Abstract
Have immigration policies in various countries been subjected to sufficient comparative analysis from the perspective of citizenship? The answer is “No”. Due to “the challenge to the nation-state”, the debate on citizenship has focused on “formal” membership and has overemphasized human rights. However, the British experience suggests two points. First, a new perspective on citizenship is needed to analyse “substantive” membership. Second, the relationship between immigration policies and “social order” needs to be explored more fully.
