Proposals to ban niqab, the face veil worn by some Muslim women, are gaining support in France and Britain. France saw its first crime by “burqa bandits” on February 6, when two men wearing head-to-foot female “Islamic” garments robbed a post office in the Parisian suburb of Athis-Mons. The men gained entrance by convincing the clerks that they were women, then lifted their veils to disclose that they were not, drew at least one firearm, and stole about $6,000.

Three days earlier, French prime minister François Fillon rejected an application for citizenship by a man who compelled his wife to wear the face veil. The petitioner was not identified, but was reported to be Moroccan and a supporter of the radical fundamentalist Tabligh-i-Jamaat, which originates in South Asia but has gained a noticeable presence among French Muslims. French authorities have proposed a specific law against women wearing extreme coverings while riding on public transportation, and are pondering a general regulation against the practice.

Westerners often group together all forms of so-called Islamic female covering as “the veil,” which properly refers only to hiding the face. The face veil or niqab should not be conflated with the headscarf or hijab. Niqab usually accompanies the full-body abaya or burqa. The difference between the latter two is small – the abaya covers everything except the hair and face, but in Saudi Arabia and other places dominated by fundamentalist Islam, it is worn with a headscarf and a face veil, concealing all but a woman’s eyes. The infamous Saudi morals patrols, or mutawiyin, harass any woman who lets her abaya slip, even to exposing a millimeter of ankle. The burqa is a single garment covering the body, hair and face, with a mesh panel allowing the wearer partial vision, and it is mainly found in South Asia. But both are now seen in Britain more often than in the past.

Covering women’s faces has been an Arab custom at various times in Islamic history, but has no justification in the Koran. The headscarf may be traced to Koranic injunctions for modesty, and is mandated in Iran along with a chador or cloak. In Western Europe, France has banned the headscarf in public buildings, including schools, for years, while Germany has adopted a patchwork of rules, most importantly limiting public school teachers from putting on the headscarf. The Flemish region of Belgium has also taken measures against radical covering of women.

Among Muslim countries, Turkey bars headscarves in government offices and universities. In Tunisia the headscarf is illegal. Egypt, compelled to curb the radical Muslim Brotherhood, has moved toward officially forbidding the face veil for students, with support for the proscription by Muslim clerics aligned with the state. Lebanon, Morocco, Malaysia, and Pakistan do not impose requirements on women’s dress, though the incidence of covering ranges from rarity in Beirut to greater frequency in rural Pakistan and even in parts of India.

Details of these matters, as well as laws and attitudes governing them, differ enough, from place to place, to bewilder Muslims as well as non-Muslims. The French bar on display of religious symbols in official facilities extends to wearing of Jewish kippot (skullcaps) and large Christian crosses. Headscarves are worn in many non-Muslim settings, including by religious Jewish women who have married, and Eastern European Christian women. Throughout most of the world, Christian nuns assume a covering nearly identical to the hijab. Women in pietistic Protestant communities, like the Amish, dress with notable modesty. In addition, in some Arab countries men wear the djellaba or galibiya, a full-length robe with a hood and long sleeves. Often, in colder climes – such as the mountains of Morocco – the djellaba is made of heavier fabric with more diverse patterns than the typically-Saudi thobe. The thobe is cut from white cotton and found throughout the Arab Gulf and other Mideastern regions.

Writing laws that distinguish between objectionable body coverings and acceptable caftans or long coats will be a challenging task. In addition, issues of civil liberties and the efficient administration of justice have complicated the discussion in Britain. Many Britons who oppose radical Islam nonetheless balk at limitations on the personal right to dress as one pleases. Claims that the face veil is, in Western Muslim communities, forced on women by their families are convincing, but generally difficult to prove. Hijab, the face veil, and other forms of “Islamic dress” – including short pants on fundamentalist men – are often defended by their wearers as a personal choice. While some advocates of anti-veil laws base their view on principles of women’s equality, advocates for such ordinances in the UK mainly argue that covering of women is an unacceptable symbol of radicalism and a factor for separation of Western Muslims from their neighbors. French president Nicolas Sarkozy, like his co-thinkers in Britain, emphasizes that the face veil symbolizes extremism and separatism.

Among these various religious and cultural artifacts, niqab stands out as a public security problem. Except on snow slopes, ski-masks, which are not, in the end, very different from niqab, are universally associated with crime and terrorism. The Western and borderland nations have seen crimes committed by people disguised in niqab and body coverings, from Britain to India.

British public opinion is catching up with the French, as UK opinion polls show two thirds of those polled supporting a restriction on niqab in banks and airports, but about the same number expressing themselves against a general ban in all public places.

The niqab question epitomizes the legal entanglements introduced to the West by relations between Muslims and non-Muslims. The most widespread Islamic legal interpretation forbids women from covering their faces and hands in public, since they must deal with merchants and other people. The problem may be solved by Muslims themselves, especially if the Green movement demanding reform in Iran throws off the strict controls on personal conduct established by the clerical regime of Ayatollah Khomeini and his successors in power.

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