1.11.2009 | Von:

Classic objections and possible counter-arguments

Socio-political objections against dual citizenship

(a) 'Unjustified' double voting rights
In nearly all states, voting rights are given on the basis of citizenship. Some commentators, therefore, critically point out that persons who are the citizens of two countries can also vote in two countries, whereas the voting rights of people with solely German citizenship are limited to Germany. Critics argue that this undermines the basic principle of equality of citizens, which is expressed by "one person, one vote". [15]

In this regard it should firstly be noted that, generally, voter turnout amongst the overseas electorate is low. Moreover, many countries of origin have neither established a system of postal ballots, nor do they facilitate voting in their diplomatic missions.

On a theoretical level, the response to the objection that citizens' equality is being infringed may be that the frame of reference for the principle of electoral equality is the single State. [16] No anti-discrimination norm in national or international law aims at equal treatment before different and independent states. Furthermore, the principle of equality only guarantees that there must be plausible reasons for unequal treatment. Where the double voting rights of dual citizens are concerned, the plausible reason is obvious: unlike non-migrants in both countries, they are influenced by both cultures, are rooted in both spheres and belong to both societies. [17]

(b) Integration
A significant objection to dual nationality lies in the assumption that it restricts the integration of dual citizens, as they do not fully identify with the country of immigration. [18]

This objection may be responded to on four points. First, states can bar people who do not wish to accept their values and culture from obtaining citizenship. Thus German naturalisation requirements since 2007 include knowledge of the German social system, culture, history and language. [19]

Second, there are no empirical studies that indicate that retention of another citizenship would erode any existing integration; there are no empirical findings to support those social-psychological assumptions which claim that, for example, an Afghan-German cannot be fully committed to Germany because he possesses two citizenships. Research on transnationalism is only gradually beginning to put forth better hypotheses as to how transnational activities and the feeling of belonging change during the course of a migrant's life, and how this varies between individuals and groups. [20] As sociologist Tomas Hammar observes, civil and cultural identity is not a zero-sum game [21], which means that individuals do not have a limited number of "identification units" that they have to divide between different states and that, therefore, increase in identification with one country proportionately reduces ties to the other. In layman's terms, if a person can simultaneously have sincere ties to a father, a mother, a spouse and children, why should a person not be able to extend his or her patriotic ties to two States at the same time? On the contrary, it is increasingly maintained that combined identities are a sociological reality. In this regard, dual nationality may be seen as legal recognition of these composite national identities. [22]

Third, making it compulsory for German-born people of foreign origin to opt for one of the two nationalities between the age of 18 and 23 may be understood by some as a signal that they are expected to be "just German" and that "Germany" does not recognise their mixed identity, despite their acknowledgement of German values. Such a perception can only have a negative effect on integration.

Fourth and last, an argument against the supposed adverse effect of dual citizenship on integration is: recognizing multiple citizenship creates an incentive for naturalisation. No one would maintain that granting citizenship – with or without the retention of another nationality – will inevitably lead to the integration of the new citizen. Yet, it is certainly a safe assumption that the granting of citizenship will simplify and improve the integration of those who would not otherwise apply for naturalisation. Even if there are few empirical studies on the outcome of these status passages, it can be expected that, due to increased political rights and formal belonging, naturalisation would lead to better positioning within, and interaction with, the majority population. [23] Further, migrants may be induced to identify more readily with a receiving country that recognises mixed-cultural identities.

(c) Loyalty
One of the main objections to dual citizenship lies in a suspected conflict of loyalties. Here, a distinction may be made between conflicts specifically mentioned and less explicit general doubts about the necessary degree of loyalty. One such possible specific conflict is that in the event of war a state depends on the undivided loyalty of the nationals it can call to arms in its service. Further, it is assumed that participation in a country´s political life – as a voter or office-bearer – could be adversely affected by divided loyalties.

With regard to the first objection, it should be pointed out that wars involving the mass drafting of civilians in countries such as Germany are unlikely. Like most modern armies, the German armed forces are constantly developing in the direction of having a smaller body of specialists, so that the non-availability of dual citizens for mass conscription in the unlikely event of war would not compromise the ability of a country such as Germany to defend itself. This would in any case only affect dual nationals from a country with which there was armed conflict.

Proponents and opponents of dual citizenship, meanwhile, agree that persons holding important public offices should give up their second citizenship. [24] As regards electoral behaviour, however, critics of dual citizenship perceive the danger of "instructed voting", whereby dual nationals vote according to the will of the government of their other nationality. However, it seems doubtful whether the state of origin is actually able to make its nationals living abroad behave in a certain way. In particular, experience in many countries where dual citizenship is permitted shows that in practice this does not lead to any appreciable influence on the part of a foreign state. [25]

Moreover, it should be borne in mind that not allowing dual citizenship is no guarantee that the population in Germany will consist only of loyal mono-nationals. Rather, a comparison must be drawn with the reality that, for decades and generations, millions of people have been living in Germany with just one –non-German – citizenship. These people will remain on German soil in the future, too. What are we to make of the fact that this section of permanent residents has no formal ties of loyalty with the state in which it resides?


Roland Koch, for example, writes in Die Welt, 15 January 1999: "Why should citizens of foreign origin have a say in politics in Germany, whereas Germans abroad have no right to vote?" [translation by the author] See Naujoks (2008:Fn.24) for further references to this kind of argument.
Likewise Aleinikoff and Klusmeyer (2002:31).
Naujoks (2004:21), ibid. (2008:392f.); Bauböck (2005:17.) Moreover, concerns in this regard may be alleviated by the introduction of an "inactive citizenship status" whereby dual nationals enjoy full and unlimited rights in the country of ordinary residence, whereas in the country in which they do not live they have a kind of "truncated citizenship"
Günther Beckstein (quoted in Die Welt, 4 August 2002): "The dual passport is the enemy of integration. New citizens must be fully committed to their new homeland." [translation by the author] See Naujoks (2008:Fn29) for further references to this subject.
Cf. Section 10, para. 1 nos. 5 and 6 German Citizenship Act.
Bloemraad (2004:395).
Hammar (1985:449).
Likewise: Hammar (1985:449); Aleinikoff and Klusmeyer (2002:36, 39).
As Thränhardt (2008) shows, equal involvement of foreign employees in companies´ internal governance has led to good integration within companies. Steinhardt (2008) proved empirically that naturalisation per se leads to improved integration in the national labour market and to higher salaries. Also according to Wüst (2006) "the political integration of migrants [makes] a contribution in terms of the acculturation process of majority and minorities that should not be underestimated." [translation by the author].
Cf. Hailbronner (1992:26); Martin (2003:17); Bauböck (2005:22); Aleinikoff and Klusmeyer (2002:41).
Bauböck (2005).



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