatic was the growing popularity among French governors and colonial officers of the idea that "French rule could be established more smoothly if one tried to win the co-operation of the inhabitants, built on existing institutions and applied civilizing pressures slowly and 'indirectly"' (von Albertini 1982: 286). These changes were justified by the doctrine of "association," which had competed with that of assimilation throughout much of the 1800s (Amselle 1996: 93-4; Deschamps 1971: 545-6; Lorcin 1995: 7). According to proponents of association, it was more productive to work with colonized peoples' institutions and to

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respect cultural differences than to override them (Lorcin 1995: 7). By the post-World War One era, the trend toward association had taken a firm hold in French colonial policies, even in former assimilationist strongholds such as West Africa (Conklin 1997).

In practice, the French policy of assimilation, signified by the granting of French citizenship to some inhabitants in Senegal, Algeria, and the vieilles colonies, was not employed outside of those regions. Under the direction of the Colonial Ministry that was established in 1894, naturalization in French West Africa, French Equatorial Africa, Madagascar, and Indochina was not easily obtained.3 Assimilation as a policy of converting natives into full-fledged French citizens was rare in most French colonies as demonstrated by the fact that in 1936 there were fewer than 2,500 native citizens among the 15,000,000 inhabitants of French West Africa outside of Senegal (von Albertini 1982: 289). In Algeria, local administrators responsible for vetting Muslims who wanted to become French exhibited "exceptional bad faith," discouraging as many as possible from jumping the high hurdles to citizenship (Weil 2002: 236-7). The predictable result was that naturalization was all but impossible for Algerian Muslims. Between 1865 and 1930 only approximately 4,400 out of over 3.5 million Muslims became full citizens (Weil 2002: 237, 240).

The doctrine of assimilation had its limits in other spheres too. France's colonial education policies, for example, were rarely as uniform as commonly believed. In their scholarship, Gifford and Weiskel (1971) seek to overturn the image of French West African schools as carbon copies of those in the metropole. They argue that while France set education policy, course content was adapted to the local conditions. The language of instruction was French for pragmatic reasons of fostering communication among diverse language groups. But they cite a 1906 report by the Inspector of Education in Senegal to illustrate the true tone of French educational policy in Africa: "Respectful of the beliefs, the customs, the habits and the traditions of the African peoples submitted to this authority, the Governor-General wants in no way to assimilate the indigenous peoples nor to orient in this direction the education given to them" (Gifford and Weiskel 1971: 677). Other evidence of France's approach to education comes from Indochina, where during the interwar period, French Governor-General Albert Sarraut decreed that instruction was to be exclusively in Vietnamese, a decision clearly not in keeping with a policy of assimilation (von Albertini and Wirz 1982: 212).4

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Approaches to the colonies differed greatly by time, place, and policy area in both Britain and France. Each country practiced both direct and indirect rule. Each believed it had a civilizing mission. Each viewed its subjects as inferior peoples. Laying out these facts does not imply that the two countries' colonial policies were precisely the same. It does demonstrate, however, that British and French colonial policies were neither as internally consistent nor as different from one another as often thought.

Integration policies: Britain, France, and post-colonial immigrants

Since the end of the Second World War, millions of immigrants have arrived in Britain and France, many from the former colonies. The two countries now have decades of experience trying to integrate migrants and minorities into their societies. As with colonial policies, it has become common to characterize British and French policies as significantly different. Britain is represented as favoring a decentralized (indirect) policy approach that encourages multiculturalism, whereas France is deemed the home of state-centric (direct) assimilation of immigrants (Favell 1998; Schnapper 1992; Soysal 1994; Todd 1994).

There is, of course, evidence to support each of these views. The early post-war history of British immigration was marked by local rather than centralized initiatives to integrate newcomers (Rose 1969: 380- 2). The government's national level integration bureaucracies such as the CIAC and the NCCI5 were relatively short lived (they did not sur- vive the 1960s) and were designed primarily to assist local jurisdictions in formulating responses to problems of immigration. As of the late 1960s, and with increasing amplitude since then, the British state turned toward "community relations" and "race relations" laws and administrative bodies that have an explicit remit to promote harmonious group interactions. In addition, British policymakers eventually accepted the counting and categorizing of citizens by race and ethnicity, codifying their decision in the 1991 census (Coleman and Salt 1996; Peach 1996).

For its part, the French state has never recognized individuals according to racial criteria, and has studiously avoided integration policies that channel money or support to ethnic groups (Bleich 2000; Soysal 1994). Until 1981, France even restricted the rights of migrants to organize collectively, hindering ethnic identities and action. The government's recent banning of Islamic headscarves in public schools appears to be further evidence of a widespread preference for assimilation over

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multicultural recognition of ethnic differences. Moreover, for the majority of the post-war era, France's primary integration institution, the Social Action Fund (FAS),6 was a centralized organization that left little leeway to local governments to craft their own integration policies (Silver 1993).

These facts demonstrate that there are real differences between British and French integration policies. However, as Adrian Favell has force- fully argued, it is not possible to summarize a country's integration strategy in terms of a coherent, discrete model because it consists of a "disparate range of state policies, laws, local initiatives, and societal dispositions - which could be implemented by many agencies at many levels" (Favell 2001: 351). Looking across time at a variety of spheres, it becomes clear that each country has - at various times and in various ways - employed a wide range of integration policies. British and French officials have used both direct and indirect methods, and have both promoted assimilation and recognized cultural differences.

The work of Gary Freeman (1979) reveals that British and French policymakers in the post-World War Two decades believed they could assimilate arriving immigrants. Home Secretary Roy Jenkins' 1966 in- vocation that integration should be defined "not as a flattening process of assimilation but as equal opportunity, accompanied by cultural diversity, in an atmosphere of mutual tolerance" (cited in Joppke 1999: 225), is often used as evidence of Britain's preference for multiculturalism. But his statement was memorable principally because it marked a significant change from the attitudes that dominated integration debates until that time. Merely a year before Jenkins' speech, a Labour party spokesman publicly suggested that "'only immigrants most likely to be assimilated into national life' should be permitted to stay in Britain" (cited in Tomlinson 1983: 12).

In terms of concrete policy areas, government-sponsored groups such as the CIAC were concerned with "the role of the education system in bringing about the cultural assimilation of immigrant children into 'British life"' (Tomlinson 1983: 16; see also Patterson 1969: 108-14), and until at least 1971, policies were in place to disperse immigrant school children to avoid heavy concentrations in any one school district (Freeman 1979: 151). Similar themes of assimilation resurfaced under the leadership of Margaret Thatcher and the Tories, especially during the overhaul of British education policy in the late 1980s and early 1990s that included the development of a new National Curriculum.

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At the time, political leaders were issuing orders to excise references to multicultural education - references that had been a prominent part of British educational philosophy since the late 1970s - and were re- assuring the public that pupils would be well-grounded in the history of "British heritage" (Tomlinson and Craft 1995: 2-5). More recently, Labour Party leaders have echoed the interest in common national val- ues by proposing "Britishness tests" for would-be citizens and by instituting oaths of citizenship during new naturalization ceremonies.7 Even the chairman of the Commission for Racial Equality (CRE) announced in early 2004 that he was skeptical of the term "multiculturalism" and saw the need to "assert a core of Britishness."8

The British system also contains several important national policy tools for promoting integration. Since 1976, for example, the Commission for Racial Equality has been able to undertake race relations audits of companies, industries, ministries, or local governments (McCrudden 1987; Bleich 2003: 100-1). The CRE has used this authority to open formal investigations into groups as diverse as the Handsworth Horti- cultural Institute, the Abbey National Building Society, the Ministry of Defense (Household Cavalry), the Birmingham Local Education Au- thority, and most recently the police service of England and Wales.9 If there is evidence of systematic racism, the CRE is empowered to issue a court-backed non-discrimination notice requiring compliance with the Race Relations Acts (Great Britain: Home Office undated: 11.3-.20). Since 2000, the Labour government has also strengthened national provisions for integrating refugees by instituting a variety of English language training programs across the country (Great Britain: Home Office 2004: 24-30).

Just as Britain has not always pursued a unified multicultural line, so has France wavered from its assimilationist path. Compare, for example, Jenkins' above statement with the French High Council on Integration's description of the basic French philosophy:

It is a question of evoking the active participation of different and various elements in the national society, while at the same time accepting the maintenance of cultural, social and moral specificities and taking for granted that the whole is enriched by this variety, this complexity. Without denying differences, knowing how to take them into account without exalting them, a policy of integration accents similarities and convergence. [Haut Conseil A l'Int~gration 1991: 18]

These two seminal statements of integration strategies are surprisingly similar. The French statement strikes a balance between fostering common ground and valuing diversity, two goals that have been present to

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varying degrees throughout France's post-war history. Any desire to simply assimilate difference was short-lived and faded away long ago. By the 1970s, for example, Freeman (1979: 309) noted that "having begun with a grander commitment to assimilation than the British, the French were quicker to admit the impossibility of absorbing large elements of non-Europeans and simply gave up." Throughout the 1970s and early 1980s, moreover, the prevailing policy philosophy in France was "insertion," which relied to some extent on "cultural groups and representatives of the immigrants" to help with integration (Favell 1998: 47).

French policymakers have leaned away from assimilationism on concrete as well as on theoretical levels. In the 1970s, the French state actively supported religious pluralism through increased tolerance of Islamic practices in factories and local public housing (including financial support for religious books and even for imams' salaries), and it promoted cultural pluralism by sponsoring mother-tongue classes for immigrant schoolchildren and by developing cultural programming on television, such as a one-hour Sunday night show called "Mosaic" (Weil 1991: 245-9). Beginning in the 1980s and continuing through today, political leaders have sought to cultivate Muslim interlocutors to represent the community's interests vis-a-vis the government (Roy 1994). In 2003, the French state took the controversial step of establishing an elected French Council of the Muslim Religion (Laurence 2003). 0 This policy directly contradicts assimilationism by institutionalizing representation based on an ethno-religious identity. It is much closer to domestic indirect rule than anything attempted in Britain."1 Moreover, while the 2004 banning of religious symbols in schools appeared to be a blow struck for assimilation, this is not necessarily the case. Its original impetus came from public order considerations of preventing verbal and physical assaults on young Muslim women who refused to wear the headscarf (Weil 2004).

In dealing with integration, the French state has also not been as uni- formly centralized as its reputation suggests. When the Socialist government came to power in the early 1980s, it instituted three principal reforms of the FAS, its main immigrant-integration bureaucracy: it made it more independent from ministerial control; it included immigrant representatives in the institution's governing body; and it created Regional Commissions for the Insertion of Immigrant Populations (CRIPI) designed to "select and subsidize social, cultural, and education programs outside of the Parisian region" (Silver 1993: 499). Since

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1999, as integration policy has evolved toward the fight against discrimination, Socialist Party leaders and their center-right successors have developed Departmental Commissions on Access to Citizenshir (CODAC), a decentralized structure for handling complaints of racisrr (Hargreaves 2000). Although it is too early to tell how much independence or impact they will have, they have been encouraged by Ministers to seek out funding for their initiatives from both national and Europear sources, suggesting some leeway for local leadership.12

There are also similarities between British and French integratior strategies that rise above distinctions between assimilationism and multiculturalism and between direct, centralized actions and indirect, decentralized policymaking. British and French decision-makers have each relied heavily on attempts to foster integration that do not requirc them to take an explicit position in these debates. Many of the ma. jor problems of immigrant integration have been addressed througi educational, urban, and housing policies that apply to areas definec principally by geography and social deprivation, rather than by th( presence of immigrants or minorities. In the 1960s, for example, th( major British government programs put in place - Section 11 of th( Local Government Act of 1966 and the 1968 Urban Programme - were officially targeted at areas, rather than at groups (Young 1983 288). Although they were designed to deal with problems associatec with immigrants, these initiatives were not labeled as such, and thc funding was open to a range of depressed areas in Britain. Similarly in France, major integration programs have been couched in "genera legal" (droit commun) terms that address groups and

neighborhood, afflicted by "unfavorable social conditions" (Lapeyronnie 1993: 160- 1). This was true of programs such as the Educational Priority Zone, (ZEP) and policy initiatives against youth unemployment and urbar degradation, especially in the early 1980s (Lapeyronnie 1993: 169- 76). Naturally, the effect on immigrant and minority integration wa, part of policymakers' calculus when crafting these policies. Yet the policies themselves were never explicitly aimed at immigrants or mi. norities. In practice, they contained both centralized and decentralizec elements, and were neutral with respect to promoting multiculturalisn versus assimilation. In this highly significant way, therefore, Britist and French policies closely resemble one another.

In summary, integration policies have taken a variety of forms it both Britain and France. They each contain elements of activist, cen tral government-led initiatives and more laissez-faire local policies

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Each country has at times demanded assimilation, and each country has tolerated and even cultivated cultural pluralism. They have both used targeted and general policies to promote integration. Although in significant ways each country fulfills expectations, it is not accurate to view Britain as a bastion of local, minority community-led integration, or France as the home of centralized assimilation. The notion of unified British and French approaches, with each country at the opposite end of an integration policy spectrum is simply not sustainable.

The legacies of history?

So far, this article has demonstrated that British and French colonial and integration models are neither as distinct nor as divergent as commonly assumed. Knowing this clears the way for a precise assessment of the true legacies of colonialism, but in itself it says nothing about the causal connection between the two policy areas within each country. How accurate is the prevailing belief that British and French integration structures are legacies of their respective colonial pasts?

In a number of concrete ways, integration policies in each country were direct continuations of policies developed for the British and French empires. This is especially true in the realms of citizenship and immigration policy, at least in the early post-war decades. As Randall Hansen (2002) has argued with respect to Britain, post-war citizenship and immigration policies were initially created to encourage close ties between the home country and its overseas relations. Until 1962, members of Commonwealth countries had unfettered access to British soil.13 Once in the United Kingdom, these West Indian, South Asian or other Commonwealth immigrants had all the rights and responsibilities of British citizens, including the right to work, the right to vote and the right to access to the welfare state.

In France, all Algerians (including Muslims) had full French citizenship within a few years of the end of World War Two (Weil 1991: 64). This was the much delayed but logical outcome of the state's claim that Algeria was an integral part of the nation. After the 1962 Evian Accords confirmed Algeria's independence, access to French citizenship con- tinued for individuals born in Algeria prior to independence because of the pre-existing colonial citizenship policies. Even if these individuals elected to become citizens of Algeria, their children - if born on French soil (and hundreds of thousands were) - were automatically granted French citizenship and did not have to go through the normal

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processes for second-generation immigrants. They were considered t( be children born to parents born on French soil, and thereby qualifiec for the same rules of automatic citizenship at birth as normally ap. plied to third-generation immigrants (Brubaker 1992: 139-42; Hanser 2002). France's colonial-era policies thus had an effect on citizenshil rights that lasted across generations.

On the whole, however, it was not the case that agencies or policiet established to manage civil, social, political, or cultural affairs in th( colonies were adapted to deal with the integration of immigrants it Britain and France. It is plausible, for example, that the Colonial Of fice or the Ministry of the Colonies could have been transformed int( immigrant integration institutions as each country decolonized. Thi: did happen briefly in Britain during and just after World War Two when the Colonial Office developed a small welfare department witl responsibility for the problems faced by immigrants from the colonie: (Rich 1986; Patterson 1969: 114). It organized facilities for black stu dents and seamen arriving in Britain, and during the war it also oversav welfare provisions for black voluntary workers (Rich 1986: 48). Thi: pattern did not become the norm for managing integration concerns however, and the office was closed in 1951 (Patterson 1969: 114).

Instead, in the 1950s and 1960s, each country established integration or ganizations de novo, such as the Commonwealth Immigrants Advisor Committee (CIAC) and the National Committee for Commonwealti Immigrants (NCCI) in Britain and the Social Action Fund (FAS)14 anm SONACOTRA in France (see Freeman 1979; Patterson 1969; Silve 1993; Weil 1991; Lapeyronnie 1993). Although these organization were initially set up to deal with problems associated with colonia immigration (as opposed to other sorts of immigration), they had ne historical basis in the colonies themselves. Colonial offices and colo nial institutions on the whole failed to expand into the area of inte gration, and ultimately withered in the aftermath of decolonization. Ii most other domains, such as education, employment, health care, ani housing, policies from the colonies were not transferred to the hom country. Immigrants arrived in a well-developed domestic institutiona environment and were expected to adapt to it. What policy continuit transpired, therefore, was not a legacy of colonial structures but rathe a result of domestic stability.

Even in areas such as citizenship and immigration where initially ther was strong continuity between colonial and integration structures, th

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consequences of such policies led both Britain and France to shift their positions significantly. The main result of open citizenship and immigration policies was an influx of hundreds of thousands of immigrants from the empire.15 Britain's restrictive 1962 Commonwealth Immigrants Act was enacted by the Conservative Government in large measure as a backlash against the recent arrivals (see Hansen 2000; Layton-Henry 1992). Yet in reaction to that move, the 1964 Labour Government passed a liberal Race Relations Act in 1965 as part of what Home Secretary Frank Soskice referred to as a "package deal" to "integrate coloured immigrants."16 Member of Parliament Roy Hat- tersley summed up the connection between the two decisions with the aphorism "Without integration, limitation is inexcusable; without limitation, integration is impossible" (quoted in Rose 1969: 229). This progression from open immigration, to large influxes of colonial migrants, to restrictive immigration policies, to liberal integration policies is certainly a legacy of colonization. But the ultimate outcomes - limiting movement within the empire and proactively promoting racial equality - are quite different from the original colonial policies.

In a parallel fashion, France's open-door policy toward residents of newly independent Algeria in the 1960s resulted in hundreds of thousands of migrants within a few years. In response to this situation, France pressured Algeria to accept restrictions on trans-Mediterranean migration, limiting the annual number of workers to 35,000 in 1968 and capping it at 25,000 in 1971 (see Weil 1991). France's citizenship rules for Algerians also provoked integration policy debates and actions. As Rogers Brubaker (1992: chapter 7) has shown, the automatic granting of citizenship to children born in France whose parents were born in Algeria prior to 1962 sparked a controversy in the late 1970s and early 1980s. Many of these second-generation immigrants (not to mention the Algerian state) did not want French citizenship ascribed to them. Yet since they lived in France, the state was unwilling to release them from citizenship and required them to perform duties such as military service. In 1984, France and Algeria signed an agreement allowing dual nationals to perform their military service in only one country. These policy discussions, though narrow on their face, helped spawn a discussion about citizenship and integration that hit crescendos in the late 1980s and the 1990s when citizenship rules were hotly debated (Brubaker 1992; Feldblum 1999). In this case, citizenship policies that applied to colonials generated an anomalous legal status, which in turn prompted a change in citizenship rules, with the entire process framed as a discussion about integration and national cohesion. Once again,

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however, there has been no direct, continuous line from colonial tc integration policies in these cases.

For those who perceive the similarities between a country's colonial pasi and integration present, assessing individual policy areas may seem tc miss the forest for the trees. Scholars such as Frank Dobbin (1994: and Yasemin Soysal (1994) have argued that institutions can take theii shape because they are modeled on the logic of pre-existing institutions in other domains. Soysal, for example, attributes variation in incorpo- ration regimes across Europe to "the conceptual and organizational configuration of the political order within which states frame their action" (1994: 35). This type of logic may apply to the cases at

hando and is particularly consistent with Joppke's (1999: 224) views of the British model's historical roots and with Favell's (1998: 3) discussion of the two countries' colonial reputations.

In the British case, the strongest advocate of this perspective has been Katznelson, who sees "indirect rule through a broker, native leadership" (1976: 176) applied almost unwittingly in the 1960s.'7 Freeman (1979: 40) and Rich (1986: 168) concur that there have been elements of this colonial philosophy apparent in post-war integration practices. For France, Jean-Loup Amselle (1996) has made the most systematic argument for the continuity between the colonial and contemporary era of an approach he calls "assimilationist regeneration," which is the marriage of the Republican concept of assimilation with the longstand- ing differentialist historiography of France as a country of Gauls and Francs - in other words, of multiple ethnic groups.

As noted earlier, there have been some aspects of British integration policies that resemble indirect rule - particularly the decentralization of integration policymaking in the first few decades after 1945. Overall, however, the argument rests on weak foundations. Since indirect rule was so widely hailed among colonial thinkers in the interwar years, it is likely that if it were seen as relevant, it would be openly advocated at home. However, there is no evidence that policymakers, politicians, or other public figures used the term in public or in private when discussing immigrants in Britain. This may have been because granting ethnic leaders real governing power was an integral part of indirect rule. Though policymakers sought input from immigrant leaders in some circumstances, the British state did not consider turning over power to minority groups to represent themselves, even along the lines the French state has taken with the Council of French Muslims. It is true that there were some immigrant leaders on the NCCI in the early

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1960s, but this group was not meant to represent ethnic minority immigrants and was never very powerful. The NCCI was chaired by the Archbishop of Canterbury (who made his chairmanship conditional on the NCCI's including immigrant members), its role was merely advisory, and it was disbanded after a few short years.'8 Moreover, managing minorities through indirect rule was incompatible with the British state's oft-repeated goal of the early post-war decades: assimilating new immigrants.

Amselle's argument with respect to France is slightly different. Rather than insisting simply that assimilation has always been the dominant national framework for dealing with ethnic diversity, he argues that French leaders and thinkers have historically been torn between viewing humanity in the singular and in the plural. In his own words, "the Republican logic which rests, as we've seen, on the principle of the fusion of the races, in fact presupposes the existence of a plurality of groups" (Amselle 1996: 106). He cites evidence from colonial con- quests in Egypt, Algeria, and Senegal, and from contemporary France to illustrate his argument about this particularly French model of multiculturalism. Amselle's thesis is appealing because it suggests that the tensions between assimilation and association - between trying to "civilize" people and trying to preserve their cultures - can be unified in one philosophical perspective that has endured for centuries. It argues for a strong legacy of colonialism on integration strategies, but not necessarily the legacy that most people see. And it appears to fit the facts that assimilation (in the sense of the state actively trying to promote "Frenchness") has been variously applied and ignored over time.

However convincing Amselle's evidence that some thinkers have melded the two strands of thinking into one philosophy, when French politicians, activists, and citizens debate symbols of integration, they often land on one or another side of a significant divide. Ongoing discussions about the Islamic headscarf, for example, reflect serious disagreements within French society. There are those who - in an assimilationist vein - believe that headscarves are un-French (perhaps even uncivilized) and should be banned where possible and discour- aged everywhere else. Others deploy multicultural rhetoric to argue that people must be allowed to draw on their identities and lead their lives without having to assimilate into a supposedly unified French culture. These disagreements suggest that there are different views about how to manage ethnic difference rather than one unified perspective that has carried forward from the colonial era to today.

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British and French colonial and integration policies are clearly neither internally consistent nor diametrically opposed. Nevertheless, French policymakers have stressed assimilation and centralization with some- what greater frequency than their British counterparts, who have typically proven more open to embracing ethnic distinctions and decentralized policymaking. Although this apparent continuity over time may reveal a legacy of the past - albeit one toned-down in intensity and consistency - in fact, there are three possible explanations for the parallels within each country. Integration policies might indeed owe their origins to colonial structures. However, it may be that both sets of institutions were caused by a third factor, making the relationship between the two spurious. Or, it is conceivable that the origins of both sets of policies within each country are unrelated, in which case the parallels would be merely coincidental.

In the French case, it is possible to sort through these hypotheses by examining the statements of integration policymakers. Did they explicitly draw on colonial principles when formulating their decisions, did they refer to other sources for their actions, or did they estab- lish integration structures without regard to historical models? French authorities specializing in integration affairs have justified their perspectives and actions with references to the past. However, politicians and policymakers have tended to speak of the French Revolutionary and Republican tradition when articulating their rationales for immigrant integration theories and practices, especially when debates about citizenship moved center stage in the 1980s. In his scholarship, Rogers Brubaker (1992) draws the lines between the Revolution, the Repub- lic, and post-colonial integration policies most clearly, highlighting the assimilationist elements in all three eras. He is not alone in viewing this history as an important inspiration for future policymaking: the High Council on Integration (Haut Conseil a l'Int6gration 1991: 19) spelled out the French integration logic by insisting that "the iden- titarian and egalitarian principles that stretch back to the Revolution and to the Declaration of the Rights of Man and of the Citizen im- pregnate our conception, founded thus on the equality of individuals before the law, whatever their origins, their race, their religion... to the exclusion of an institutional recognition of minorities." References to the anti-model of Vichy also serve to bolster the positive view of the French model of integration. When discussing the pros and cons of collecting racial or ethnic data on citizens, a high-placed French integration official insisted that it could not be done because it would recall the categorization of Jews during the Vichy regime, an obviously

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intolerable outcome.19 As numerous scholars have demonstrated (Bleich 2003; Feldblum 1999; Favell 1998), lessons from the Revo- lution, Republican, and Vichy eras have played a prominent role in debates surrounding integration policymaking, whereas references to colonial experiences have been exceptionally rare.

It is more difficult to pinpoint the sources of Britain's post-war integration strategies. It seems plausible that recognition of racial and ethnic difference (and the institutionalization of such recognition in British post-war censuses and laws) was handed down from centuries-old liberal and pluralist models of social organization, or that it was a logical extension of the United Kingdom's multi-national structure. Gilles Kepel (1997: 86, 98, 145), for one, views British colonial policies, internal decentralization, and post-war ethnic policies as derived from the same philosophical origins. However, during the early stages of colonial immigration into Britain, official policy was race-blind and even assimilationist. Embracing multiculturalism was a decades-long and sometimes painful process during which many more references were made to concurrent developments in North America than to Britain's colonial history. When passing race relations legislation, in particular, British policy experts and political leaders turned repeatedly to North American laws and policies for inspiration, using them as guideposts for developing their institutions (Lester and Bindman 1972; Rose 1969; Bleich 2003). As an indicator of the impact of the American model, it is interesting to note that the landmark 1969 British study Colour and Citizenship was explicitly inspired by Gunnar Myrdal's An American Dilemma, and that its goal was to help stave off the type of racial disintegration prevalent in the United States (Rose 1969: xix). The substantial attention to the North American situation and the paucity of references to the colonies suggest that in the British case, integration structures were largely independent of colonial legacies.

On the whole, therefore, it is difficult to sustain an argument that colonial institutions affected current integration policies in an over- arching manner. Colonial structures in both countries were quite varied. Policymakers cannot, therefore, cast an eye back to the colonies and come away with simple lessons. Integration policies have also embodied many currents that run against each country's supposedly dominant approach, further complicating the picture. Even if one accepts that there have been tendencies toward indirect rule and multiculturalism in Britain and toward assimilationism across time in France, the preponderance of the evidence

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suggests that present-day integration policies do not flow from colonial history.

Conclusions

This article finds that Britain and France did not formulate their integration policies with colonial traditions weighing on the brain. This contradicts the plausible and commonly held view that each country's integration institutions reflect its colonial past. The historical record shows that the assumptions central to this argument - that France's colonial policies and integration structures have been assimilationist and direct, and that Britain's have been differentialist and indirect - are not as true as they at first appear. Each country has exhibited aspects of both strategies in its colonial and integration structures. On balance, the two countries are closer to the middle of the spectrum than the edges, even if France has employed state-centric assimilation with respect to its colonies and its integration policies more explicitly and moderately more often than has Britain.

Policymakers also made few references to colonial templates when formulating immigrant integration strategies. The Revolutionary and Republican traditions (for France) and the United States (for Britain) were more common orientation points than colonial precedents. Neither French nor British policymakers relied exclusively on those referents when devising their strategies; but to the extent that they molded their integration structures based on examples from other arenas, they looked to non-colonial sources more than to colonial ones.

Although the broad version of the colonial legacies argument does not hold, narrower versions do. Aspects of each country's post-World War Two integration approaches were indeed linked to previous colonial policies. This is especially true in the domains of immigration and citizenship, where inclusive rules set up for colonial subjects were maintained even after decolonization took place. Colonial structures and their effects - particularly on migration from colonial hold- ings - also eventually provoked a number of additional consequences. The arrival of large numbers of ethnic minority immigrants from the colonies generated specialized administrative agencies to deal with problems of housing, schooling, and racism, such as France's FAS and SONACOTRA and Britain's CIAC, NCCI and eventually the CRE.

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Of course, some of these agencies and other policies were subse- quently eliminated or altered, and most of them were reactions against the status quo rather than a continuation of it. Nonetheless, significant elements of each country's integration institutions cannot be un- derstood without reference to specific colonial structures and their effects.

Legacies of colonialism on official integration institutions are thus narrower and more limited than frequently supposed. It is worth highlighting, however, that colonial legacies may remain significant in other ways. For example, racist beliefs that expanded and became deeply rooted during the colonial era continue to exist to this day. The legacy of racism has been important in British and French societies, in part by spurring governmental action in the form of an- tiracist laws and policies. Focusing this study on official institutions has called into question one type of legacy, but it has not ex- hausted all paths for exploring the contemporary effects of colonial history..

British and French colonial and integration approaches are not diametrically opposed, nor are there broad structural legacies between the colonial and integration eras in either country. This article replaces these presumptions with a more realistic assessment of the complex nature of British and French policies in both time periods, and with a sense of the specific ways in which each country's colonial man- agement spilled over into its dealings with immigrant minorities after decolonization. Britain and France may have first gained experience governing diversity in their colonies, but the way each country man- ages its multiethnic society today has less to do with its colonial past than has frequently been presumed.

Acknowledgments

For helpful comments as this article developed, I thank Ian Barrow, Adrian Favell, Veronique Dimier, Peter Hall, Randall Hansen, John Rex, Patrick Weil, the members of the Middlebury College Political Science Department Faculty Research Group, and the reviewers and Editors of Theory and Society. Jill Parsons provided excellent research assistance. For financial support for a conference series in which this paper was first presented, I am grateful to the German Marshall Fund of the United States.

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Notes

1. Freeman (1979: 28-42) and Lapeyronnie (1993: 129-33) are exceptions to this rule. How- ever, their injunctions not to read contemporary policies as direct legacies of colonial history have had little impact on popular assumptions about the connections between the two eras.

2. Though not all of India was under direct rule at all times. I thank Ian Barrow for highlighting this point.

3. Naturalization was "theoretically open to every native, but it had to be requested from the administration and was subject to a number of conditions: knowledge of the French language, conclusion of military service, etc. and above all it meant the renunciation of the applicant's personal status and his subordination to French law" (von Albertini 1982: 279).

4. Anne Raffin's (2002) review of French colonial policy in Indochina during World War Two shows elements of assimilation tempered heavily by a lauding of cultural pluralism and strict limits on access to citizenship.

5. The Commonwealth Immigrants Advisory Committee and the National Committee for Commonwealth Immigrants.

6. Fonds d'Action Sociale. 7. See The Observer, 7 September 2003; The Evening Standard, 26 February 2004. 8. The Times, 3 April 2004. 9. A full list of reports on formal investigations is available on the CRE web site at

http://www.cre.gov.uk/publs/cat-fi.html. 10. Conseil Franqais du Culte Musulman. 11. As such, it is in keeping with Jean-Loup Amselle's conclusion that France operates "a

veritable indirect administration of entire sectors of the population" (Amselle 1996: 164). 12. See the French government's circular NOR/INT/K/04/00019/C of 5 February 2004. These

commissions, although with regional responsibility and with regional participants, are chaired by the departmental representative of the central state.

13. Very few colonial subjects immigrated prior to 1948, when the British Nationality Act formally instituted equal citizenship for the United Kingdom and the colonies.

14. The mandate of the organization when initially formed in 1958 was to construct housing for "Muslim workers in the metropole and their families" (Silver 1993: 493).

15. Empire here refers to current or former colonies as well as possessions such as Algeria deemed at the time to be part of the state. For data on migration flows see Hansen (2000) and the annexes in Weil (1995).

16. PRO HO 376/68. See also Hansen (2000), and Bleich (2003). 17. He writes that "most of the literature on British race politics misses the significance of the

critical structural decision to link the Third World population to the polity through buffer institutions, replicating key features of traditional colonial relationships" (Katznelson 1976: 178).

18. I thank John Rex for an exchange that helped clarify the role and composition of the NCCI. 19. Confidential interview, Paris, 30 June 1997.

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The Legacies of History? - Middlebury College