‘All happy families are alike; each unhappy family is unhappy in its own way.’
The beginning line of Leo Tolstoy's Anna Karenina echoes often through the pages of two extraordinary recent investigations of citizenship in Africa. Nothing quite captures the particular complexities of a country's history and its people, its context and ongoing challenges, its capacity and capriciousness, than the unique (and often unhappy) trajectories of citizenship policies and practices. Citizenship laws are not only the backbone of juridical African states, but also the connective tissue of African nations, of families created by centuries of co-existence and conflict, external interference and continual internal contestation over who belongs – and who does not.
This belonging is both deeply symbolic and substantive, the dividing line between access to resources, ownership of land, and rights to participate, politically, economically, socially. Citizenship also operates as a dividing line between people, foreigners and ‘true’ citizens, diasporas and homelanders, those with passports and those with citizenship ‘at heart’ (a ‘ubiquitous trope’ of how Pailey's interlocutors often describe attachment to Liberia). These fissures all too often run through individual families, deepened by centuries of mobility, of marriage and parentage, and interactions between ‘different’ peoples and legal regimes, of lives that cross, transgress and transcend borders.
Both Citizenship in Africa (Manby 2018) and Development, (Dual) Citizenship and its Discontents in Africa (Pailey 2021) make profound contributions not only to citizenship studies, but also to deeper understandings of international relations, conflict, colonial legacies and systemic inequality. And yet the contrasts in their scope and scale, their methodological orientations and vantages, their completely different yet equally rich source materials, provide an opportunity to interrogate citizenship both from the top-down and bottom-up, from the intricately technical to the deeply personal.
Deftly interweaving thousands of legal documents and secondary scholarship, Citizenship in Africa convincingly makes the case that citizenship and nationality laws are central to political and ethnic dynamics throughout the continent. Within each section of her book, starting with a conceptual and historical overview of citizenship law, Manby first elucidates the regional and international frameworks (and the tensions therein) that underpin the normative dimensions of nationality law; how citizenship was structured within colonial frameworks before independence; and how those in charge adopted, adapted, and altogether revised and reshaped citizenship policy over the past few decades of state building. The book highlights the diversity of policies and practices within contemporary citizenship regimes, from identification rules to naturalisation and statelessness, before a series of illustrative in-depth country case studies detailing extreme examples of exclusionary citizenship policies and practices. The book finishes with a series of conclusions, including thematic patterns, policy recommendations and directions for future research.
To call Manby's book comprehensive is an understatement; she covers practically every legal dimension of citizenship and nationality policy, with examples and vignettes from every country, over a span of centuries. Each page itself is not only packed with empirical detail, the footnotes themselves constitute an entirely separate and engaging counter-melody of thought exercises and a treasure trove of additional primary sources and secondary analysis. This is a reference book invaluable to scholars seeking to better understand the history and politics of particular countries, colonial legal legacies, and to situate Africa within the broader global context of nationality and citizenship regimes.
Where Manby goes broad, Pailey goes deep. Pailey effectively employs a ‘single’ country case study of Liberia, the ‘first African state to devise legal norms around membership and belonging’ (18) (‘single’ is a misnomer here, with fieldwork spanning five countries on three continents) to illuminate how the ‘conception and practice of citizenship across space and time’ (52) is one of ongoing conflict and contestation, especially in contexts of post-war recovery. She insightfully expands her considerations of citizenship beyond (sometimes anodyne) law and policy to ground her analysis in how citizenship is understood, performed and experienced by Liberian citizens themselves. Thus her analysis is rooted in generous interview excerpts from over 200 respondents covering extensive variation of Liberian citizens in relation to the state, from Liberians living in so-called ‘near’ (Accra, Freetown) and ‘far’ (London, Washington) diasporas, to homelanders that never left throughout the recent decades of political instability and violent conflict, as well as returnees. She also interviews Sierra Leoneans for comparative context. Through her interlocutors she develops a rich theoretical framework for contemporary citizenship, as a multi-dimensional concept operating on multiple levels, bringing together identity (passive), practice (active), and a set of relations (interactive).
The heart of Pailey's book are the chapters devoted to unpacking how Liberia's historical and contemporary experiences with conflict, migration, and post-war recovery have been inextricably intertwined with contestations over citizenship, particularly the protracted debate and ‘instrumental tug of war’ over dual citizenship between homeland and transnational Liberians (108–9). Each empirical chapter contains a multitude of insights and analysis, many of which are strong enough to stand on their own accord (indeed, many chapters are based in part on existing journal publications). That said, read together, the entire book provides an integrative and illuminating deep-dive into the nuanced, multi-dimensional, deeply rooted – and contested – experiences and conceptualisations of citizenship in Liberia.
Both books recognise the importance, and value, of understanding citizenship law and policy in its own right. This is an ambitious task, as citizenship policies in Africa are a recipe with ingredients of home-grown histories and also borrowed from elsewhere, legal inheritances of colonisers, layers of conflict, quests for power, and evolving international norms. Both books illuminate the discriminatory and discretionary, how unequal laws and uneven application create strata along lines of race, gender, ethnicity, language and class and how those policies so often are deployed to organise, to classify, to separate who had rights to what and who didn't – the core of politics. Moreover, Pailey's book reveals how citizenship status not only shapes what one can acquire but also what is required, a political economy of belonging, which Pailey eloquently defines as a ‘transactional system in which socioeconomic transformation invariably depends on the provision of privileges/protections in exchange for the fulfilment of duties/obligations and vice versa’ (3).
Historically, what citizenship policies often did not possess, as many scholars from Ekeh to Mandami have articulated, was the glue of national consolidation and collective identity (with few exceptions). Perhaps even more impactful, citizenship policies were not intended to establish connections of accountability between emerging states and citizens; these were policies oriented in exclusion. The lack of accountability was two-fold; ‘subjects’ with little attachment to the state project and rulers with little attachment to serving the public. In Africa, citizenship has operated nowhere near the ‘bundle of civic, political, and social rights’ (Marshall, Citizenship and Social Class, 1950) that has dominated the framework of modern citizenship studies for the past few decades.
Indeed, as the first section of Citizenship in Africa incisively outlines, the origin story of citizenship policy leaves the people out altogether; these laws were the stuff not of vertical connections between state and citizens, but horizontal boundary-making between states themselves. In the parlance of political science, the origin story of African citizenship policies is reflective of the (highly unequal) relationship of states to each other, refracted through the power dynamics of former colonised spaces, and interwoven into the fabric of newly independent states with inherited borders.
Thus it may not be useful to think of citizenship within these contexts as a ‘bundle’ but rather as a lens; a prism to clarify, to magnify, and to illuminate all sorts of dimensions of politics of a particular country, from its unique family histories of settlement and emigration, the centrality and value of land, and the recognition that citizenship policies have often emerged after moments of conflict, whether liberation struggles from colonisers, or internal divisions that have turned violent. Citizenship law is shot through with implicit assumptions and inequalities about who belongs, who is deserving, who is welcome.
Indeed, Pailey views citizenship not only as a signifier of birthplace or legal status but ‘a decision and also an act’ (52–3), as a set of practices of someone who contributes to their country, both through government-citizen channels as well as through citizen-citizen relations. Throughout the book, Pailey employs actor-oriented analysis to great effect, interweaving impressions of citizenship definitions and the centrality of contributions to Liberia with dozens of interviews with homelanders as well as embassy officials and diaspora community representatives and everyday emigrants in Accra, Freetown, London and Washington. She provides ample space for extended quotes from her respondents, allowing the impassioned, the nuanced and the contradictory perspectives to animate her analysis. This approach illuminates the heterogeneity of how citizenship is performed and experienced in a variety of social-economic practices.
Her method is infused with intentionality and rooted in lived experiences, even (and especially) her own; the author's individual perspective is not taken for granted and part of both methodology and motivation (another contrast with Manby, who writes in a more academic, and arguably more distant, style in line with her legal focus). By foregrounding lived experience and individual perspective over content analysis of legislation and policy, Pailey's interviews vividly support her conclusion that Liberians ‘practice citizenship differently primarily based on their social locations and that these practices have a direct impact on the set of relations between the Liberian government and citizens as well as amongst citizens themselves’ (77).
Chapter four is a particularly convincing and devastating account of how crises of citizenship underpinned Liberia's major episodes of conflict, especially how conflict, and conflict-produced displacement, have reshaped perspectives of who can claim ‘full’ Liberian citizenship through the virtue of remaining in-country during the conflict. She deftly navigates the complexities of the ‘both/and’ nature of particular ruptures, for example how Doe's coup ‘ultimately expanded Liberia's citizenship architecture and pried open its political economy of belonging’ with how ‘his subsequent reign as de facto head of state ironically muzzled the political practices of citizens he claimed to have liberated from settler domination’ (121) as well as how Liberia's ‘unprecedented waves of emigration’ both facilitated strengthening of citizen-citizen relations and also undermined them by supporting armed conflict from afar. She effectively argues that the term ‘post-conflict’ is a misnomer for Liberia (and arguably elsewhere), as struggles over citizenship and entrenched inequality remain ongoing.
Pailey's careful considerations of concepts are indeed a highlight throughout the book, beginning with the central theoretical development of citizenship and continuing on through her interrogations of Liberia following the civil wars. In her chapter on post-war recovery and development, she introduces ‘diaspocracy’ to describe President Sirleaf's proclivity to staff government positions with Liberian returnees, building an incisive argument on the dual imperatives of state and nation building, and how Sirleaf's diaspocracy privileged externally implemented state-building at the expense of nation-building.
In contrast, Manby does not further a novel argument or conceptual development as much as provide a meticulously comprehensive and thorough overview of the history and consequences of nationality and citizenship laws in Africa. Depending on the section of the book, citizenship policy is both the outcome variable as well as the explanatory factor animating conflict, inequality, land reform and a host of other ongoing social, political and economic challenges. Yet if one is looking for insights into a particular country's present or past, or a synthesis of key migration and citizenship issues, Manby's book delivers. There is information about the citizenship policies of all African countries (as well as many sub-national units with their own policies), whether briefly mentioned as an illustrative example, as well as different moments over time.
As the structural approach often changes throughout the book – with first sections organised (loosely) temporally, before sections where chapters are organised thematically (interspersed with case vignettes), others with extended state-by-state studies, at times the dizzying level of fine-grained information and amount of temporal and geographic ‘travelling’ one does on every page can leave the reader almost disoriented. This is a book perhaps most useful to not start at the beginning and read cover to cover, but to start at the back, with the excellent index, for a more targeted approach. ‘Citizenship in Africa’ is not a book to be enjoyed once and put back on the shelf; it is a book that should be within easy reach time and time again as a vital reference and resource.
Indeed, reading these books together is an exercise of complementarity and connection. Both Manby and Pailey bring together rich, detailed data from very different sources to cover an underexplored topic within African politics scholarship, with numerous extensions and directions for future exploration. Yet their scope and scale are often almost oppositional at times. The contrast within their discussions of naturalisation is instructive here. Manby provides numerous examples detailing the variation and often obstacle-ridden naturalisation policies within African countries as well as outlining the relative lack of naturalisation across the continent (111–15). In her conclusion she argues that naturalisation should be ‘brought in from the arbitrary cold’, with more attention to streamlining and expanding naturalisation policy as an integral part of citizenship policy reform. Contrast this with Pailey's discussion of naturalisation as ‘betrayer and betrayed’ (163–74), full of fraught and emotional recountings of diaspora Liberians weighing strategic naturalisation in the so-called Global North (and thus having their Liberian citizenship revoked) as well as often rejecting naturalisation because they did not want to betray Liberia and their fellow citizens. Naturalisation as a policy prescription worthy of reform and attention within one approach; naturalisation as contested and complicated personal and community act of identity and claims-making on the other. Both accounts offer invaluable insights into the nuances and complexities of citizenship policy and lived experience.
Together, if explorations of African citizenship are a lens through which to understand how national family histories may be ‘unhappy’ in their own particular ways, Citizenship in Africa and Development, (Dual) Citizenship, and Its Discontents in Africa are incredibly rich kaleidoscopes, offering invaluable, and incredibly different, illuminations of the diversity and ongoing disputes over citizenship and belonging.
