Blaming the system or blaming the victim?
Structural barriers facing Muslims
in Western Europe

W.A. Shadid and P.S. van Koningsveld

Published in: Shadid, W. & P.S. Van Koningsveld (Eds.):
The Integration of Islam and Hinduism in Western Europe,
Kok Pharos Publishing House, Kampen, 1991,pp. 2-21.

© No part of this article may be reproduced or copied without
acknowledgement of the authors  and source

Muslim migration to the industrialized West European countries took place mainly during the fifties through the seventies as a result of the economic and demographic policy of those countries. Since the second half of the seventies, however, labour migration to Europe has become almost impossible due to restrictive measures. Nowadays, migration to this part of the world is only possible for refugees or in the context of family reunion. The migration pattern that has led to ethnic concentrations of Muslims in some European countries was caused, on the one hand, by the colonial past of those particular countries and by their bilateral agreements for the recruitment of labour migrants, on the other. The colonial past of England, for example, has caused an over-representation of Muslims from Pakistan, India and East-Africa. France has stimulated migration from its former colonies both for economic and demographic reasons. The inhabitants of some colonies were allowed to settle down in France without any restrictions. For this reason large numbers of West- and North- Africans, especially Algerians, are living in this country. In the same context The Netherlands have a large group of Surinamese and Antilleans. Belgium, Germany, The Netherlands and, to a lesser extent, Sweden recruited labour migrants form Turkey and Morocco in the sixties and the seventies. England, on the other hand, made use of labour supply from the Commonwealth countries.
As a result of the complex nature of this migration process the nationalities and hence the legal status of Muslims in the various European countries differ considerably. Those having a “colonial background”, like the Muslims from the Commonwealth countries in England, the Algerians in France and the Surinamese in The Netherlands usually possess the English, French or Dutch nationality, often in addition to their nationality of origin. The majority of the remaining Muslim migrants are still merely foreigners, only. In France “One million of the young Beurs have two nationalities, which only complicates their situation without increasing their opportunities. These are Algerian children born in France after 1 January, 1963. They are claimed by Algeria, but also by France, which does not want to lose her nationals” (See Krieger-Krynicki: 1988,124)
Accurate figures with respect to the number of Muslims in Western Europe are lacking. In several of these countries there exists no general, obligatory registration of the religious affiliation of citizens and a great percentage of the second generation of the migrants was born in the host countries. Roughly estimated figures indicate that there are 360,000 Muslims residing in The Netherlands, 2,800,000 in France, 200,000 in Belgium and 45,000 in Sweden. The estimated number for England varies between 750,000 and 1.5 million. Germany has 1,8 million Muslims, of which 80% originates from Turkey (See Gerholm and Lithman (eds.): 1988; Van Esch and Roovers: 1987; Nielsen: RP35,1987; Anwar: 1984,3).
A considerable proportion of Muslims in Western Europe had been recruited as labour migrants for an initial period of one or two years. However, due to the structural shortage of unskilled labour in the host countries in the fifties and sixties, as well as to their legislation concerning foreigners, the stay of these workers became more permanent. The increasing length of the period the individual labourers stayed and the process of family reunion that took place in the seventies are the main indications of the permanent character of their settlement. These facts resulted not only in a growing pressure on the existing infrastructural provisions in these countries, but also made the creation of specific provisions such as mosques and mosque-centered organizations, Islamic schools and Islamic religious education indispensable. The immigrants manifested themselves as Muslims and de facto started to constitute an integral part of the social structure of their host countries. This development also had an impact on the view Muslim migrants held with respect to the part Islam played in their lives. To them Islam no longer was, first and foremost, a religion individually practiced, but increasingly became a factor contributing to a distinct social identity as well, and as such the basis of an Islamic community outside the Muslim world.
The permanent settlement of ethnic minorities in Western Europe also stimulated the discussion on the possibilities and desirability for these minorities to integrate in European society, while at the same time retaining the distinctive traits of their original culture, including their religious heritage. In this respect recommendations have been made by scholars, and policies have been formulated by Governments concerning the concept of a multi-cultural society. A multi-cultural society can be defined as a society in which both native and foreign ethnic and religious groups, together with the essential elements of their culture, are accepted as constitutive parts, and in which this view is reflected in the official Government policy, both in theory and practice.
However, in all of the industrialized West European countries ethnic minorities experience a situation of deprivation. Their low socio-economic and cultural position is reflected by a high rate of unemployment, a considerable percentage of school drop outs, and by poor housing conditions and religious provisions. In explaining the deprived situation of these and other groups, social scientists have developed different approaches such as the “achievement-oriented” versus the “transformation-oriented”, and the “colour-blind” versus the “colour-conscious” approach. The controversies resulting from these conflicting approaches, have led to the well-known methodological dichotomy of the “blaming-the-victim” versus the “blaming-the-system” perspective. The former explains the socio-economic situation of deprived groups by emphasizing their inability to compete for the scarce goods and services in society because they do not posses the necessary intellectual, economic and psychological capacities. Since rewards are directly proportional to the contribution made to society, these groups perforce remain deprived. In the latter perspective the situation of deprivation is primarily seen as a result of the unequalities existing in the existing power relations between majority and minority, which is thought to be characterized by exploitation, oppression and racial discrimination of minorities, resulting in a vicious circle of deprivation. Because the power relations are out of balance, it is believed that this situation, which is basically of a purely socio-economic nature will be transferred to the ensuing generations, unless fundamental changes are brought about in the dominant system, as well as in the power relations between majority and minority resulting from it.
In our point of view, however, the deprived socio-economic and cultural position of minorities in Western Europe has to be explained by the existence of structural barriers which are caused both by the system and by the groups concerned. We thus opt for an intermediate position between the “blaming-the-system” and “blaming-the-victim” approach.
In this chapter we shall attempt to present an overall analysis of the most important social and legal barriers which are encountered by Muslim minority groups in Western Europe in relation to the observance of their religious duties. Needless to say that other important structural barriers, especially those of a more explicitly socio-economic and political nature, fall outside the scope of this chapter, even though they also play an essential part in the daily life of the groups concerned, as well.

Structural barriers
Structural barriers are defined here as obstacles which are neither accidental nor temporary and which restrain equal participation in the host society, including socio-economic mobility as well as the possibility to observe essential religious duties. In other words, structural barriers are factors standing in the way of the emancipation of and of equal opportunities for ethnic and religious minorities and therefore contribute to their economic, social and cultural marginalization. These barriers then serve as a plausible explanation of this marginal position of minorities and of the reasons for perpetuating the dependency of them on the majority.
Structural obstacles are inherent to society, on the one hand, as well as to the individuals and the groups concerned, on the other. The former are reflected in interethnic relations and especially in the form of prejudice, stereotypes and discrimination of ethnic or religious minorities. Furthermore, barriers can be found within the institutional and legal sectors of society, in particular in the discriminating practices and guide-lines of certain institutions and organizations. Barriers inherent to the individuals and groups concerned are traditionalism, deficiency in education and language skills and uncertainty with regard to settlement in a host country. At a group level, factors such as intra- and interethnic and religious diversity and discord, and a lack of organizational unity on a national level, can be considered as structural barriers as well. These factors also play a part in the process of marginalization.

Barriers in society
The relation between State and Church
In order to understand the possibilities and obstacles which Muslims encounter in Europe it is of the utmost importance to pay attention to the relation between the political and religious powers in these countries.
In The Netherlands the principle of freedom of religion and the separation of Church and State are enshrined in the Constitution. The State has no jurisdiction to interfere in any way in the internal matters of communities based on religion or on a philosophy of life. The next important constitutional principle of importance to be taken into account is that of equality and non-discrimination which does not apply to individual citizins only, but to various kinds of groups and institutions as well. Also the religious and philosophical communities and their organizations and institutions have, in principle, an equal status in their relationship to the State. Thus, the marked constitutional separation of the political and religious powers is counterbalanced by the constitutional duty of the State to continue treating religious groups on a basis of equality as well as of neutrality, even though they do remain separated. This balance of constitutional principles crystallized in the so-called “pillarization system”. This typically Dutch system was founded at the end of the 19th century, mainly as a result of a long ideological, political and social struggle between Catholics and Protestants. This system, among others, grants religious groups the right to establish their own infrastructural provisions, such as schools, universities and hospitals, using public funds, but not unconditionally. Non-Christian religious communities can also make use of the possibilities offered by this system.
The Belgian Constitution, on the other hand, offers the opportunity to recognize separate forms of religious worship (erediensten) and the state is then obliged to finance specific costs needed for the maintenance of their infrastructure, in particular the salary of the ministers of religion. The Belgian Government, like that of The Netherlands, also pays the salary of the ministers of religion contracted to offer pastoral support in state institutions such as the army and prisons. In 1974, Islam was recognized as a religion by the Belgian Government. For various reasons, however, the Royal Decree of 1978 for the formation of a committee for the benefit of the management of the religious community has not yet been effectuated.
In England there is no strict separation between Church and State and there exists no system by which the state can “acknowledge” religious communities. On the contrary, the Church of England is the dominant church and plays a central part in the country. The combination of political and religious powers manifests itself in multiple facets of British society. The Queen is both the Head of State and of the Church of England. Religious education of an outspokenly Christian nature is compulsory in state schools and a minister of religion can celebrate marriages which are legally recognized (See Joly: 1988,32). The same applies more or less to Sweden and Denmark where the Lutheran and the Evangelical Lutheran Churches respectively occupy central positions. In France, in contrast to the countries just mentioned, a strict separation of Church and State is enshrined in the Constitution. This, however, does not apply to three of the departments under German rule from 1871-1918. The state is completely neutral (laïque) in religious matters. Just as in the countries previously mentioned freedom of religion is guaranteed by the German Constitution as well. Religious organizations, such as churches and synagoges, are dealt with in German Constitutional Law as Bodies of Public Law (Körperschaften des öffenlichen Rechtes). It is only on the basis of that legal capacity that they can deal with the central State as well as with the Länder and make use of the privileges granted to them by law. This implies, among others, a representative organizational structure.
However, in spite of the separation of State and Church and the secularized political systems, the Governments of all the countries mentioned contribute financially in one way or another to the maintenance of the infrastructural provisions of the religious communities. The form and the amount of this contribution, as well as the goods and services which may be financed, vary considerably from one country to another and in some cases even vary by county or federal state within the same country. In general, the financial contributions entail the defrayment of pastoral activities, a possible tax-rebate or exemption, and subsidies within the framework of the conservation of monuments. In order to be able to make use of such financial contributions and tax-facilities it is necessary in Germany to be recognized as a body of public law, in Sweden as a Free Church and in England as a charity organization (see Hirsch Ballin: 1988).
Though all of the West European countries stress the freedom of religion in principle, they stress, at the same time, that this freedom may be limited by law. In fact, the actual space granted to religious freedom varies from country to country. And it is clear that norms and values of a Christian background (e.g. feast-days and days of rest) are in a privileged position, whereas those devired from Islam have to fight themselves in. The definition of religion is also deeply influenced by the history of each country. In Sweden, for example, Muslims cannot refer to the Freedom of Religion Act, in order to observe Islamic rules concerning dress, slaughtering and the like. Such aspects have nothing to do with religion, according to the Swedish concept thereof.  In Holland the situation is completely different.
As far as Islam is concerned, freedom of religion, in practice, is used in Europe more or less in the sense of tolerance towards the believer(s) observing his/their own individual religious duties. This implies, among others, that there is little or no social and legal space for collective ceremonies such as prayers on Friday and the two main annual Festivals. In most European countries the possibilities in principle existing for Muslims to obtain public funds for various aspects of their religious life, have not been realized yet, due to a number of obstacles to be discussed below. Most of these communities and many of their politicians still consider Islam a foreign religion. They are not yet ready to accept the fact that this religion has become embedded in the social, cultural and political life of their countries.

Guidelines and legislations
Structural barriers for Muslims in European countries differ also with respect to the division of responsibilities between the national and local Governments. The most centralized administration is to be found in France, whereas the other countries to various degrees have decentralized systems. It is therefore possible that in some municipalities the wishes of Muslims will be met with while in others to a lesser extent or not at all.
The naturalization laws are the first obstacle that can be mentioned. The status of foreigner forms a barrier to the emancipation of Muslims in Western Europe. It seriously hinders their participation in some parts of society and impedes them in appealing to some provisions. Some countries, such as England, have even begun “to institute classes of citizenship with less than full rights. On the other hand some countries have sought to involve immigrants by extending to them various forms of voting rights” (Nielsen: 1987: 22).
Political participation and the right to vote for foreigners on a local level exists in The Netherlands and Sweden only, while in Belgium this participation is limited to advisory councils on a local level. Governments of the host countries can also prohibit the formation of political organizations by foreigners if they fear that these organizations will create a disturbance of public life. Neither is it possible for foreigners in these countries to hold public offices or to have jobs with vulnerable bodies of the administration such as the Ministries of Interior, Foreign Affairs, Defence and the like. In Belgium a law of 1921 prescribes the registration of an organization, such as a mosque, as an ASBL (Association Sans But Lucratif) and requires that the majority of the founders should possess the Belgian nationality (See Dassetto and Bastenier: 1985, 68-69). In Germany it is forbidden for foreigners, except for a few exceptions, to even start a business of their own (See Anwar: 1984: 17ff).
Furthermore, beside the differences in legislation with regard to family law between the host countries and the countries of origin, Muslims in Europe have to cope with other barriers which will be discussed below.
Where education is concerned, there are hardly any Islamic schools except in The Netherlands and Denmark. In these countries, 13 and 20 Islamic schools respectively have been founded with public funding. In Belgium only one such school exists, which was established by the Islamic Cultural Centre.There is also no specifically Islamic religious education in public schools in Britain, Sweden, Germany or France. Some of these countries do allow this however if it is given within the framework of supplementary education in the language and culture of origin. However, in The Netherlands and Belgium Islamic religious education at primary public schools has been made possible and is already being provided in a number of municipalities.
Most of the countries have adjusted some of their regulations in order to enable dressing rules at school as they apply to Muslim girls, but at the same time England, France, Belgium and The Netherlands each have recently had their own headscarves-affair.
National and local rules and legislative measures frequently cause difficulties in founding mosques or providing Muslims the opportunities for Islamic burials and their own cemeteries. In this respect, however, it is worth mentioning that the adjustment of some of these guidelines have already been accomplished here and there in each European country. Yet, there is still a need for legally sanctioned guidelines guaranteeing these adjustments and allowing Muslims, for example, to take a day off on their religious holidays. None of these countries offer them the necessary spiritual or pastoral care on a formal basis in state institutions, such as the army and prison. A special committee in The Netherlands has recommended, in this respect, the establishment of a centre of services for Muslims, with four Imams for the army and prison (See Hirsch Ballin: 1988). It is worth mentioning that Sweden is the only country that forbids ritual slaughtering without pre-stunning.
Policy of national and local governments
As has been indicated before, European Governments were forced to adopt a restrictive migration policy for economic and social reasons. This policy has been supported by various political parties and pressure groups in society, including those for foreigners. Furthermore, many negative statements have been made as well as measures proposed concerning the position of foreigners in these countries. In this regard the restrictive immigration laws and measures, and despite the terminology used, the policies of assimilation are the most important ones. The statement of the French Minister of the Interior that Algerians should be considered “as foreign workers and not as immigrants, and that consequently the children born in France should not get French citizenship automatically” is also indicative in this direction (See Krieger-Krynicki: 1988:124). Other measures which have affected the views of the indigenous population on foreigners unfavourably are the remigration and assimilation policies of these countries. These policies and statements reflect a signal of the non-acceptance of foreigners and tend to create problems for them in the encompassing society.
The negative attitude of local authorities to foreigners can be illustrated by their hesitation towards and their refusal to permit the foundation of Islamic schools in The Netherlands and Britain respectively. Though the Constitution in both countries permits the foundation of such schools, local authorities in The Netherlands have formulated many doubts in this respect, while the British local authorities have not allowed them at all so far. It is argued that such schools will inhibit integration of the second generation of immigrants with the result that their possibilities to emancipate in society will be minimalized. The fact that so far 13 Islamic schools in Holland have become operational is due to the constitutional freedom of education. Local authorities had no legal possibilities to stop such schools. Moreover, the refusal of the German authorities to recognize two Turkish Muslim organizations as a 'body of public law' can also be considered a structural obstacle and an indication of the negative attitude of local authorities. This refusal makes it impossible to give specific Islamic religious education at the German schools, other than that which is incorporated in the supplementary lessons on the children's own language and culture (See Shadid and van Koningsveld: 1989; Nielsen: 1984:14; Thomä-Venske: 1988:81ff).
This negative attitude of local authorities in Western Europe is not merely a consequence of the existing prejudices and stereotypes regarding Islam. The attitude of some political parties and civil servants towards religion in general also plays a vital part. The integration of Islam within the regulations and legal structures of European countries largely depends on the general attitude of these secular civil servants. Their secular attitude, however, is hardly a hindrance to the infrastructural provisions for Christian groups, because the rights and privileges of the churches have been fixed in the course of a long historical process resulting in various kinds of direct and indirect financial assistance from the Government. These agreements and responsibilities are the result of a long historical process and are enshrined in the Constitutions of most of the countries mentioned.
Another factor of importance in explaining the negative attitude of officials towards Islam is their lack of knowledge of this religion, in general, and of the structure of Muslim communities in their host countries, in particular. This lack of knowledge stands in the way of an adequate reaction to the wishes of and the developments within Muslim communities. In this respect we should mention the decision of Dutch local authorities to accommodate a club for homosexuals in the same building where a mosque had been accommodated, as well as their reaction to the wish of Muslim girls to wear Islamic dress at schools (See Shadid and van Koningsveld: 1985, 1986).

Prejudice, stereotypes and discrimination
Direct and indirect discrimination may be the major obstacles impeding the emancipation of ethnic minorities despite the fact that the constitutions of all of the European countries include laws against racial discrimination. Although techniques are lacking which measure to what extent institutional and direct discrimination are detrimental to religious minorities, the influence of such discrimination is obvious. The nature, origin and interrelations between prejudice, stereotypes and discrimination have been approached from various perspectives and numerous theories have been formulated (See Elich and Maso: 1984, Essed: 1989). In this context it is more important to pay attention to the question why discrimination against ethnic minorities, in general, and against Muslims in Europe, in particular, has increased rapidly in the last decennia. This process is evidenced by protests against the foundation of mosques, Islamic schools and the rise of fascist groups and parties. The answer to this question has to be sought in a combination of a number of factors.
First of all, their is the drawback in the economies of Western countries. Even if there is enough to share with 'outsiders', latent discrimination still  exists. It becomes more manifest, however, when in various sectors of society scarcity emerges. Ethnically different citizens are then considered unlawful competitors.
A second factor, in this respect, is the ever increasing visibility of Muslims and their infrastructure in the encompassing society due, among others, to the emphasis they put on maintenance of their social and cultural identity. It is beyond any doubt that feelings of superiority of Western norms and values are in conflict with this goal expressed by Muslim groups and generates anti-foreigner feelings, not only in those economically threatened but also in other groups in society. Research in Germany at the beginning of the eighties pointed out that 50% of the Germans have anti-foreigner feelings. This group consists mainly of retired persons, housewives and poorly educated people (See Kreiser: 1985,14). The increase of anti-Islamic pamphlets and the defacing and destruction of mosques as a reaction to the so-called Rushdie affair in The Netherlands and during the Gulf War in Britain are also obvious examples pointing in this direction. The cry for a mono-cultural society was heard more loudly, without any resistance worth mentioning. Islam and Muslims were considered a danger and a threat for Western principles and democracies (See Van Koningsveld and Shadid: 1989,12). With respect to Belgium it should be mentioned that the fear of Muslims is caused by the fact that “public opinion obviously does not make a fine distinction between that which derives from the cultural and religious traditionalism of the population of Muslim origin, and that which derives more explicitly from a religious radicalism with political overtones that could be classified as 'fundamentalism', or better as 'Islamism'“ (See Bastenier: 1988,141). However, it is not primarily the fear of fundamentalism that causes the negative feelings against Muslims in Western Europe. It is above all the clash between the feelings of superiority of the Western cultures held by the indigenous population and the signal that originates from the desire of Muslims to retain their identity which creates negative feelings and discriminatory practices. Common people by referring to militant and violent activities of Muslim fundamentalist groups try to rationalize their negative feelings, which have thus become manifest. By referring to the worldwide acts of violence caused by Muslim fundamentalists, the manifestation of negative feelings becomes socially acceptable. Where Sweden is concerned, the present anti-Islam reactions are sought in the history of Swedish society. Up to a few decades ago, this country was ethnically and culturally, as well as religiously, a homogeneous society that tried to protect itself from foreign influences. Despite their modern secular image Swedes still view Christianity as being central to their national identity.
The negative image of Islam in European countries is partly caused and maintained by education at schools. Research on the image of Islam in school-books in Germany has pointed out that the views expressed are inadequate and ethnocentric. “There are some major types of unsatisfactory and defective statements, omissions of basic and essential historical facts and above all misleading interpretations and opinions” (Tworuschka: 1986:16).
Research in The Netherlands and England also indicates that school-books present an unfavourable view of the Third World, in general, and of Islam and Muslims, in particular. The information given is often partial, irrelevant, ethnocentric and stereotyped. The same is true of France. The image of Islam presented in France is often caricatural and creates an obstacle to understanding and dialogue. Islam is considered as a new religion “with a God: Allah who would be just as much a stranger to the Jewish-Christian tradition as the Roman Jupiter...” (Garaudy: 1984:27; see also Van Dijk: 1986; Klein: 1985; Van den Berg en Reinsch: 1983; Reinsch: 1987).

Racist groups and parties
A clear indication of the increase in the informal discrimination of foreigners in European countries is the electoral success of the ultra-right groups and parties in the past few years. These parties have elected representatives not only to the national parliaments but also to the European Parliament. Furthermore, violence against foreigners and their infrastructure is becoming a frequent phenomenon in most of the European countries. For a general view on these groups and parties and their history we refer to the existing literature (See Anne Frank Stichting: 1985,1988). These groups advocate a propaganda of hatred against foreigners. In this context they use the ancient policy of the scape-goat in which minorities are held responsible for the problematic economic situation in Western Europe. Nowadays, the slogan 'our country is ours alone' is heard in all of the European countries. One of the ultra-right groups in The Netherlands has in its propaganda created a view of Islam as a system of norms and values that is hostile to and totally inconsistent with the Dutch tradition (See Van Koningsveld and Shadid: 1989,134).
In the long run, and if appropriate measures against the ideas and practices of such groups are not taken, discrimination of Muslims will no longer be a taboo, a situation which will result in a further increase in discrimination. Moreover, the institutionally and structurally adverse effects on minorities, in general, will then increase considerably, especially if other political parties should tolerate these groups or use some of their ideas for electoral reasons.

Barriers inherent to the groups concerned
Barriers which impede the emancipation of Muslim groups and maintain their marginal position in European countries are not only imposed on them by host societies but are also caused by the individuals and groups concerned. Some authors consider the wish of ethnic minorities to preserve their culture in host societies to be a structural barrier to the socio-economic emancipation of these groups. In this connection reference is made to Muslim parents who do not allow their daughters to acquire a higher education because the educational structure in Europe is not in accordance with Islamic guide-lines. It is questionable whether Islam and Islamic rules can be held responsible for the attitude of these parents. Other factors such as traditionalism, social environment, socio-economic motives and an interest in education in general, and in particular for girls, are more important in explaining this attitude. These factors indeed form an obstacle to social mobility. However, preserving their own culture, as such, can also be a barrier to the socio-economic mobility of individuals, if the society they live in is intolerant. In this context it is rather a system-bound barrier. The solution should then not be sought in rejecting the group's culture but in taking effective measures to reduce intolerance in society. Intolerance, actually, is an 'ongoing' process, which means that an intolerant society will always find a negative characteristic to justify its intolerance. Referring to the preservation of culture as an obstacle to the emancipation of ethnic and religious minorities, therefore, fits in with the ideology of the perspective of 'blaming the victim' while the 'blaming the system' approach is more appropriate in this context.
In the following paragraphs attention will be paid to a number of structural barriers which are inherent to the groups concerned and which impede their emancipation in Western Europe. Such barriers are, first of all, their ethnic and religious diversity and, secondly, the lack of adequate representative organizations.

Ethnic and religious diversity
Beside the enormous ethnic diversity, we find among Muslims in Europe a religious diversity which is similar to that in the countries of origin. Apart from the major, Sunnite and Shi'ite, streams we find adherents of 'sects', such as the Ahmadis and the Alevis, whose beliefs are rejected by those of the major streams. Moreover, among Muslims in Europe a distinction can be made between mystical orders (tariqa's) and religio-political movements. The former are represented by orders such as the Qadiriyya, Naqshbandiyya, Darqawiyya, Alawiyya and the Chistiyya. The religious-political movements, on the other hand, emerged before and during the decolonization process of some Muslim countries and aimed at reintroducing Islam as a foundation for the state. Some of them originate from the reformistic movement that was introduced in Egypt under the influence of scholars such as Muhammad Abduh and Rashid Rida. One of these movements is the so-called Salafiyyah, whose goal is to modernize Islam by renewed research into its classical sources, viz. Quran and Tradition, and which still plays a prominent role in the official policy of the Moroccan state. Both the modernistic and conservative offshoots of this reformistic movement play an important role among Muslims from North Africa and the Arab world in general, living in Western Europe. Other religious-political movements are the Nurci's, Sulaymancis and the Milli Görüs from Turkey. These movements have been forced into opposition as a result of the secular state introduced by Atatürk and they are represented in most of the West European countries, with head quarters in Germany. The Deobandi and Barelwi movements as well as the Jamaat-i-Islami from South Asia, are the most important ones among Muslims from India and Pakistan in England and elsewhere (See Shadid and Van Koningsveld: 1990,23).
The ethnic and religious diversity and rivalry leads to a disruption of the initiatives aiming at the realization of the infrastructural provisions needed by Muslims. In each West European city there are numerous mosques and mosque-associations which were founded on private initiatives, in some cases with the help of international Muslim organizations or of the Governments of the countries of origin. It is not only the theological differences that play a fundamental part in this diversity of mosques and organizations. Political as well as regional differences are also of great importance. The development of organizations is influenced significantly by the regulations for subsidies and specific legislation in the individual countries. Estimates indicate that there are 300 mosques and prayer-halls in The Netherlands, 130 in Belgium, 600 in England, 912 in France and 800 in Germany (See Kepel: 1987,228; Joly: 1988,37; Bastenier: 1988,136; Anwar: 1984,19ff; Krieger-Krynicki; 1988,128). Each mosque is based on and administered by a local organization. The local organizations are mostly clustered on a national level in so-called master-organizations based on ethnical origins, theological streams or political affiliations or a combination of these. In the course of time many initiatives have been taken in the various countries to cluster these diverse organizations into one central representative body for Muslims. For France it is stated that “In recent years, Muslims have struggled for the creation of a central representative body of all the Muslims in France [.....] Up to now, however, this enterprise has not been successful, the Muslims being separated in several rival tendencies” (Nielsen, Research papers, no. 35,1987,29)
In The Netherlands such a central organization, the National Islamic Committee, which combines 90% of all Muslim organizations, has been founded as a result of the developments around the so-called Rushdie affair. The Dutch Government has not recognized it as such. However, this Committee has been dissolved recently in order to pave the way for a National Islamic Council.
Belgium is in a slightly different situation because of the existence of the 'Islamic Cultural Centre of Belgium', which maintain ties with the Muslim World League and is mainly financed by Saudi Arabia. The Belgian Government granted this centre a monopoly position as the organization representing all the Muslims in Belgium, when Islam was recognized in 1974. Because of “the existing rivalries concerning the exercise of religious leadership within the Muslim community”, this recognition has resulted in the foundation of other central bodies, and the same pattern of a plurality of central bodies is to be observed in England, Germancy and France (Bastenier: 1988,139ff; Van Esch and Roovers: 1987,50; Nielsen: 1984,12; Thomä-Venske: 1988,82).

Activities of the Muslim organizations
The majority of the Muslim organizations is mainly of a religious and socio-cultural nature. Their activities primarily aim at creating a more or less stable religious and social infrastructure for Muslims, and in that respect at adjusting the national legislation in host societies in order to allow Muslims to comply with Islamic requirements. In the majority of these countries this has been achieved to a certain extent, insofar as ritual slaughtering, mosque-schools, religious education and the like are concerned. Even though these organizations undeniably provide necessary activities, their diversity and one-sided orientation limit their prospects in achieving socio-economic and religious emancipation within the various societies. The ethnical and religious diversity of these organizations, as well as their being focussed on their countries of origin, not only weaken their position in relation to their host Governments but also impede these particular Governments in applying one and the same policy with regard to Islam. The negative impact of this ethnic and religious diversity is most evident in Belgium. The law by which Islam was recognized has not yet been effectuated due to the lack of consensus among the different Muslim communities in this country. “The diverse national origin of the Islamic immigration to Belgium, as well as the contemporary ferment throughout the Islamic world and the struggle for power in various Muslim states, may be seen to have repercussions in Belgium principally in the form of tendencies which deny sufficient legitimacy to those Muslim leaders with whom the Belgian Government has had its dealings. Together, these difficulties seem to have brought about a paralysis of the legal process” (Dassetto and Bastenier: 1985,8). In other European countries the situation is just about the same, which, to a large extent, explains the fact that the Governments of the countries of origin still extant their influence on Muslim communities and their welfare in Western Europe.
Only through unified initiatives and the formation of their own politically conscious organizations extending across the ethnic boundaries will Islamic communities be able to succeed in improving their socio-economic and religious positions in the host communities. In practice we see, however, that initiatives to unify organizations with different goals, of a political, cultural and religious nature, under one and the same master organization do not succeed. The foundation of the Turkish Community in Berlin, may be mentioned as an example. “Internal disputes at the beginning of 1986, however, led to the withdrawal of the Islamic Centres and the Islamic Federation from the Turkish Community. As a national organization, the Turkish Community has taken a laicistic and pluralistic stand on religious issues “ (Thomä-Venske: 1988,82).
The lack of qualified potential and financial means
Another barrier is found in the lack of financial means and qualified potential for the creation of an appropriate infrastructure. Because Islam in Europe is a relatively new phenomenon and Muslim communities consist mostly of members of a low socio-economic status, there still remains an enormous need for money to set up a complete infrastructure and to catch up with the Christian religious provisions which have existed for centuries. Some larger Muslim religious organizations receive financial support from the countries of origin as well as from other Muslim countries, such as Saudi Arabia and Libya. However, this financial aid is meant mainly for the establishment of new mosques. The salaries of the imams and costs of other needs have to be paid from the contributions of the individual members, which is minimal. It is only the Turkish Government which sometimes pays for the imams. In some cases, such as in Sweden, Muslim religious organizations receive financial aid from the host Government. In The Netherlands such organizations on a local level obtain a small subsidy from the authorities for their socio-cultural activities.
Furthermore, the Muslim communities, especially in The Netherlands, Belgium and Sweden lack qualified leadership for the administration and management of their organizations. The majority of the contracted imams, with the exception of those who are sent by the governments of the countries of origin, have a modest religious education. The same is true of the imams working as volunteers. In Belgium 18 of the 23 Moroccan imams have only the Quran-school. Furthermore, the rector of the 'Big' mosque for Algerians in Paris, who has been sent by the Algerian authorities, does not speak French (See Dassetto and Bastenier: 1985; 104; Kepel: 1987, 313ff). Because of these shortcomings the imams are mainly confined to performing their 'internal' functions and are incapable of establishing intercultural and interreligious contacts. Another shortcoming is the fact that the management committees of these organizations consist mostly of volunteers who have neither the time nor the capacity to formulate a broader policy and to keep up functional contacts with the society they live in. The maximal use of the possibilities offered by the legislation of a host society is moreover impeded due to ignorance of their existence. The lack of qualified  leadership forms also a structural barrier to the flexibility in theological thinking and knowledge of the various interpretations and possibilities that to be found in Islam itself.

The 'temporary' character of settlement
Another structural barrier is the type of migrant one is dealing with. As has been previously stated, Muslim religious groups display an enormous variety in their legal positions and, as a consequence, also in their orientations towards and future prospects within their host communities. Labour migrants, in particular, are more oriented towards their countries of origin and usually consider their stay as being temporary, whereas the actual situation indicates a permanent settlement. Because of this attitude they shrink from considering the host society their own and from associating with political and other organizations. Consequently, their participation in the decision-making process, which is necessary for their socio-economic and religious emancipation, is often lacking. This idea of temporary settlement also constitutes a major impediment to taking long term initiatives regarding the creation of their own religious infrastructure; for their willingness to apply for citizenship and for reducing the aforementioned influence of their Governments.
To illustrate the impact of this barrier we may refer to the comparison between Algerians, on the one hand, and Tunisians and Moroccans in France, on the other hand. Where the latter are concerned we are dealing “with a more recent immigration, less integrated into the French system and more marked in various ways by the culture and society of the country of origin. The Tunisians seem, to a larger extent, to have been single migrants, to have a strong belief in the return to their country and to share, at the same time, a certain secular view of society which makes the French model more acceptable” (See Leveau: 1988,110). The same is also true of the Turks in Germany, Belgium, The Netherlands and Sweden. For the next generations of these migrants in Europe, a secularization process may be expected. This will not automatically imply that the value of Islam will vanish for them. On the contrary, it can be argued that despite the existing differences in the perception of Islam, their Islamic background will increasingly become a common-identity symbol to these migrants, differentiating them from the hostile society surrounding them. In other words, Islam will come to the foreground, not as an entity of religious rituals and behavioral rules, but as a symbol of a separate identity. 
Influence of the countries of origin
The countries of origin, in particular Morocco and Turkey, are trying to retain their grip on their citizens in host countries. The influence is directly maintained through the 'Turkish Presidency of Religious Affairs' and 'The Cultural Mission of the Moroccan Embassy'. The former also has an attache for religious and social affairs at the Turkish Embassies in some countries. Their activities mainly entail the appointment of teachers for religious education and supplementary education in the language and culture of origin, support in founding mosques and the appointment of imams. Both countries have tried to retain their influence and grip on their citizens abroad, also through other organizations such as the Moroccan 'Amicales' and the Turkish 'Grey Wolves'. Because both Turkish and Moroccan law prohibit the formation abroad of political parties or branches of those in existence, cultural or religious associations are founded as a substitute (See also Dassetto and Bastenier: 1985,17ff; Van Esch and Roovers: 1987,79).
The Turkish Government therefore creates or promotes specific cultural and religious associations abroad in order to reduce the influence of these oppositional movements. The Turkish Islamic Foundation in The Netherlands (ISN) and The Turkish Islamic Cultural Federation (STICF) are the kind of organizations which advocate Islam as furthered by the Turkish Government. Their main activities are focussed on the emancipation of the Turkish community in the receiving countries with emphasis on the Islamic-cultural identity. These goals are reached through activities such as the foundation of mosques, the appointment of imams and teachers for Islamic religious education and the foundation of the so-called Islamic schools in The Netherlands.
The groups abroad are moreover influenced directly and indirectly by international Muslim organizations, such as the Muslim World League, as well as by religious and political developments in their countries of origin. The re-islamization process as a resistance ideology, spreading among Muslim intellectuals in the countries of origin as well as abroad, leads to greater interference from the governments of these countries. To a certain extent, the re-islamization process is responsible for both conflicts and heterogeneity among the religious organizations abroad.
The direct influence of the Governments of the countries of origin can also be illustrated by the interference of the King of Morocco who requested the Moroccan community not to participate in the municipal elections in The Netherlands in 1986.
In the previous paragraphs an attempt has been made to systematize structural barriers at various levels and to elaborate their impact on the deprived position, of Muslim groups in Western societies, as far as religion is concerned. It is, however, far from easy to draw general conclusions regarding these structural barriers and their impact on the emancipation of Muslims in Europe. Muslim communities meet with different situations in these countries, some of which are the result of long historical processes. They have to fight their way into various legal frameworks and to deal with all kinds of guide-lines and legislation. Therefore, they cannot make use of the experiences of similar Islamic groups in other countries and sometimes not even of experiences in the same country. The major differences between the individual host countries concern the following:
The relation between the political and religious powers or between Church and State. The responsibilities the governments have towards religious communities and their infrastructure show considerable diversity.
The extent of decentralization of the political power. There are differences in the relations between national, local or federal governments and in the distribution of administrative and political responsibilities.
The legal status of migrants in the host countries and the opportunities granted by legislation to foreigners also show considerable differences where the various countries are concerned.
The comparative approach presented in this chapter clearly indicates that in order to stimulate the emancipation process of minority religions in Western Europe, first of all activities will have to be undertaken to eliminate the influence of barriers existing in the system or in society at large. We see that in countries where system-bound barriers are less prominent the process of emancipation is in progress more than in other countries where similar or comparable group-bound barriers exist. This justifies the conclusion that the society-bound structural barriers form the main impediment to the emancipation of minority religions in these host communities.
We agree with the statement that “It is only in considering Islam as one of the permanent constituents of the social, religious and political system of Europe that it will be possible to escape from the ambiguities characterizing the present situation of immigrants” (See Leveau: 1988,121). But whether the inevitable outcome, namely violence “which has already occurred in some reactions and practices of a socially marginal nature- violence on the part of the immigrants as well as the dominating society” (See Leveau: 1988,121). can be avoided is doubtful because of the other above-mentioned barriers. The elimination of these society-bound barriers is in our point of view a necessary but not a sufficient condition to effectuate the emancipation of these groups and to realize a multicultural society or a variant of it.
In order to achieve the emancipation of ethnic minorities host countries will have to adopt specific policies to fight prejudice and discrimination and to adjust legislation, while Muslim communities will have to strive for oecumenical processes of unification of their initiatives.
On the other hand, the impact of the other, group-bound, barriers will, we believe, decrease considerably in the next two or three decades to come. Ongoing naturalization will decrease the influence of the countries of origin and these groups will be increasingly oriented towards their new fatherlands. A comparison between the educational level of the first and second generation of Muslim migrants also justifies the conclusion that in the long run they will acquire a significantly qualified potential. Moreover, many initiatives have been taken to change the system-bound barriers, and a number of these changes have actually been realized in different countries. From past and present situation we can learn that the emancipation of the various Catholic and Protestant groups in Europe was guaranteed best by constitutional measures.

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