“Non Western” Secularism: the Case of “Religious” Citizenship in Israel and Turkey

Anna Parrilli


The essay examines the connection between citizenship and religious affiliation. To this end, it focuses on two case studies, namely Israel and Turkey. In Israel, the Law of Return acknowledges to all Jews a “fundamental right” to Israeli citizenship. In Turkey, while the constitution explicitly affirms the principle of State secularism, ethnicity and religion are closely interrelated, and they both contribute to defining Turkish national identity. This interrelation produces flaws between the black-letter constitution, and the operational rules governing citizenship. The essay argues also that Israel’s and Turkey’s legal systems are both characterized by the persistent influence of the Ottoman legal tradition, as well as that of the communitarian paradigm underling Jewish and Islamic traditions. In both countries, citizenship and State approach towards religious communities follow the logic of the millet, which operates in an institutionalised form, in Israel, as a cryptotype in Turkey.


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Comparative Law Review is registered at the Courthouse of Monza (Italy) - Nr. 1988 - May, 10th 2010.
Editors - Prof. Giovanni Marini, Prof. Pier Giuseppe Monateri, Prof. Tommaso Edoardo Frosini, Prof. Salvatore Sica, Prof. Alessandro Somma, Prof. Giuseppe Franco Ferrari, Prof. Massimiliano Granieri.

Direttore responsabile:Alessandro Somma