As Karnataka hijab row escalates, a look at laws on face coverings across the world

The Karnataka hijab row has captured the entire country’s attention with people from all walks of life expressing their opinions. While many agree with the students demanding that they be allowed to wear hijabs in classrooms, others say a uniform should be adhered to.

The issue has snowballed into a major controversy with the Karnataka High Court now hearing the case against the ban.

However, this is far from the first time that the issue of face coverings — the burqa, niqab and hijab — has created controversy. Here’s a look at how other countries have dealt with the face coverings: which allow it and which don’t.

Turkey

Mustafa Kemal Ataturk introduced the secularisation of Turkey in its Constitution of 1924. While Ataturk never forbade the headscarf, he actively discouraged its use in public venues. His efforts saw an almost disappearance of hijab and burqa in Turkey.

In 2013, Turkey lifted its decades-old ban on headscarves in the civil service. Then Prime Minister Recep Tayyip Erdogan hailed the move as a “step toward normalisation”.

Critics had accuse Erdogan of lifting the ban to force his Islamic values on the majority Muslim but staunchly secular nation.

France

France was the first European country to put a ban on wearing a burqa or niqab in public.

The legislation has been in force since April 2011.

In order to quell allegations of discrimination, the wording of the law deliberately avoids mentioning religious veils, stating instead in general terms: “In the public sphere, no-one must wear an item of clothing that serves to cover the face.”

In addition, wearing any kind of religious clothing (including head scarves) in schools has been banned since 2004.

The ban is estimated to affect only some 2,000 Muslim women. This is because it is believed that only this small number of women opt for the veils in a population of five million Muslims.

While introducing the ban, President Nicolas Sarkozy had said that the veils oppress women and were ‘not welcome’ in France.

As per the law, wearing a full veil attracts a €150 fine and instruction in citizenship. Anyone found forcing a woman to cover her face risks a €30,000 fine.

In 2016, the European giant took it one step further and also banned burkinis, women’s full-body swimsuits. The Prime Minister Manuel Valls had called the swimsuits “the affirmation of political Islam in the public space”.

It was later lifted in seaside resorts after France’s top administrative court overruled the law.

Switzerland

Switzerland joined the list of European nations banning the niqab in 2021. In March, over 51 per cent of Swiss voters cast their ballot in favour of the initiative to ban people from covering their face completely on the street, in shops and restaurants.

According to the law, full facial veils will still be allowed to be worn inside places of prayer and for “native customs”, such as carnival.

The ban came after the Italian-speaking region of Ticino voted in favour of a ban on face veils in public areas by any group in September 2013.

Discussions on banning face veils in Switzerland cropped up in 2009 when Justice Minister Eveline Widmer-Schlumpf said a face-veil ban should be considered if more Muslim women begin wearing them, adding that the veils made her feel “uncomfortable”.

Denmark

In 2018, Denmark became another European nation to introduce a ban on face coverings in public places. Offenders can incur fines of up to €134 ($157). Repeat offenses are punishable by up to 10 times that amount.

The wording of the legislation does not specifically mention Muslim women but says that “anyone who wears a garment that hides the face in public will be punished with a fine”.

Belgium

A law banning the full-face veil came into effect in Belgium in July 2011. The law bans any clothing that obscures the identity of the wearer in places like parks and on the street. Anyone who breaks the law risks a fine or up to seven days in jail.

Support for the legislation crossed the ideological spectrum, with supporters calling it an effort to promote gender equality.

“I think we have to defend our fundamental principles of the Enlightenment. Man and women are equal in all aspects,” Peter Dedecker, a lawmaker from the center-right New Flemish Alliance, was quoted as saying.

The Netherlands

If you cover your face with a veil in the Netherlands, you face a fine of at least €150. The ban not only applies to burqas and other veils, but also full-face helmets and balaclavas.

The Netherlands introduced the ban after 14 years of debate. In 2005, the Dutch parliament surprisingly voted in favour of a proposal for a complete ban on burqas that had been introduced by right-wing lawmaker Geert Wilders. The parliament passed a milder version of the proposal in 2016.

Italy

A 1975 law aimed at protecting public order makes it illegal to cover the face in public but courts have systematically thrown out local moves to use the ban to outlaw the full-face veil.

Two regions held by the anti-immigrant Northern League — Lombardy and Venetia — have banned the burqa and full-face veil in hospitals and public places.

Austria

The ruling coalition agreed in January 2017 to prohibit full-face veils (niqab and burka) in public spaces such as courts and schools, with the law coming in to force in October the same year. Known as the Law against Wearing Face Veils, it requires people to show their facial features from chin to hairline. If that area is not visible, they face a fine of up to €150.

Bulgaria

Like the Netherlands, Bulgaria introduced a burqa ban in 2016. Wearers face a fine of up to €750 if they break it. There are some exceptions for people playing sport, at work or in a house of prayer.

Sri Lanka

In April 2021, Sri Lanka’s cabinet approved a proposed ban on wearing full-face veils including Muslim burqas in public, citing national security grounds, despite a United Nations expert’s comment that it would violate international law.

Public Security Minister Sarath Weerasekera has called burqas, a garment that covers the body and face worn by some Muslim women, a “sign of religious extremism” and said a ban would improve national security.

The wearing of burqas was temporarily banned in 2019 after Easter Sunday suicide bomb attacks killed more than 260 people.

Russia

Russia’s Stavropol region has a ban on hijabs: the first of its kind imposed by a region in the Russian federation. The ruling was upheld by Russia’s Supreme Court in July 2013.

UK

There is no ban on Islamic dress in the United Kingdom, but schools are allowed to decide their own dress code after a 2007 directive.

In January 2010, then Schools Secretary Ed Balls said it was “not British” to tell people what to wear. A 2016 poll had found that 57 per cent of the British public supports a burqa ban.

With inputs from agencies

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