Despite their constitutionally secular status, the United States, France, and Turkey--the
three cases that I examine in this dissertation--have, in fact, been deeply concerned with religion
and have engaged it on many fronts. The three states’ rules regarding the wearing of headscarves
reflect a broad array of policy differences among them. Yuksel Sezgin and I have prepared an
index of state-religion separation based on 29 issues and 40 countries.
According to this index,
the states maintaining the firmest separation from religion would have the score of 0.0 (0/29) and
the ones with the weakest separation would have 1.0 (29/29). The score of the US is only 0.17
(5/29), whereas that of France is 0.34 (10/29) and that of Turkey is 0.48 (14/29).
In line with these differences, these three states have had distinct policies to regulate
religion in schools. Historical and contemporary debates on secularism in all these three cases
have pointed to education as the main battlefield in state-religion controversies.
therefore, I specifically focus on the five most publicly debated state policies on religion in
schools in three cases: a) prohibitions on students’ religious dress and symbols in public schools;
b) proscriptions on student-led prayer in public schools; c) restrictions on private religious
education; d) the presence of religious instruction in public schools; and finally e) public funding
of private schools run by religious groups. Table 2 compares my three cases regarding these five
policies. Like the index data above, the table stresses a higher degree of separationism in the US,
compared to France and Turkey. The ban on religious symbols exists in France and Turkey. In
all three countries, students are not allowed to collectively pray in public schools. Turkey is the
only one that bans private religious education; state-run religious schools and courses there have
an official monopoly on religious education. Turkey is also an exception in religious instruction
in all public schools. Finally, France is the only one among these three states that provides public
funding to private schools run by religious groups.
4
Kuru and Sezgin 2005.
5
See appendix 1.
6
See Monsma and Soper 1997, Haarscher 2004, and Berkes 1998.
3
Convention