CRITICAL ASIAN STUDIES 157 nationhood.14 As Joya Chatterji notes, twentieth century scholars largely assumed that newly independent states derived their citizenship regimes from European models.15 Later works on citizenship largely persisted with such assumptions, focusing on the differences between procedural and substantive citizenship, and largely took for granted that citizenship of postcolonial states was automatically bestowed on all inhabitants following independence.16 Yet, as Chatterji’s study of “minority citizens” in South Asia reminds us, “the question of whether full formal citizenship was actually extended to all members of these states, and how it was created, qualified, or denied in specific historic locations and circumstances, has not sufficiently been investigated.”17 Recent scholarship attends to Chatterji’s question. For example, drawing on Arendt in her study of colonial bureaucracy and partitions in the British Empire, Yael Berda dubs those excluded from the political community via partition, “citizenship’s others.”18 Within recent citizenship studies, citizenship has been defined “as an ‘institution’ mediating rights between the subjects of politics and polity to which these subjects belong.”19 In the postcolonial context, such an approach has primarily meant understanding how citizenship status becomes contested by investigating practices through which claims are articulated and subjectivities are formed. In doing so, the postcolonial lens offers an understanding of citizenship from the viewpoint of the marginalized, a critique of European experiences, and a re-examination of the liberal constructions of citizenship.20 In particular, it charts how colonial legacies, nationalism, and majoritarianism in newly independent nations gave rise to legal tensions between citizenship by birth and by descent, and how legal frameworks of citizenship were significantly influenced by struggles over defining a national political identity.21 As Engin Isin points out: [the] enactment of citizenship is paradoxical because it is dialogical. The moment of the enactment of citizenship, which instantiates constituents, also instantiates other subjects from whom the subject of a claim is differentiated. So an enactment inevitably creates a scene where there are selves and others defined in relation to each other … the dialogical principle of citizenship always involves otherness.22 This process of othering is acute in South and Southeast Asia, where citizenship is a key aspect of competing demands for membership and the associated imperative of delimiting such demands on the part of the state.23 Exclusionary mechanisms – especially on religious and ethnic grounds – have become the center of citizenship debates in both India and Myanmar. While agreeing with the criticism of democratic backsliding in both countries, we argue that contrary to popular belief, religious and ethnic discrimination when it comes to citizenship and migration is not recent, but has been part of both countries’ citizenship policies since independence. 14 Kohn 1944/2005. Chatterji 2012. 16 Jayal 2013; Chatterji 2012. 17 Chatterji 2012, 1050. 18 Berda 2022, 2. 19 Isin and Nyers 2014, 1. 20 Sadiq 2017. 21 Ibid. See also Berda 2022; Rhoads 2023a. 22 Isin 2008, 18–19. 23 Othering takes the form of defining the boundaries of exclusion, “shaped by the institutional practices and their underpinning ideological conceptions, which define the paradigm for the allocation of political, social, economic, cultural and symbolic resources, privileges and duties” (Shani 2010, 149). 15

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