The effect of veiling/unveiling of a Muslim woman upon her personal agency in the process of implementation of the policy of State Neutrality and Islamic Fundamentalism by - Shreya Chaudhary

The effect of veiling/unveiling of a Muslim woman upon her personal agency in the process of implementation of the policy of State Neutrality and Islamic Fundamentalism. -Comparative Study between France and Iran

            Authored By- Shreya Chaudhary

The veiling of a Muslim woman is an intrinsic part of the central discourse in the Western world that pertains to the apparent threat of Islamic Fundamentalism. In the same vein, it remains an inherently significant and revered part of the East and densely populated Muslim regions that are deep-rooted in tradition of Islam. Subsequent to the September 2001 attacks, the idea of a Muslim woman to both support a ‘violent’ religion as well as to themselves be a ‘subordinate’ member of the same religion has gained currency in the West.[1] A veiled Muslim woman is often accorded by the West to be subdued, victimised, and without personal agency. Unveiling her is understood to set her free from the shackles of a constricting and violent religion. However, the idea of a veiled woman is disparate across the world. Within the Iranian context, the concept of veiling of a Muslim woman is embedded in their deep-seated ideology and politicisation of Islam. It can be construed that the reality of an Iranian Muslim woman is ensnared with the notion of coercive veiling.[2] This dichotomy relating to the veil exists in a kaleidoscopic nature continually interacting with all ambits of a Muslim woman’s life including the employment sphere, and its norms for a Muslim woman ultimately having a significant bearing on personal agency of a Muslim woman. This paper aims to assess the position and effect of the ubiquitous veil upon the realities of a Muslim woman, within the French and the Iranian contexts, specifically at the workplace, due to the broader persisting principles of state neutrality and Islamic Fundamentalism in these two distinct ideological and political structures respectively. We will observe how even in distinct contexts, irrespective of the varying discourses on veiling, they continue to dictate and reduce the identity of a Muslim woman to a subject incapable of personal agency.

Insight into the evolution of the ‘veil’ in France.

In the year 2004, the French Parliament passed a law prohibiting the conspicuous display of any religious symbols in schools. The ban was passed by a vote of 276 to 20 in the French Senate and by 494 to 36 in the French National Assembly, after which it was signed into effect by then President Jacques Chirac.[3] This ban encompassed ‘obvious’ religious symbols like the Jewish Kippa and Christian crosses. The ‘hijab’ and veiling were observed as a mechanism of strong religious commitment.[4] Prior to this ban, schools had the autonomy to decide if they wanted to ban hijab which led to debates regarding schools that prohibited the use of hijab. Consequently, the wearing of ‘obvious’ religious symbols at all public schools was banned unleashing protests and debates in Europe especially among Muslims living in other parts of the world and France.

In the year 2011, another law passed that barred covering of face in French public places.[5] This ban encompassed attire ranging from helmets to full body coverings including burqa worn by women- a face veil worn by Muslim women. These two bans were upheld by multiple French officials and citizens as advancement of the principle of secularisation known as Laïcité.[6]

The European Court of Human Rights (hereinafter referred to as ECtHR), which is not bound by its prior decisions due to disparate political, social, economic contexts of different European countries has somehow fallen back on upholding similar legal reasoning with respect to veiling. In Sahin v. Turkey[7], the ECtHR found that Turkey’s ban on headscarves in universities did not violate Article 9[8] of the Convention because the ban was necessary to protect the “rights and freedoms of others” and to protect the “public order.”

Similarly, in the case of SAS v France[9] assessed French law which banned the wearing of clothing that covered the face while in public spaces and if it was a violation of the protected rights enshrined in the European Convention on Human Rights (ECHR). The French citizen, but a devout Muslim woman contended that the ban was discriminatory under Article 14 of the ECHR[10], and that it impeded upon her private life protected under Article 8 of ECHR. She further asserted that the ban was in violation of Article 9 of the ECHR that protects the freedom to manifest one’s religion or beliefs[11], and that it was a clear violation of freedom of expression under Article 10 of ECHR.[12] Her contention was that her choice to wear her niqab was based on her spiritual feeling at the time and she was cognizant of the need to remove the same for formalities like at banks, during security screenings or other circumstances where identification is significant. Although the court rejected the arguments by the State pertaining to public safety, on which the Court ruled that a blanket ban was disproportionate, and that the ban was necessary to uphold gender equality as a State Party cannot invoke gender equality in order to ban a practice that is defended by women – The court in the present case held that there was no violation of Articles 8, 9, 10, and 14 of the ECHR. It opined that the law had the legitimate aim of ensuring the respect for the minimum requirements of life in society, namely the French principle of “living together” and recognized that countries have a wide margin of appreciation when regulating such matters. The principle of ‘living together’ is tied down with the french principle of Laïcité, as religious distinction and lack of neutrality can act as hindrance in of harmoniously coming together of French people.

Principle of Laïcité.

This principle denotes the separation of church and state as the means to ensure national integration and peace. The secular identity of the French is based on maintaining religious neutrality in its civil society. In consonance with this principle, the donning of ‘obvious’ religious symbols can be construed to be antagonistic to Laïcité harbouring diverse and public religiosity that may cause hindrance with national integration. The French constitution explicitly states that Laïcité also incorporates the individual's right to religious freedom and the equality of all citizens irrespective of their origin, race, or religion. The right to equal treatment despite religious conviction principally presents a challenge to the prohibition of religious symbols in public schools.

The application of laicite reveals that there are deep ambiguities in relation to the multi-layered connotation of this concept. For instance, it can be contended that the 2004 and 2011 bans strayed from the contours of the Laïcité that revolves around the exercise of religious neutrality by the public officials and the State.[13] Such actions of neutrality are not essentially meant to be carried by ordinary citizens under the French legal system thereby distorting the concept. In the same vein, Laïcité is often understood as a commitment of passive neutrality and non-intervention within the private religious realm of an individual. For some it can be perceived as an overriding obligation to uphold and protect secularism. However, these bans hinted towards the principle of Laïcité getting translated into a coercive removal of hijab.

The Veil and the Policy of Neutrality at Workplace in France.

It is also instructive to note that in pursuance of this belief the effect of same has seeped into workplace setting of a Muslim woman. In February 2014 a privately-owned French company claimed to have become the first in the country to ban the wearing of Muslim headscarves and other prominent religious symbols at work. The 4,000 workers at recycling company Paprec, based in the Parisian suburbs, were no longer allowed to demonstrate their religious faith by wearing items like the Yarmulke/Kippah (the Jewish skullcap), Christian crosses and Muslim head or face covers.[14]

In the year 2017, the European Court of Justice welcomed a ruling allowing companies to ban staff from donning ‘visible’ and ‘obvious’ religious symbols. In the present case, Samira Achbita[15] had been a receptionist for the Belgian branch of G4S, the London-listed outsourcing and security company when, after three years at the firm she decided she wanted to start wearing a headscarf at work for religious reasons. Achbita was fired in June 2006 for refusing to take off her scarf. The company said she had broken unwritten rules prohibiting religious symbols.

In the second case, Asma Bougnaoui[16], a design engineer, was fired from an IT consultancy firm, Micropole, after a customer complained that his staff had been “embarrassed” by her headscarf while she was on their premises to give advice. She had been told before taking the job that wearing a headscarf might pose problems for the company’s customers.

In Achbita’s case the ECJ followed the advice of a senior legal adviser to the court, who argued that companies should be allowed to have policies banning the wearing of religious and political symbols. “The court of justice finds that G4S’s internal rule refers to the wearing of visible signs of political, philosophical, or religious beliefs and therefore covers any manifestation of such beliefs without distinction. The rule thus treats all employees to the undertaking in the same way, notably by requiring them, generally and without any differentiation, to dress neutrally.”

In Bougnaoui’s case the court’s adviser had ruled that she had suffered discrimination. She had been “professionally competent” and sacked only because she had refused to remove her headscarf, the advocate general advised. The court upheld this view with a less ringing endorsement. It said customers’ wishes not to be served by a worker wearing a headscarf did not give companies a get-out clause from EU anti-discrimination law.

The CJEU ruled in Samira Achbita and Asma Bougnaoui, that the prohibition on wearing an Islamic headscarf in the workplace does not constitute direct discrimination based on religion if the prohibition stems from an internal organisational rule prohibiting the visible donning of any political, philosophical or religious symbols. However, such a rule can constitute indirect discrimination if it results in a disadvantage for persons adhering to a particular religion, unless the rule is objectively justified by a legitimate aim and the means of achieving that aim are appropriate and necessary. The CJEU notably ruled that the desire for a private company to project an image of neutrality towards its customers is legitimate

It is instructive to note that the United Nations Human Rights Committee (UNHRC) has in a catena of cases held a different perspective pertaining to such bans. In the case of F.A. v France[17], wherein an educational childcare centre employee was fired for violating the centre’s policy on secularity and neutrality by wearing an Islamic veil. The Cour de Cassation found that the restriction on the freedom to manifest one’s religion as set down in the centre’s internal regulations was sufficiently precise, justified by the nature of the tasks performed by the employees of the association (i.e., caring for young children who are naturally predisposed to influence) and proportionate to the aim pursued. The applicant brought a complaint before the UNHRC, asserting a violation of Article 18 (freedom of religion) and 26 (prohibition of discrimination) ICCPR.

In its decision, the UNHRC rejected France’s contention, finding instead a violation of the applicant’s freedom of religion and discrimination based on the employee’s gender and religion. The Committee stressed that the restriction was not objectively justified, nor was a proportionate measure.

It is essential to contemplate if the regulations, with respect to the prohibition of hijab, are implemented across various European countries because they are all concerned about the lack of integration or if it is the fear of the spread of Islamic fundamentalism in Europe assumed to be symbolised through Muslim women's dress. The Western perception of veiling and its subsequent established policies create a link between veiled women and Islamic fundamentalism. There is a tacit assumption that the more veiled women in the streets, the more power to the Islamic fundamentalists.

The racial and national identity crisis in Europe is a reality. This implies that not only is a "foreign" religion seen as alienating, but also race is an indicator of "otherness".

Immigrants will always be seen as immigrants, no matter how assimilated or integrated they are - and veiled Muslim women symbolise an immigrant "other" most starkly in the French national imagination.[18] However, many Muslims themselves argue that, in fact, Islamic ideals can coexist with European values. This mandatory unveiling of a Muslim woman explicitly contravenes the Right to manifest one’s religion or belief under Article 18(1) of the ICCPR and General Comment 22 of the Human Rights Committee that observes display of symbols as freedom to manifest one’s religion or belief. This distinct perception of Muslim women and their otherness, which through unveiling according to the West helps reinforce autonomy in women has managed to deprive them of the agency to follow their spirituality and belief of donning a veil and wearing what they desire.

Veiling in Iran

Veiling in Iran is embroiled within the political system and gender principles. However, the hijab has witnessed a tumultuous journey in Iran. The first attempt to use hijab as the subject of legislation was by a new monarch, Reza Shah in 1936 who wanted to force women to remove the veil in public under his unveiling order. Shah’s vision of modernity, inspired by Turkish leader Mustafa Kemal Ataturk, included changing what Iranian women wore. There was no essential drive to establish an Islamic state moreover, his motivation could be directed towards a westernisation programme. Therefore, Shah’s coercive unveiling of women was also entangled in a greater agenda of transitioning to Westernisation.[19]  For the anti-Shah revolutionaries, the concept Gharbzadegi (Westoxification) was used to characterise their disillusionment with the Shah's process of modernisation and was advocated by secularists and Islamists alike." The term alludes to the alienation felt by many Iranians concerning the implementation of the Shah's version of Westernisation. It reflects the rejection of this type of administration and the dissatisfaction with the reformation that had taken place during the Pahlavi era. The concept of Gharbzadegi also subsequently became a way to describe women influenced by what was perceived to be a degraded Western-type morality. Accordingly, the gharbzadeh woman encompassed some of the most problematic Western evils. The Pahlavi regime projected an ideal of the Iranian woman as one who wore modern, Western style clothing while remaining modest in terms of the society at large. In their political agenda, the Islamic Republic created new female illustrations to counteract the Pahlavi discourse on women. The "Islamic-thus-modest" model and the ideal of Fatima, the daughter of the Prophet Muhammad were established. Fatima's life and experiences were understood to illustrate the female ideal particularly through her family responsibilities as wife and mother. The Islamic state, prioritising women's roles in the domestic sphere, imposed laws concerning women's education and professions restricting their participation in public and communal life. By July 1980, a particular dress for an Islamic woman was brought into picture. All body parts of the Islamic woman were to be covered-a complete opposite of Shah’s vision of unveiling woman. The coercive female dress code represented the re-establishment of the country's forgotten moral code. Once again women were used as voiceless agents, this time to depict a discarded Western image. The emergence of new security units that policed women's appearance effectively forced women to don the hijab in public space.

In post-revolutionary Iran, the veil acquired yet another layer of meaning during the Iran-Iraq war. The veiled Iranian woman was now represented as being more pious than the Iraqi woman. Posters depicting veiled Iranian women as mothers, sisters, wives, and daughters who supported their sons, brothers, husbands, and fathers in the war were displayed everywhere.

For women, the political ideologies of both the Pahlavi’s and the Islamic State have been defined by explicit elements of gendered political coercion. Despite the overwhelming attempt to control women's agency by the Islamic State, groups of Iranian women have resisted.

Veiling and Employment-Iran

In Iran, mandatory hijab wearing was imposed several years after the 1979 Islamic Revolution. The Islamic Penal Code of the Islamic Republic of Iran, under Article 638 of Book 5 states that women who appear in public without a proper hijab should be imprisoned from ten days to two months or pay a fine of 50,000 to 500,000 Ryal.[20] This is indicia of absolutely no recourse or avenue for an Iranian Muslim woman to unveil evem in the vicinity of her home let alone workplace.

This makes it instructive to note that to combat the restrictions pertaining to veiling at workplace, it becomes incessantly significant for Iranian women to first protest against this mandate at a national level. Since the advent of these compulsory hijab laws in Iran, there have been multiple cases of the Iranian authorities’ draconian measures to ensure compliance to their set laws. For instance, in 2018 the Iranian Police department announced they had arrested 29 women for taking off their hijab.[21] Iranian officials arrested Nargess Hosseini on January 29, 2018, as she took off her headscarf to protest Iran’s compulsory hijab while standing on top of an electric utility box on a street in Tehran. They arrested Azam Jangravi on February 15, 2018, and Shaparak Shajarizadeh on February 21, 2018, in similar circumstances. The Human Rights Watch urged Iranian authorities to not arbitrarily detain women who are peacefully protesting a mandatory dress code. On 27 October 2018, students in Islamic Azad University, Central Tehran Branch protested after a morality police van entered the campus and attempted to arrest several women for improper hijab. Similarly in 2019, students in University of Tehran protested the mandatory Hijab rule and were attacked by vigilantes and authorities.[22]

Although painstakingly the mandatory veiling in Iran has gained traction in International Human Rights Law (IHRL). The United Nations Special Rapporteur, on violence against women, Dubravka Simonovic, condemned the arrest of Nasrin Sotoudeh, a women human rights activist and lawyer, and stated that, “Nasrin Sotoudeh has been systematically criminalised for her work in defence of human rights, particularly the rights of women who oppose compulsory veiling laws.” Ms. Sotoudeh has been detained since June 2018 and was sentenced to a combined 38-year imprisonment on nine charges related to her work defending women arrested for peacefully protesting compulsory veiling laws. Under Iranian law, she will need to serve 12 years in prison, the longest of her sentences. She has been detained in highly prisons with highly concerning sanitary and structural issues.

The UN Rapporteur has further stated that, “No one should be coerced to wear religious symbols that they consider not essential or even contrary to their religions or beliefs,” said the experts. “A woman’s or girl’s choice in manifesting or expressing her identity, including her religion or belief, is protected under freedom of religion or belief and freedom of expression as provided by international human rights law.[23]

A 22-year-old woman, Mahsa Amini, recently this year in 2022 was arrested by morality police in the capital Tehran and died in custody.[24] Her death has sparked nearly two weeks of widespread unrest that has reached across Iran’s provinces and brought students, middle-class professionals and working-class men and women into the streets.

A UN expert called for the prompt establishment of an independent investigative mechanism into all human rights violations leading up to and since the death of Jina Mahsa Amini. The UN Special Rapporteur about human rights in the Islamic Republic of Iran, Javaid Rehman, said current investigations and domestic accountability channels had failed to meet the minimum standards of transparency, objectivity, and impartiality.[25]

The effect of these draconian laws coupled with the ongoing protests in response to the same have managed to affect every sphere of the life of an Iranian woman including her workplace. Under the present law, women must cover their hair and wear loose-fitting clothes in all public places, including the workplace and at school and university. The mandate is enforced by so-called morality guards. Complying with hijab rules means that women evade a fine or arrest, but wearing one also carries other benefits for women's careers. "If you are properly veiled, you can work in this industry and make money because the government will put its weight [behind you] and allocate budgets.”[26] So, to even bring a change in the system itself, it is pertinent for women to be present at the table of law-making for which they have to comply with the set hijab laws.

The complete mandate on wearing of the veil signifies the need for women to have to show up at work. To enter your workplace, to have your ideas put forth even as a woman for gender equality, it is pertinent for them to be covered wholly and appropriately. To be heard, you need to comply with the veiling laws in place thereby relentlessly governing what it is to be a Muslim woman in Iran.  [27]

It is pertinent to note that the crux of the problem in Iran is not whether women were directed to unveil or veil across distinct time periods, but what remains a vexing concern is that the very autonomy to decide whether a woman herself wants to veil or not has been seized from her, which is contravention to the legal standing of IHRL. While Article 27 of The Constitution of Iran ostensibly protects the right to freedom of peaceful assembly, the guarantee falls short of international standards set out in the International Covenant on Civil and Political Rights (ICCPR) by requiring that participants are not “in violation of the fundamental principles of Islam”. There is no clear definition or criteria that define what can be considered “fundamental principles of Islam”.[28] The right to freedom of expression, recognised under Article 24 of the Constitution is similarly undermined by vague qualifications, such as being “deemed harmful to the principles of Islam or the rights of the public”.  Article 40 further allows for restrictions of rights, including peaceful assembly, if their exercise is deemed “injurious to others” or “detrimental to public interests”. These restrictions fail to meet requirements of international standards that limitations are necessary and proportionate, and in pursuit of one of a limited number of narrowly drawn legitimate aims, per Article 19 of the ICCPR.[29] This grants authorities’ significant discretion to impose overbroad and vague restrictions on individuals’ rights in violation of the country’s international human rights obligations. The revised version of the Islamic Penal Code, adopted in 2013, comprising of penalties under Article 638, Book 5, related to Hijab laws criminalise the exercise of the right to freedom of expression, association and peaceful assembly, in contravention of international human rights law and standards.

Reflections

It can be concluded that despite the diverse meanings of the hijab in varying Muslim social, religious, and cultural contexts, the veil continues to be an increasingly politicised symbol in contemporary Western political discourses. The "clash of civilizations" between Islam and the West has become a tiresome mantra in current pollical scenario.

The policy of neutrality enforced by companies in France at workplace is strongly interconnected and reinforced by the idea of state neutrality in civil society thereby upholding the banning of the veil and dictating the nuances of the identity of a Muslim woman. On the other hand, Iran’s mandate of veiling, to de-westernise Iran and to emerge as a true Islamic state with the ‘ideal’ Islamic Irani woman takes over the wheel yet again to dictate Muslim women.

It has been illustrated how women's agency and representation in Iran and France have been and are controlled by authoritarian, patriarchal tropes that result in alienating female ideals. The coerced unveiling implemented by the French government inscribes competing and contradictory frames of reference on Muslim women's bodies.[30] The dominant French discourse treats Muslim women as objects to be utilised within broader ideological debates that ultimately disregard and marginalise Muslim women's voices and agency. Both the French and the Iranian governments demonstrate, through authoritarian laws on veiling/unveiling, direct discursive parallels. Despite all the rhetoric of equality and freedom from oppression (especially in Western discourses), both French and Iranian narratives severely restrict Muslim women's control over their own lives especially in their workplace environment.

There is a necessity for deeper awareness and understanding of Islam and for dialogue with Muslim communities. In creating societies characterised by mutual understanding and genuine multiculturalism, there needs to be greater openness to varying forms of self-representation. It is imperative to move away from geopolitical essentialisms that positions Muslim women's bodies as instrumental for broader political agendas. It is pertinent for areas of a Muslim woman’s life like her Workplace environment to not cater to political motives of the State and to function independent of the existing political ideals to truly enforce its policy of neutrality or Islamic Fundamentalism.

[1] Hoel, Nina, and Sa’diyya Shaikh. “Veiling, Secularism and Islamism: Gender Constructions in France and Iran.” Journal for the Study of Religion, (2007), vol. 20, no. 1, pp. 111–29. JSTOR, http://www.jstor.org/stable/24764329.

[2] Hoel, Nina, and Sa’diyya Shaikh. “Veiling, Secularism and Islamism: Gender Constructions in France and Iran.” ( 2007),20, no. 1, pp. 111–29. JSTOR, http://www.jstor.org/stable/24764329.

[3] Jailani, Yusuf. “The Struggle of the Veiled Woman: ‘White Savior Complex’ and Rising Islamophobia Create a Two-Fold Plight.” Harvard International Review, (2016), vol. 37, no. 2, pp. 51–54. JSTOR, http://www.jstor.org/stable/26445581.

[4] Carvalho, Jean-Paul. “VEILING.” The Quarterly Journal of Economics, (2013) vol. 128, no. 1, pp. 337–70. JSTOR, https://www.jstor.org/stable/26372500.

[5] Jailani, Yusuf. “The Struggle of the Veiled Woman: ‘White Savior Complex’ and Rising Islamophobia Create a Two-Fold Plight.” Harvard International Review, (2016), vol. 37, no. 2, pp. 51–54. JSTOR, http://www.jstor.org/stable/26445581.

[6] Bauer, Marie-Noelle."Leading the French Resistance". Emel - The Muslim lifestyle Magazine. March/April 2004, pp. 12-13.

[7] Leyla Sahin v Turkey EHCR 2005 ECHR 819

[8] European Convention on Human Rights, (ECHR) art 9.

[9] SAS v France ECHR 2014

[10] European Convention on Human Rights, (ECHR) art 14.

[11] European Convention on Human Rights, (ECHR) art 9.

[12] European Convention on Human Rights, (ECHR) art 10.

[13] Hunter-Henin, Myriam. “Why The French Don’t Like the Burqa: Laïcité, National Identity and Religious Freedom.” The International and Comparative Law Quarterly, (2012), vol. 61, no. 3, pp. 613–39. JSTOR, http://www.jstor.org/stable/23279928. Accessed 13 Oct. 2022.

[14] Engy Abdelkader, “A Comparative Analysis of European Islamophobia: France, UK, Germany, Netherlands and Sweden.” UCLA Journal of Islamic and Near Eastern Law, (2016) Vol. 16, Forthcoming

[15] Samira Achbita v G4S Secure Solutions, NV CJEU (2017) Case C-157/15

[16] Bougnaoui v. Micropole SA, CJEU (2017) Case C-188/15.

[17] F.A. v. France, CCPR/C/123/D/2662/2015, No. 2662/2015

[18] Hoel, Nina, and Sa’diyya Shaikh. “Veiling, Secularism and Islamism: Gender Constructions in France and Iran.” Journal for the Study of Religion, (2007), vol. 20, no. 1, pp. 111–29. JSTOR, http://www.jstor.org/stable/24764329.

[19] Hoel, Nina, and Sa’diyya Shaikh. “Veiling, Secularism and Islamism: Gender Constructions in France and Iran.” Journal for the Study of Religion, (2007) vol. 20, no. 1, pp. 111–29. JSTOR, http://www.jstor.org/stable/24764329.

[20] Article 638, Book 5, Islamic Penal Code of the Islamic Republic of Iran.

[21] Dehghan, Saeed Kamali,"Tehran hijab protest: Iranian police arrest 29 women". The Guardian. 2 February 2018.

[22] "Iranian students protest mandatory headscarf rule - the Washington Post". The Washington Post. 13 May 2019.

[23] “Iran: Jailed for defending women who opposed compulsory veiling, Nasrin Sotoudeh must be freed, say UN experts.” OHCHR, 21 June 2021.

[24] “Arrest by hijab police leaves woman comatose.” Al Monitor, September 15, 2022.

[25] Iran: UN experts demand accountability for death of Mahsa Amini, call for end to violence against women. OHCHR, 22 September 2022.

[26] “Iran: Abusive forced veiling laws policewomen’s lives,” Amnesty International, May 28, 2019.

[27] Kaukab Shairani “Iran: Does wearing the hijab help women's careers?”, DW-Made for Minds. May 3, 2022

[28] IHRDC, HRAI. “In preparation for the List of Issues prior to Reporting (LOIPR) for the ISLAMIC REPUBLIC OF IRAN, Article 19.” OHCHR, 2020.

[29] Ibid.

[30] Hoel, Nina, and Sa’diyya Shaikh. “Veiling, Secularism and Islamism: Gender Constructions in France and Iran.” Journal for the Study of Religion, (2007) vol. 20, no. 1, pp. 111–29. JSTOR, http://www.jstor.org/stable/24764329.