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date: 23 February 2024

Women, Equality, and Citizenship in Contemporary Africafree

Women, Equality, and Citizenship in Contemporary Africafree

  • Robtel Neajai PaileyRobtel Neajai PaileyDepartment of International Development, University of Oxford


Though deeply contested, citizenship has come to be defined in gender-inclusive terms both as a status anchored in law, with attendant rights and resources, and as agency manifested in active political participation and representation. Scholars have argued that gender often determines how citizenship rights are distributed at household, community, national, and institutional levels, thereby leaving women with many responsibilities but few resources and little representation. Citizenship laws in different parts of Africa explicitly discriminate based on ethnicity, race, gender and religion, with women bearing the brunt of these inequities. In particular, African women have faced structural, institutional, and cultural barriers to ensuring full citizenship in policy and praxis, with contestations in the post-independence era centering around the fulfillment of citizenship rights embedded in law, practice, and lived experience.

While African women’s concerns about their subjective roles as equal citizens were often sidelined during nationalist liberation movements, the post-independence era has presented more meaningful opportunities for women in the continent to demand equality of access to citizenship rights, resources, and representation. In contemporary times, a number of local, national, continental, and transnational developments have shaped the contours of the battle for women’s citizenship equality, including the prominence of domestic women’s movements; national constitutional reviews and revisions processes; electoral quotas; female labor force participation; and feminism as a unifying principle of gender justice.

African women have had to overcome constraints imposed on them not only by patriarchy, but also by histories of slavery, colonialism, structural adjustment, land dispossession, militarism, and neoliberalism. They have often been subordinated in the domestic or private sphere, with gendered values and norms then undermining their agency in the public sphere. Although African women have managed to secure some political, socio-economic, and cultural rights, resources, and representation, this has certainly not been the panacea for achieving full equality of citizenship or gender justice.


  • Groups and Identities
  • History and Politics
  • Political Philosophy
  • Political Values, Beliefs, and Ideologies
  • World Politics


Throughout the contemporary era, citizenship has been defined generally as both legal status and “lived experience” (Isin & Turner, 2007, p. 16); a form of political activity, identity, and solidarity (Bosniak, 2000, p. 451); an identification of group and individual engagement (Barry, 2006, pp. 20–21); and simultaneously as identity, practice, and a set of relations (Pailey, 2016a). While the literature on citizenship tends to overly emphasize its inclusionary force, citizenship is essentially about exclusion in that it creates gendered, racialized, classed, ethnicized, and aged “non- or partial citizens” (Lister, 2003, p. 43). In this vein, the term “citizen” has been challenged by feminist scholars as historically male-centric and inherently exclusionary because women were not included in the original social contract instituted by Western enlightenment, but were instead “generally subsumed under male heads of households with no legal rights of their own” (Tickner, 1997, p. 627). While citizenship as an ideal has been presumed to be genderless, it is still “based on male defined norms which deny the complexities of female experiences” (Seely, Diouf, Malischewski, Vaikath, & Young-Burns, 2013, pp. 431–432).

In the same way that feminist scholars have questioned the primacy of maleness as a referent of citizenship, so too have internationalist and Africanist scholars challenged whiteness as a referent of citizenship by centering the experiences of so-called Global South subjects in their analysis about citizenship and geopolitical hierarchies of power. Adopting a feminist lens of analysis, this article demonstrates that contestations over women’s equality in contemporary Africa have centered around the fulfillment of citizenship rights embedded in law, practice, and lived experience. It examines structural, institutional, and cultural barriers to ensuring full citizenship for women in policy and praxis, including an evaluation of how African women’s political, economic, social, and cultural rights have transformed over the post-independence period. To that end, the article contends that the assertion of women’s citizenship in Africa has essentially been about ensuring equality of access to rights, resources, and representation.

Feminist, Internationalist, and Africanist Conceptions of Citizenship

As one of the foremost feminist theorists on the intersection between citizenship and gender, Lister (2003, pp. 37, 41–42, 196) borrows Oldfield’s definition of citizenship as both legal status with attendant “social and reproductive rights,” and practice as “an expression of human agency in the political arena” to argue convincingly that to be a citizen means to enjoy the rights of citizenship required for social and political participation, while to act as a citizen means to “fulfil the full potential of the status” despite structural constraints such as entrenched gendered inequalities. Thus, a comprehensive theorization of citizenship must factor women as subjects rather than objects of study and must also incorporate both their individual rights and political participation in all spheres (Lister, 2003, p. 41). For example, earlier attempts to cast citizenship as a gender-neural, abstract concept failed because they did not account for women’s uniquely embodied experiences (Lister, 2003). Accordingly, feminists are deeply concerned about how women are excluded from citizenship based on “their relationship with the private sphere” as well as “the problematization of their inclusion in the public sphere” (Gouws, 2005, p. 3). In this respect, the private sphere has been identified as a site of both agency and oppression for women (Yuval-Davis, 1997b), thus “changing the divide between the private and the public sphere but also understanding the fluidity of its boundaries and the interconnectedness between the two spheres are some of the greatest challenges for creating an egalitarian citizenship” (Gouws, 2005, p. 5).

For some scholars, it is important to abandon the private–public dichotomy altogether because “women’s exclusion from the public, political arena is in some way determined by structural inequalities in the family and the labour market and by the public–private divide” (Siim, 2000, p. 32). Thus, citizenship is context specific, with African women, for instance, deriving citizenship simultaneously from membership of different communities, including family, state, nation, while often experiencing limitations to their agency and autonomy in these same institutions (Imam & Kamminga, 2012, pp. 11–12). For example, in some African countries with federal systems, such as Nigeria, women’s citizenship rights are conferred at dual levels (national and state); while national citizenship in Nigeria is conferred by birth via a parent or grandparent who was indigenous to Nigeria at the time of independence, state-level citizenship is derived from paternal origins, so much so that married Nigerian women are denied state-level citizenship if they reside in a spouse’s state of origin that differs from their father’s (Pereira, 2004, pp. 1, 7). This has consequences in the political realm, in which Nigerian women have been barred from contesting for political office in regions other than their paternal state (Pereira, 2004, p. 1).

As the example from Nigeria shows, it is particularly useful to analyze how women’s citizenship is mediated through fluid and interconnected institutions such as “the state, civil society, and the domain of the family, kinship and other primary relations” (Siim, 2000, pp. 4, 19; Yuval-Davis, 1997a). Women’s citizenship is particularly constrained because of their “time poverty” resulting from added responsibilities in the home (Gouws, 2005; Lister, 2003). Feminist scholars have recognized the practical and material conditions that limit women’s citizenship, including domestic responsibilities such as childcare which keep them “tied to traditional gender roles,” thus leaving unchallenged “fundamental social divisions that allocate different roles to women and men” because of their biological differences (Goldblatt, 2005, p. 124). Women’s largely unpaid and unrecognized care work in the home due to the sexual division of labor severely restricts their ability to live as agentic citizens in the private and public spheres; this has been heightened in contexts like South Africa where the burden of care for those with diseases like HIV/AIDS rests with women (Goldblatt, 2005), or in public health emergencies such as the 2013–2016 Ebola outbreak in Guinea, Liberia, and Sierra Leone, where women provided the majority of home- and hospital-based care (Pailey, 2016b). Thus, scholars have argued that state structures must acknowledge and validate care as a fundamental citizenship right to enable women to exercise the institution equally and sufficiently (Goldblatt, 2005, pp. 130–131; Sevenhuijsen, 1998, pp. 19, 23).

In studying how women experience citizenship differently based on their layered identities in and outside the home, the concept of “non- or partial citizens” has become particularly instructive for explaining the variable ways in which different types of women are included or excluded from the institution. For instance, in the same way that essentialist citizenship binaries served to subordinate the private female non-citizen to her public male citizen counterpart, as indicated in Table 1, they have similarly served as justifications for why Europe (as the so-called rational, impartial, independent, subject-citizen parent) colonized Africa (as the so-called the irrational, partial, and dependent object-non-citizen child).

Table 1. Characteristics Defining the Male Citizen vs. Female Non-Citizen

Public, male, citizen

Private, female, non-citizen

Abstract, disembodied mind

Particular, embodied, rooted in nature

Rational, able to apply dispassionate reason and standards of justice

Emotional, irrational, subject to desire and passion, unable to apply standards of justice

Impartial, concerned with public interest

Partial, preoccupied with private, domestic concerns

Independent, active, heroic, strong

Dependent, passive, weak

Upholding the realm of freedom, of the human

Maintaining the realm of necessity, of the natural and repetitious

Source: Lister, 2003, p. 71.

Some feminist scholars struggle with whether women’s inclusion as citizens should focus on their embodied difference from or sameness with men, since the liberal tradition of rights tends to falsely equate equality with sameness. Others argue that negating or ignoring women’s embodied difference from men “reinforces or reintroduces inequality into the concept of citizenship ... while it is assumed that rights apply universally to everyone many groups of people with particular identities feel excluded from citizenship” (Gouws, 2005, p. 4). In embracing a “gender inclusive” model of citizenship, Lister (2003, pp. 68–92) proffers the term differentiated universalism to illustrate how the universalism of citizenship must accommodate women’s difference and diversity. Having recognized that the tendency to universalize “citizenship as rights” often inadvertently renders invisible some women’s very specific needs and vulnerabilities that may block them from pursuing “legal and policy redress” (Manicom, 2005, p. 36), Lister (2003, p. 87) argues that a feminist praxis of citizenship recognizes and responds to the particular needs of individual citizens—whether based on historical exclusion, such as the experience of colonialism, or because of contemporary inequalities, such as the feminization of poverty—while simultaneously affirming their equal membership in society.

As women are far from homogeneous, some scholars have argued that we should be thinking of “feminist pluralistic citizenship” to illustrate the differences between women given their varied social qualifiers as well as the “different sites of their participation” (Gouws, 2005, p. 5). While feminism has clearly reconfigured the “‘classic-modern’ citizenship project,” scholars such as Manicom (2005, p. 22) have argued that it has simultaneously silenced “black and Third World women living in the metropoles and post-colonies” whose perspectives, experiences, and subjectivities must be part and parcel of a feminist theorizing of citizenship because their “cultural, racialized, national, ethnic, religious or communal identities have been central to their exclusion from citizenship and are integral to their strategies for pursuing an inclusive, democratic politics.” In a “non-sexist, non-racist and non-Westocentric” configuration of citizenship, the position of women must be compared to that of men, but also in relation to their memberships in “dominant or subordinate groups, their ethnicity, origin and urban or rural residence” as well as their “global and transnational positionings” (Yuval-Davis, 1997b, pp. 4–5). Adopting an intersectional, internationalist definition of citizenship in reference to Crenshaw’s (1989) groundbreaking work about how individuals experience dominance and discrimination differently depending on their social qualifiers, Yuval-Davis (2000, p. 172) addresses Manicom’s concerns in her notion of “multi-layered citizenship” to describe how “people’s rights and obligations to a specific state are mediated and largely dependent on their membership of a specific ethnic, racial, religious or regional collectivity.” Although not entirely confined by it, “people are not positioned equally within their collectivities,” just as women are not positioned equally within the institutions that govern their lives (Yuval-Davis, 2000, p. 172).

Given the asymmetrical nature of geopolitics and the citizenship hierarchies within countries and continents, an important body of research has emerged to examine citizenship from a Global South perspective, generally, and the evolution of citizenship in post-independence African states, specifically. Echoing Mamdani’s 1996 seminal text, Citizen and Subject, Manby’s unprecedented book published in 2009, Struggles for Citizenship in Africa, asserts that citizenship laws in Africa, as residual hallmarks of colonialism, have been contested because of their exclusionary and discriminatory manifestations, thereby fomenting conflict and instability in the contemporary era. A historical analysis of the evolution of citizenship laws in Africa, beginning with the onset of colonialism, demonstrates that citizenship was non-existent for the “subjects” of colonial rule, and only a few native male administrators retained any form of citizenship within colonial territories (Manby, 2009; Mamdani, 1996). Anticolonial struggles for independence, on the other hand, simultaneously constrained and liberated African women. While women were able to assert greater power within nationalist movements through their identification as mothers, they were also confounded by the deliberate silencing of their demands for gender-inclusive citizenship, agency, and participation (Hassim, 2005, p. 56).

During independence, citizenship laws were reconfigured in the same manner European law configured liberal citizenship, by birth or ancestral lineage, whereby those not native to the soil were excluded either because they had migrated to the region during the colonial period, or because they had migrated from another section of the territory (Manby, 2009). Just as colonial boundaries remained the same, so the citizenship norms that were adopted often reflected a European ethos. Although modern legal norms, coupled by globalization, are pressuring Africa to loosen regulations on citizenship, post-independence states still hold very strict definitions of who belongs, often excluding ethnic groups who were not physically present in the polity by a particular date (e.g., Uganda and DRC), non-blacks (e.g., Liberia and Sierra Leone), immigrants (e.g., Nigeria), and women (Manby, 2009). This trend, scholars have argued, is manifested in the fractured nature of contemporary African identity formation (Adejumobi, 2005; Manby, 2009; Mamdani, 1996).

Citizenship as a site of contestation in Africa is particularly at odds with its liberal definition in social theory, which claims that modern citizenship included civil, political, and social rights for all members of a given society, whereby all enjoy the right to equal treatment under the law (Marshall, 1950). This construction of citizenship has been critiqued implicitly and explicitly by a range of scholars, including O’Connell Davidson (2013, p. 15), who asserts that “those who enjoy citizenship in the formal sense do not always enjoy equal access to its privileges and protections.” It is clear that social theory of liberal citizenship has a blindspot where the Global South, generally, and Africa, specifically, are concerned. It has an even larger blind-spot for the lived experiences of women citizens in those areas. Given that the very foundations of citizenship were couched in whiteness, maleness, and property ownership, black and African feminists have argued that women’s citizenship in the Global South, and particularly in Africa, has its unique logics fashioned not only by patriarchy, but also by histories of slavery, colonialism, structural adjustment, land dispossession, militarism, and neoliberalism (Mama, 2011; McFadden, 2005). Thus, Africa represents an important case study of how contestations over women’s citizenship equality have evolved from decolonization onwards.

African Women’s Struggles for Citizenship Equality

During the period immediately following independence in most African countries, citizenship laws explicitly discriminated on the basis of gender, with African women excluded from certain rights and privileges, if they were deemed citizens at all (Manby, 2018). For instance, whereas most countries in Africa are gender-neutral in terms of granting both men and women the right to pass on citizenship to spouses and children, others are gender-neutral only with respect to children, favoring men in the transfer of citizenship to spouses; still others invariably deny women the right to pass on citizenship to children (Manby, 2018; Seely et al., 2013). The latter group includes countries as varied as Liberia—though Liberia was never formally colonized by European powers—Burundi, Guinea, Libya, Mauritania, Somalia, Sudan, Swaziland, and Togo (Manby, 2018; Pailey, 2014, 2016a).

At independence, restricted citizenship laws based on gender were a reflection of restrictions embedded in the citizenship laws of former colonial metropoles. However, countries with revolutionary heads of state eschewed the practice of gendered citizenship discrimination. One such leader was Burkina Faso’s Thomas Sankara, whose strong commitment to gender equality quite possibly influenced the country’s adoption in 1989—long after his ouster—of a family code with strong women’s rights provisions (Manby, 2018, p. 98). Some early post-independence citizenship laws did not restrict women from transmitting citizenship, as was the case in Chad, which changed gendered discriminatory laws during the period 1961–1962, and Côte d’Ivoire, whose laws did not discriminate on the basis of gender when they were first adopted in 1961 (Manby, 2018, p. 98). While Lusophone countries may have obtained independence later (in the mid- to late and thereafter), they adopted gender equality norms in their citizenship laws from the outset, thereby enabling women to transfer citizenship to their children and, with the exception of Mozambique and São Tomé and Príncipe, to their spouses; this could be attributed to the countries’ socialist ideologies (Manby, 2018, p. 98). A watershed moment in the battle for African women’s citizenship equality occurred in 1992 when a woman activist in Botswana, Unity Dow, was granted the explicit right by the Court of Appeal to transmit citizenship to her children and spouse (Manby, 2018, p. 98). Widely publicized across the continent, the case emboldened advocacy around the right to citizenship and nationality for African women. By the end of 2017, 42 out of 54 African countries did not explicitly restrict African women from passing on citizenship to their children, and under half had removed laws restricting women from passing on citizenship to their spouses; the transmittal of citizenship to spouses has encountered more resistance (Manby, 2016; 2018, pp. 98, 102).

According to Manby (2018), the impetus for introducing gender equality in citizenship laws across Africa came from simultaneous local, national, international, and transnational advocacy. Despite significant gains in transforming citizenship regimes across Africa to address the needs of women, fierce resistance to granting women equal citizenship rights has persisted. For instance, although the Protocol to the African Charter on Human and Peoples’ Rights on the Rights of Women in Africa adopted in 2003 compels states to refrain from gender discrimination, it is virtually silent on citizenship rights for women primarily because of strong opposition from North African states (Manby, 2018, p. 101). In formerly colonized or so-called developing contexts like Africa, “the relationship between gender and the nation or women’s rights and national identity politics has been unpredictable and uneasy,” with contestations over citizenship particularly stark in the 20th century and beyond during the “third wave” of democratization (Moghadam, 1994, 2003, p. 65; Yuval-Davis, 1997a; Jayawardena, 1986). As Pereira (2004, p. 1) has argued, “[African] women’s experiences of citizenship are deeply steeped in experiences structured by gender inequality,” including the economic liberalization and structural adjustment programs of the 1980s and 1990s as well as the more contemporary neoliberal project which severely limits women’s abilities to live fully (Nyamu-Musembi, 2007, pp. 200–204). Because restrictions on African women’s citizenship still persist despite some legal reforms to the contrary, African scholars like Nyamu-Musembi (2007, p. 177) have argued that formal citizenship—the rights and obligations that define the state–citizen relationship—does not necessarily guarantee substantive citizenship—the “absence of constraints imposed by lack of action on the part of state institutions, or constraints imposed by norms, relationships and institutions at the sub-national or informal level that mediate one’s experience of formal citizenship, regardless of gender.”

Thus, citizenship as lived experience for women in Africa demonstrates the limitations of citizenship as couched in laws and rights solely, what Gouws (2005, p. 3) describes as “procedural equality.” For instance, although South Africa admittedly has one of the most liberal constitutions in the world, a Women’s Charter for Effective Equality which heralds gender-inclusive citizenship and socioeconomic rights for women as the bedrocks of democracy, and one of the most advanced National Machineries for Women—a state structure created for the express purpose of gender mainstreaming—South African women at varying levels still struggle to benefit from the rights and privileges of citizenship, what Gouws and others refer to as “substantive equality” (Gouws, 2005, p. 3; Manicom, 2005, p. 26; Seidman, 1999). Although the differential experience of black South African women in particular during apartheid was heavily negated by a nationalist liberation struggle, in the post-independence era these same women began to assert their subjectivity by securing certain rights in the public domain—including reproductive, labor, customary, and political rights—through collective mobilization bridging racial, socioeconomic, and ideological divides (Gouws, 2005, pp. 8, 10; Hassim, 2005, pp. 57–69; Seidman, 1999). However, many of the conditions that rendered them subordinate and unequal during apartheid and before it remain unchallenged and unchanged in a post-independence and post-apartheid nationalist project (Gouws, 2005, p. 8; Manicom, 2005, p. 26). As a case in point, Manicom (2005, p. 34) has shown that South African women at varying levels are reduced to second-class citizens in part because of the post-apartheid state’s adoption of neoliberal policies that have “fostered a feminization of labor and of poverty,” particularly adversely impacting black women.

As the example of South Africa indicates, an examination of African citizenship laws demonstrates that legal treatment of women is variable and uneven, both across the continent and within individual countries (Seely et al., 2013). While many African constitutions have been rewritten since the 1990s, “women’s citizenship rights are not automatically enshrined” (Seely et al., 2013, p. 433). In their analysis, Seely et al. (2013) illustrate how laws drafted in early post-independence periods tended to be less gender neutral, outwardly discriminating against women, while laws in countries with significant Muslim populations tended to favor men. Where there is a high prevalence of strong women’s movement advocacy (as in Rwanda and South Africa) or legal court action (as in Botswana and Zimbabwe), citizenship laws can be amended “either by leveraging the legal system to bring about change or by emphasizing gender neutrality in the law as part of a larger constitutional overhaul” (Seely et al., 2013, p. 430).

African women post-independence have had to contend with the inherent contradiction between liberal citizenship emphasizing equal rights under the law (without guaranteeing those rights in practice), and customary law which confines women to the private sphere under the authority of male relatives (Meintjes, 1995, p. 7). To address the unintentional and deliberate centering of men in statutory and customary forms of citizenship, respectively, scholars have argued for a radical shift in how we construct public and private spheres of influence because they form the basis of legal systems and determine how men and women relate. According to Meintjes (1995, p. 8), “the reordering of roles and responsibilities in private and every-day life are particularly pertinent, since these determine how women can participate in civil life” as full citizens. In her analysis of citizenship construction and practice in South Africa, Meintjes (1995, p. 7) makes the important point that citizenship rights enshrined in legal statutes and regulations alone will not liberate women from the strictures of dominance and discrimination. Similarly, Imam and Kamminga (2012, p. 26) have argued that “women’s legal position, however, is not only framed by the content of law, but also by the extent to which they can access it, and the extent to which it is likely to work in their interests.”

The difficulty in addressing women’s differential experience of the institution of citizenship lies in the fact that:

inequalities that can be linked to “citizenship” for women are extremely broad and multifaceted, including (but not limited to) economic rights and inheritance, health care and reproductive freedom, domestic and sexual violence, marriage and divorce, and representation in political institutions.

(Seely et al., 2013, p. 431)

Across the globe generally, and in Africa specifically, women have evoked citizenship in their struggles for suffrage, political quotas, and welfare rights (Lister, 2000; Moghadam, 2003, p. 64; Narayan, 1997; Walby, 1994). For example, in South Africa women were actively involved in ensuring that the country’s first democratic constitution enshrined broad sweeping rights for women, including rights to equality, freedom from violence, freedom and security of person, reproductive freedom, etc. (Ndlovu & Mutale, 2013, p. 74). Similarly, women from Zambia, Malawi, and Uganda fought for the inclusion of women’s rights provisions in their countries’ constitutions, specifically related to affirmative action, non-discrimination, and criminalizing violence against women (Ndlovu & Mutale, 2013, p. 74).

Since feminists define citizenship as both legal status with certain rights and practice through political agency, it is important to examine how the active assertion of African women’s political rights and representation serves as a proxy for citizenship equality, and how some women have employed leadership in the public sphere to enhance women’s citizenship in all spheres.

Political Rights and Representation as Proxies for Citizenship Equality

According to Ndlovu and Mutale (2013, pp. 74–76), a range of simultaneous factors have elevated women’s political participation and representation in post-independence Africa, thereby augmenting equality of citizenship to varying degrees. Ameliorations have included increases in women’s movements, quota systems and access to educational opportunities, transitions to multiparty democracy, and global and national agreements, conventions, and commitments. Although the examples included herein of women’s struggles for equality of citizenship in politics are primarily from sub-Saharan Africa, the battle for women’s political participation in North Africa has always been germane to contestations over citizenship rights, resources, and representation. Though North African women have experienced improvements in their post-independence political representation, exceptional cases of women ascending to parliaments, cabinets, or judiciaries are few and far between (Moghadam, 2003, p. 71). This serves as a stark reminder of the challenges African women continue to face in achieving one of the hallmarks of gender-inclusive citizenship—agency as manifested in active political participation and representation.

Executive-Level Leadership

While scholarly research has focused extensively on African women’s increased representation in parliaments and legislatures across the continent, a growing body of literature centers on executive-level leadership given the upsurge of African women serving as presidents (in Central African Republic, Ethiopia, Liberia, Malawi, Mauritius), prime ministers (in Burundi, Guinea Bissau, Madagascar, Mali, Mozambique, Namibia, Rwanda, São Tomé and Príncipe, Senegal), vice-presidents and deputy presidents (in Burundi, Djibouti, Gambia, Liberia, South Africa, Uganda, Zimbabwe), and cabinet ministers (in Comoros, Ethiopia, Kenya, Liberia, Somalia, South Africa, Sudan) (Adams, 2008, pp. 476–479; Cheeseman, Onditi, & D’Alessandro, 2017; Ettang, 2014; Garnett, 2016; Ndlovu & Mutale, 2013, pp. 1, 73; Pailey, 2014).1 In this vein, scholars have questioned whether the conditions of women—and by extension their experiences of the institution of citizenship—improve during the leadership of female heads of state, using the first term of Liberia’s and Africa’s first democratically elected woman president—Ellen Johnson Sirleaf—as a case study (Kodila-Tedika & Asongu, 2017; Pailey, 2014).2

Using six main gender indicators—gender equality; equality of representation in rural areas; women’s economic rights; active participation in economic life; political rights; and legislation protecting women against violence—Kodila-Tedika and Asongu (2017, p. 88) argue that although there were minimal positive gains in the equality of representation of rural women as well as improvements in women’s economic rights during Sirleaf’s first term (including the construction of markets, the doling out of microfinance, and the introduction of property rights for women), there were no apparent substantive changes in the position and condition of Liberian women between Sirleaf’s first term and the single term in office of her predecessor, Charles Taylor.3 Accordingly, it has been argued that Sirleaf’s brand of femocracy—a term coined by Mama (1995) to describe prominent African women in politics who serve the interests of a small, elite group of women and men—has upheld long-standing patriarchal norms in Liberia, thereby limiting the prospects of other women wishing to actually shatter the political glass ceiling as a means of strengthening women’s equality of citizenship (Pailey & Williams, 2017; Pailey & Harris, 2017).

Political power in most African countries is highly centralized in the executive; thus, a careful review of how women engage as active citizens in national politics has included an examination of whether they factor not only in presidential leadership, but also in cabinet appointments. While the number of women appointed to cabinet-level positions in Africa has increased significantly from 1980 onwards, the politicization of ethnicity, particularly in multiethnic societies, has also adversely impacted said appointments. Evaluating a dataset on the composition of cabinets in 34 African countries from 1980 to 2005, Arriola and Johnson (2014, p. 495) argue that women in sub-Saharan Africa are less likely to obtain ministerial positions in cases where incumbent presidents use cabinet-level appointments to build alliances with primarily male political leaders who promote and campaign on behalf of specific ethno-regional constituencies. In cases where presidents must contend with a large number of these predominantly male political entrepreneurs, cabinet-level appointments of women tend to remain low because entrenched gender inequities block women from obtaining the financial and social capital (i.e., property) necessary to become ethno-regional patrons (Arriola & Johnson, 2014, pp. 495–497).

Legislative and Judicial Leadership

Given the power of national legislatures and parliaments to enact laws that can augment or reduce women’s citizenship rights, resources, and representation, it is little wonder that legislative leadership has served as a battleground for African women’s assertion of their political agency. While some scholars have argued that women’s representation in sub-Saharan parliaments where executive branches are strong and legislatures are weak could prove futile or possibly undermine democracy, others have demonstrated that increased female political participation could result in “significant substantive or symbolic or representation effects” (Bauer, 2012; Bauer & Burnet, 2013, p. 103; Creevey, 2006; Geotz & Hassim, 2003; Hassim, 2010; Muriaas & Wang, 2012). Whereas substantive representation effects are defined as “advancing women’s interests through the policy making process and measured in terms of policy agendas or legislative items that promote, protect, or enhance women’s rights and interests,” symbolic representation effects are defined as “altering gendered ideas about the roles of women and men in politics, raising awareness of what women can achieve as political actors and legitimizing them as political actors, or encouraging women to become involved in politics as voters, activists, candidates, leaders” (Bauer & Burnet, 2013, p. 103).

In the last two decades alone, the representation of women in sub-Saharan national legislatures has increased significantly, primarily because of the introduction of electoral quotas, with the most recorded gains in eastern and southern Africa (Bauer & Burnet, 2013, p. 103).4 Partly in response to the decline of the share of women in parliaments and legislatures from 9.2% to 7.8% in 31 African countries during multiparty democratic elections in the early 1990s (Yoon, 2001, p. 76), African women across the continent campaigned for national gender quota laws—constitutional provisions mandating political parties to include women on party candidate rosters—to improve the descriptive (numerical) representation of women, with countries across the continent beginning to adopt these laws in the early 2000s (Kang, 2013). Governments and political party leaders across Africa have responded to women’s demands for political inclusiveness with specific measures including gender quotas, and this has happened in both democratic and autocratic settings at varying degrees (Muriaas, Tønnessen, & Wang, 2013, p. 90). Bauer and Burnet (2013) illustrate, using the case studies of Botswana (a stable multiparty democracy in southern Africa since 1966) and Rwanda (a one-party developmentalist state in East Africa since a 2003 post-genocide political transition), that where women’s legislative representation is concerned, more democratic states such as Botswana are not more likely to adopt quotas than seemingly undemocratic ones such as Rwanda. For example, while gender quota campaigns have proven unsuccessful in increasing the number of women in parliament in Botswana, which has one of the lowest representations of women in parliament in Africa (at close to 8%), Rwanda’s constitutional gender quota has resulted in the only majority-women parliamentary lower house in the world (at close to 60%) (Bauer & Burnet, 2013, pp. 103–104).

These case studies corroborate previous research which illustrates that successful political transitions (which often result in new constitutions with gender equality provisions) and women’s movement mobilization for economic and political power are essential not only for adopting electoral gender quotas but also for showcasing the potential benefits of increasing women’s participation in politics as a means of asserting their active citizenship (Bauer & Burnet, 2013, p. 104). For example, as a proxy for the enhancement of women’s citizenship rights, resources, and representation, women’s political participation in many African countries has increased after political transitions, especially those precipitated by armed conflict, such as happened in Liberia, South Africa, and Uganda, with the latter two having significantly higher numbers of women in parliament after the transitions (Adams, 2008, p. 480; Britton, 2005; Pailey, 2014; Tamale, 1999). In some cases, however, postwar transitions may clamp down on women’s agency, political participation, and representation, as in the case of Sudan’s 2005 peace agreement which saw the emergence of an ultra-religious movement, Salafism, calling for limits on women’s political participation in the name of “religious piety and public morality” (Muriaas et al., 2013, p. 91).

While there appears to be widespread interest in the effect of gender quota laws on the election of women, some scholars have erred on the side of caution by arguing that where human rights norms are unenforced and democratic institutions unprotected, quotas cannot meaningfully promote gender equity or enhance women’s citizenship rights (Hassim, 2010). Academics and activists alike who champion electoral gender quotas as conduits for ensuring political equity and agency for women, promoting democracy, and advancing democratic norms, have met stiff opposition from others who deem such quotas undemocratic “artificial” responses to the underrepresentation of women in political spaces as well as means by which authoritarian regimes legitimize their rule (Krook, 2013). Other valid critiques of gender quotas are that they elevate elite women at the expense of women with lower socioeconomic backgrounds; and they operate as reserved seat systems that do not compel countries to exceed minimum requirements (Kang, 2013, p. 101).

The literature also clearly demonstrates that descriptive (numerical) representation of women in political office—including the presidency—does not always translate into substantive representation or the improvement of women’s citizenship equality (Pailey, 2014; Squires, 2008; Steady, 2011). Some scholars have gone a step further to assert that the descriptive (numerical) representation of women in politics is a necessary though insufficient condition for ensuring women’s citizenship equality (Goetz & Hassim, 2003; Imam & Kamminga, 2012, pp. 11–12). For example, Uganda’s 1998 affirmative action policy, which consists of including women in local councils and reserving parliamentary seats exclusively for women, propelled more women into mainstream politics than ever before, with women occupying almost 25% of parliamentary seats and 30% of local government positions (Ahikire, 2004, p. 8). Nevertheless, seats reserved for women in local councils and parliament are less politically significant or relevant than general constituency seats, and rather than addressing historical gender imbalances they reinforce the notion that women are less capable and qualified for politics than men (Ahikire, 2004, p. 16; Tamale, 1999).

While gaining a place in a national legislature or parliament may prove beneficial for women’s descriptive (numerical) representation or women’s political agency, there is no guarantee that women, when elected, will have the capacity to change largely male-dominated institutional structures to bring about any positive changes for women’s citizenship rights, resources, and representation (Tinker, 2004, p. 542). There is also no guarantee that they will advance feminist political agendas, which, for some scholars, should be the end goal (Goetz & Hassim, 2003; Tamale, 1999; Tinker, 2004, p. 542). Ugandan feminist legal scholar Sylvia Tamale (1999, p. 194), for instance, advocates for the advancement of African women’s active citizenship outside of state-led structures because she remains skeptical that the state can actually deliver or further gender and citizenship equality norms. For example, some scholars have argued that African courts, as products of colonial systems, are limited in their ability to enforce gender equality regulations because they often uphold and sustain patriarchal values and norms (Nkiwane, 2000). Thus, it is not entirely surprising that women remain severely underrepresented in judicial-level leadership in Africa, where they could effectively invoke laws and regulations that uphold women’s citizenship rights, resources, and representation (Dawumi & Kang, 2015).

The discussion thus far has demonstrated that the representation of some women in key positions of formal political authority—be it judicial, legislative, or executive—enables them to act as agentic citizens thereby enhancing women’s equal access to rights, resources, and representation in all spheres. The section “Socioeconomic and Cultural Rights as Proxies for Citizenship Equality” looks at how less formal structures simultaneously enable and constrain women’s equality of citizenship.

Socioeconomic and Cultural Rights as Proxies for Citizenship Equality

Whereas claims to political rights by African women have been by far the more prominent, economic, social, and cultural rights claims have been viscerally contested because they are perceived as “‘relative’ and context specific” (Imam & Kamminga, 2012, p. 33). In contestations over socioeconomic and cultural rights, non-state male gatekeepers and duty bearers—including family heads, customary title-holders, religious leaders, and community chiefs—have been essential in both fulfilling and denying women’s equality of citizenship (Imam & Kamminga, 2012, p. 46). For instance, under the guise of “culture,” tradition, or religion, gendered sociocultural and economic norms as well as customary practices in Africa—including female genital mutilation, forced and child marriage, the denial of women’s inheritance and land ownership, gender-based violence, etc.—have severely limited women’s abilities to experience citizenship fully despite having legal rights as citizens (Pereira, 2004, pp. 8, 10). Using the example of South Africa, Manicom (2005, pp. 35, 37) illustrates that regardless of the post-apartheid state’s attempts to reconcile fundamental tensions between cultural and gender rights—thereby improving women’s legal status and protection within the confines of cultural practices, values, and norms—customary or “traditional” laws remain “deeply patriarchal” and antithetical to women’s emancipation in the same way that the capitalist labor market subjects working-class women to exploitation.

There is a healthy debate amongst feminist scholars, however, about whether deeply embedded socioeconomic and cultural norms actually help or hinder African women’s citizenship equality. For example, Tamale (2008, p. 47) has challenged the notion that all African cultural norms are static, fixed, unchanging, and “essentially hostile to women.” Citing the Protocol to the African Charter on the Rights of Women in Africa—which states explicitly that “women shall have the right to live in a positive cultural context and to participate at all levels in the determination of cultural practices”—Tamale (2008, pp. 57–58) demonstrates how the Protocol “recognizes and validates African women’s agency in challenging culture as a concept of power/authority and reshaping it so that it connects with rights.” While admitting that patriarchal norms in Africa based on Judeo-Christian or Islamic morality (or both) attempt to “regulate and control the sexuality and reproductive capacity of [African] women,” Tamale (2008, pp. 58, 61–62) indicates that African women have also evoked cultural values to try to expand their constellation of citizenship rights, such as guaranteeing women’s rights to sexual pleasure and the denouncement of sexual violence in marriage.5 As a case in point, for over four decades Ugandan women’s rights groups and feminist lawyers attempted to alter discriminatory laws governing marriage, divorce, and property ownership, including prohibiting widow inheritance, vetoing bridewealth, and restricting polygamy (Tamale, 2008, p. 59). For Tamale (2008, pp. 64–65) it is clear that while elements of culture in Africa are oppressive to women, these same norms, values, and practices can be radically transformed from the bottom up by African women themselves to render them “emancipatory” and “egalitarian.”

As a case in point, while some precolonial and colonial hierarchies severely undermined African women’s agency and participation—during which they “remained confined in the privatized rural spaces of the colony”—during and after decolonization African women began to engage with and challenge “African and European colonial patriarchies” in both traditional and modern institutions of governance (McFadden, 2005, pp. 4–5). For example, in the post-independence era women in countries like Botswana, Lesotho, and Sierra Leone have fought to assume their rightful positions as traditional leaders, namely chiefs, despite attempts to deny them these roles (Bauer, 2016; BBC, 2010; LaFraniere, 2004; Lee, 2012; Matemba, 2005). Previously assumed to be “undemocratic and patriarchal” as well as the exclusive domain of men, chieftaincy has endured in the post-independence era to become an important institution from which to measure women’s citizenship equality at the local level (Bauer, 2016, pp. 222–223). Given that traditional authorities “are seen to play an essential role in local governance, in managing and resolving conflict and in representing community identity, unity, continuity and stability,” they remain important conduits for enhancing women’s symbolic and substantive representation as well as women’s citizenship equality (Bauer, 2016, p. 227). Though having women in traditional hierarchies in Africa does not necessarily translate into improved agency and participation for women, there are examples of this happening, from ensuring inheritance rights for women in Botswana to terminating child marriage in Malawi (Bauer, 2016, p. 227; Werft, 2016).

African women have simultaneously embraced and challenged cultural and socio-economic norms to claim and secure citizenship rights, resources, and representation. This can be seen by considering the themes of access to land, freedom from physical violence, and contestations over structural violence.

Securing Access to Land.

Scholars of land and gender have argued that in agrarian economies, which predominate on the African continent, the unequal distribution of land and limited land rights for women reproduce gender inequalities and relegate African women to a lifetime of poverty and second-class citizenship (Tsikata, 2009, p. 19; Wanyeki, 2003 Butegwa, 1991;). Even in cases where land legislation is passed upholding gender equality norms, African women still face major obstacles to access (Ravborg, Spichinger, Broegaard, & Pedersen, 2016, p. 416). Across the continent, the very idea that women should own land remains a site of major contestation (Adoko, 2008, p. 125). Generally, contemporary land tenure in Africa blends customary (local-level legal processes) and statutory land titling, with former British and French colonies preserving colonial-era land systems in order to exert control over territory and maintain political sovereignty; however, the two systems have not always cohered (Whitehead & Tsikata, 2003, pp. 72–74). Following independence, states captured land for agricultural use and production, but inefficient land administration led to rampant land seizures by political and economic elite men (Whitehead & Tsikata, 2003, p. 73). Although African socio-legal customs and practices around land are very diverse, “flexible and negotiable” (Whitehead & Tsikata, 2003, p. 76)—with women’s claims, access, and control equally so—during post-independence land reform processes in many parts of the continent men increasingly invoked “custom” as a means of exerting ever greater control over land at the expense of women (Whitehead & Tsikata, 2003, p. 74).

In contemporary Gambia, for instance, men relabeled farms that had been previously designated as women’s private fields as “household” land for a new irrigation project, thereby illegitimately asserting power where it did not exist before (Whitehead & Tsikata, 2003, p. 79). Similarly, in Kurebwa’s (2015) study of Madondo communal lands in the Gutu district of Zimbabwe, political, administrative, and traditional institutions have failed to acknowledge women as important players in the management (i.e., access and control) of woodland and water resources (including grazing land, timber, firewood, fish, river sand, and wells), thereby creating unnecessary tensions between men and women. Although women are primarily responsible for collecting woodland and water resources for household and community consumption, and are therefore more heavily dependent on these resources, it is traditionally male heads of households in rural Zimbabwe who control access to these resources, thus leaving women and non-heads of households out of decision-making about how said resources should be managed (Kurebwa, 2015, pp. 18, 21–22). On the issue of the redistribution of land in Zimbabwe, in particular, McFadden (2005, p. 8) asserts that women’s demands for family property ownership, “for title and/or guaranteed state protections to their occupancy of redistributed land indicate a critical interface between notions of women’s rights and citizenship with forms of private property.”

Given heightened contemporary contestations over land due to colonial legacies around individual versus communal property ownership, environmental degradation, rising urbanization, agricultural commercialization, and population growth, countries like Zimbabwe—including Tanzania, Uganda, Malawi, Côte d’Ivoire, Niger, Ghana, and South Africa—are undergoing radical land reforms, with varying implications for the rights, resources, and representation of women (Whitehead & Tsikata, 2003). African women lawyers, feminists, and international gender and development experts have challenged an emerging consensus amongst some influential policy makers, legal practitioners, and academics that there is potential for customary land tenure to meet the needs of all, including women (Whitehead & Tsikata, 2003). They argue that African women’s land access and ownership, particularly in rural settings, must be enshrined in statutory law and enforced by state institutions in order to subvert gendered inequalities embedded in customary land tenure systems (Whitehead & Tsikata, 2003). While these advocates acknowledge the limitations of formal legal structures and institutions—including lack of access for rural women, gender biases inherent in legal concepts, and the contradictions between customary social relations and legal practice—they maintain that statutory law still offers women the best recourse against land inequities (Whitehead & Tsikata, 2003, pp. 99–100). Despite the assertion of statutory law as the best mechanism for ensuring women’s citizenship equality, long-running debates about the merits of customary over statutory law have propelled some scholars to argue that the greatest challenge facing women in contemporary Africa is not whether to choose customary or statutory, but rather “how to maximize their claims under either, or both” (Stewart, 1996; Whitehead & Tsikata, 2003, p. 102). According to Whitehead and Tsikata (2003), substantive changes in political, legal, and cultural practices are necessary to ensure African women’s equal rights to land and the livelihoods that accompany land ownership.

Ensuring Freedom From Gender-Based Violence

In addition to safeguarding land and land resources, ensuring women’s bodily integrity—including reproductive rights such as access to contraception and abortion, as well as freedom from physical and sexual violence—has a direct bearing on how women generally, and women in Africa specifically, experience citizenship (Lister, 2003, pp. 125–127). Guaranteeing freedom from violence is one of the ways in which women in Africa have fought for equality of citizenship in the post-independence era. To that end, scholars have argued that different forms of violence against women and girls in Africa are both a cause and a consequence of gender inequality (Ali, 2015). In particular, violence against African women inside and outside the home—be it in the form of physical abuse by an intimate partner in Tanzania; rape as a weapon of war in the Democratic Republic of the Congo, Liberia, or South Sudan; trafficking in Nigeria; female genital mutilation in Egypt, Guinea, Somalia, or Sudan; or sexual slavery, assault, or harassment in Central African Republic, northern Uganda, Sierra Leone, or South Africa—is a function of “structural gendered inequalities and pervasive gender-based discrimination” and has served to both police and punish women, thereby rendering them “lesser subjects” rather than citizens (Davies & True, 2015, p. 8; Dosekun, 2013; Jakobsen, 2014; Medie, 2019).

Yet, while this violence has been intended to silence and subordinate African women, they have used the very tenets of citizenship—agency and participation—to collectively mobilize at community, national, regional, continental, and transnational levels to challenge the scourge primarily through lobbying for anti-violence legislation, though implementation remains a challenge. For instance, countries across the continent have passed domestic violence and rape laws while brokering alliances with multilateral agencies such as the United Nations, which adopted, under the sponsorship of Namibia, UN Security Council Resolution 1325 in 2000 to address structural inequities that enable gendered violence during conflict (United Nations, 2000; Medie, 2019). In addition, women’s organizations including the Kenya-based Coalition on Violence Against Women (COVAW) have used their collective agency to combat gender-based violence as a human rights issue, in particular through advocacy and awareness raising, training, and developing networks against violence (Ali, 2015, p. 58). Similarly, women have asserted themselves as active citizens in post-independence peace processes and political settlements bringing armed conflicts to an end, particularly in South Sudan, South Africa, Liberia, Sierra Leone, and Somalia (Sabala, 2015, p. 82). They further leveraged their roles as peace-builders to champion even greater rights, resources, and representation for women post-crisis. For instance, although South Sudanese women participated only marginally in negotiations that brought about the 2005 peace agreement, they have had an impact on laws and policies that specifically address gender inequality, including the 2003 Prisons Act, 2008 Child Act, 2009 Land Act, 2009 Local Government Act, and National Gender Policy and Strategic Plan 2011–2016 (Sabala, 2015, pp. 84, 90).

Combatting Structural Violence and Second-Class Citizenship in North Africa

Although much of the literature mentioned thus far has focused almost exclusively on how women in sub-Saharan Africa have fought for citizenship rights, resources, and representation in the post-independence era, Moghadam (2003) offers a fascinating account of how North African women with feminist ideological leanings in particular have challenged structural violence and second-class citizenship largely enshrined in patriarchal family laws around property, residence, and descent—called “personal status laws” based on Shari’a or strict interpretations of Islam—and championed democratization in the region.

Morocco and Tunisia in particular demonstrate important examples of North African women subverting their second-class citizenship, given their countries’ comparatively “stronger tradition of trade unionism and socialist and social-democratic parties,” as well as higher female labor force participation (Moghadam, 2003, p. 74). While women in Morocco have advocated for equity in education, pay, political power, and development participation following the fourth UN World Conference on Women in Beijing in 1995 (Moghadam, 2003, p. 64; Sadiqi, 1999), Tunisian women have worked with government to develop and implement the Beijing Platform for Action by institutionalizing the rights of working women within the country’s labor code (Moghadam, 2003, pp. 73–74). Women’s rights groups played a prominent role in demanding reforms in the status of women in Morocco despite the entrenched nature of kinship as a prominent marker of social relations; so, it was not entirely surprising when in October 2003 the king of Morocco announced revisions to family law which favored women with respect to marriage and divorce (Charrad, 2007, p. 234). As Morocco and Tunisia demonstrate, gains have been made in the attainment of North African women’s rights, resources, and representation, yet state-level repression has remained constant elsewhere. For instance, the Egyptian state attempted to silence celebrated feminist Nawal El Saadawi with the closure in 1991 of her Arab Women’s Solidarity Association (AWSA) and its journal Nun, which opposed the Gulf War and Egypt’s participation in it (Moghadam, 2003, p. 80; Saadawi, 1995). Similarly, Islamists in Algeria have publicly disparaged women’s organizations as hezbe fransé, insinuating that they espoused colonial ideals and served the interests of France (Moghadam, 2003, p. 80).

Although all societies are stratified by gender, the North Africa region represents an extreme case of gendered stratification and subordination “manifested in the differential legal rights of women and men, women’s under-representation in political structures, and their limited access to paid employment” (Moghadam, 2003, p. 69). Because religion trumps other social institutions in much of North Africa, often elevated to that of civil status, citizenship is thus defined through the prism of religious affiliation, thus severely limiting women’s ability to inherit or own property or enter formally into contracts without the guardianship of a male relative (Moghadam, 2003, pp. 69–70). Similarly, Charrad (2007, pp. 234, 237, 243–253) argues that the kin-based societies of North Africa largely define citizenship along extended patrilineal lines, thereby producing a form of “kin-based patriarchy” that curtails women’s rights on a range of issues including marriage, divorce, polygamy, inheritance, and citizenship conferral on a child or spouse. For Algeria and Morocco, “lineages and kin-based social formations remained central elements of the social structure and anchors for political power,” thereby limiting the individual rights of women (Charrad, 2007, p. 239). Nevertheless, while Morocco’s and Algeria’s post-independence legal systems tend to privilege kin-based relations, thereby subordinating the individual, Tunisian law provides more scope for individual rights, including those of women.

In what Moghadam (2003, pp. 70–71) describes as neo-patriarchal states in North Africa and the Middle East in particular, male citizens have few political rights, and women citizens have even fewer. In North Africa, generally, rights are often defined by gender, region, and religion; universal rights enshrined in constitutions are not universally applied or enforced; and traditional patriarchal norms are dominant through strict adherence to Shari’a (Moghadam, 2003, pp. 66–67, 70). For example, while former Egyptian president Nasser seemingly adopted feminism as a guiding political principle, allowing women unfettered access to education and employment in the public sphere, his regime failed to address or challenge discriminatory family laws severely limiting women’s rights in the private sphere (Moghadam, 2003, p. 71). Despite attempts to relegate North African women to second-class citizenship under the veil of religious fundamentalism, with varying levels of success women across the region have led movements to modernize family laws, criminalize gender-based violence, enable women to retain their own nationality and pass their nationality on to their children, and grant women greater access to employment and political decision-making (Moghadam, 2003, p. 72).

Conclusion: Moving from Rights to Justice

This article has adopted a feminist lens of analysis to examine how African women’s citizenship—defined as legal status with attendant rights, resources, representation; and as practice through active political participation—has evolved from independence onwards. Although the rights discourse has predominated in women’s struggles for equality of citizenship across the length and breadth of Africa, and has framed the contours of this article, some scholars correctly argue that equality is fundamentally about ensuring justice rather than simply instituting procedural rights:

“Rights” have levelling and universalised legal meaning. “Justice”, on the other hand, is far broader, and implies a holistic understanding of ways in which certain groups and institutions can prevent others from realising their different liberties . . . Through rights discourses, gender mainstreaming consequently constructs universal subjects as passive recipients, impedes their agency in driving change, thereby foreclosing possibilities for them to drive alternative gender transformation in society and privileges the subject positions of globally and regionally dominant subjects.

(Lewis, 2009, pp. 209, 212)

Although citizenship is often framed as a system of rights, the rights-based approach to securing equality has been fiercely critiqued for being unaccountable to the socially weak, “legalistic, top-down, and relying excessively on supranational legal frameworks, formal legal instruments and institutions,” and thereby detrimental to the “priorities and practices of people who frame and make rights claims in struggles over resources or social power” (Goetz, 2007, p. 26; Nyamu-Musembi, 2007, p. 177).

Goetz (2007, pp. 30–31) and other scholars recommend advocating for gender justice rather than the more mainstream gender equality or women’s empowerment, because gender justice demands accountability by power-holders and addresses structural inequalities “that result in women’s subordination to men.” Scholars have also asserted that because citizenship is gendered, removing legal barriers to full citizenship rights for women, though necessary, is ultimately an insufficient condition for achieving equality, and this general belief is true for African women (Tickner, 1992). For example, in her analysis of why women in Ghana fail to win competitive elections—and are therefore inadequately represented in political decision-making—Darkwa (2016, p. 247) argues that legal frameworks and regulations that purport to protect the rights of women in public and private spheres do not challenge the status quo sufficiently. Feminist scholars have repeatedly posited that an emphasis on “legal rights” is too narrowly focused on the citizen–state relationship, preferring instead to analyze barriers that may inhibit women from engaging with the world as autonomous human beings.

While changing legal frameworks around citizenship may not address African women’s lived experiences of inequality entirely, Manby (2009, p. 22) has argued convincingly in her analysis of the struggles for citizenship in Africa that “a denial of the right to citizenship itself under national law is often central to the denial of other rights,” and that the legal right to citizenship is the foundation of all other rights including the right to vote or hold public office, the right to healthcare and education, the right to freedom of movement, and the right to land. Similarly, Seely et al. (2013) contend that laws make manifest “unwritten social conventions,” and are therefore important markers of what societies deem legitimate and just. Thus, the literature suggests that conceptualizations of citizenship remain varied and nuanced in Africa, and that debates about how women’s equality of citizenship can be anchored in law, practice, and lived experience will continue to prevail.


This article benefited immensely from the research assistance of Dzifa Hoyah.

Further Reading

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  • 1. Although African women have held prime ministerial positions in a number of countries, these posts have been largely symbolic.

  • 2. Only five African women have served as presidents since the advent of multi-party democracy in the 1990s—Ellen Johnson Sirleaf of Liberia, Joyce Banda of Malawi, Bibi Ameenah Firdaus Gurib-Fakim of Mauritius, Catherine Samba-Panza of Central African Republic, and Sahle-Work Zewde of Ethiopia—with only Sirleaf of Liberia and Gurib-Fakim of Mauritius assuming power through elections.

  • 3. It is worth noting that gender-disaggregated data for other contemporary African female heads of state—including Joyce Banda of Malawi and Ameenah Gurib-Fakim of Mauritius, who was subsequently impeached—is scarce.

  • 4. While the numerical representation of African women at parliamentary and legislative levels is steadily increasing, thus surpassing the rest of the world, the number of African women occupying chieftaincy positions is dismally low. This is of particular concern because traditional leaders tend to wield considerable power in rural governance structures (Cheeseman, Onditi, & D’Alessandro, 2017, p. 2).

  • 5. Tamale (2008, pp. 58–59) argues that even within matrilineal societies in western, central, and southern Africa, where “inheritance and authority passes through women to the male of the line,” patriarchy reigns supreme.