Why France is tied in knots over girls who wear the scarf

The French shed blood to overthrow clerical power and establish republican values. They still believ

When I was at school in Sussex the day would start with prayers and a rousing hymn, prior to which the headmaster would invite Catholics, Jews and Jehovah's Witnesses (I don't think we had Muslims then) to step outside while the rest of us soldiered onward for the Church of England. Looking back now, I feel a little uncomfortable with the assuredness of it all. Mine is small discomfort, however, beside that of the French nation in the face of a slip of cloth.

Tied and worn by Muslims as a headscarf, the piece of cloth has snagged the foundations of the French republic. The cornerstone of liberty, equality and fraternity looks all awobble.

France is headstrong about keeping religion out of the public sphere, in which the British make no bones about placing it. The British maintain the curious custom of having a monarch at the head of an established church and, more curious still, the prime minister appoints bishops. Thus, the British instinct is to be flexible towards teenage girls covering their heads with a scarf in school. State schools are required to provide religious instruction and prayers of the Christian persuasion, while remaining sensitive to the beliefs and dress codes of other cultures. Head teachers who insist on uniform generally refrain from chastising pupils for embellishing it with a Muslim veil, a Jewish skullcap or a Sikh turban. Like most other European countries, Britain tends to encourage different cultures to subsist within the nation.

Not so France. It is hard for foreigners to grasp just how strongly the French feel about the separation of church from state. Their stand is: worship as you will, but keep it out of public places. Witness their writhing over George Bush's habit of locating God in the White House. Their word for keeping religion at bay is laIcite, which I won't try to translate: secularism is much too tame. Rather, it is a force of passion, reforming zeal and intransigence born in the French revolution; it remains foremost among republican values, resounding with the rumble of tumbrels.

Every French schoolchild learns that the clergy were brought to book with the aristocracy in the 1789 revolution. The Catholic Church continued to have its ups and downs thereafter, but never regained the stifling control it had had over society. The worst bloodshed of the revolution was not in rushing aristocrats to the guillotine, it was in civil war in the west, where a population loyal to the Church and the ancien regime was massacred by "squadrons of death" despatched by the new masters in Paris. Indeed, bloody wars of religion mark France's history from much earlier times.

The French see laIcite, then, as a national accomplishment marked with their blood; it has become a religion in its own right. And it is most fervently established in the state school system. Freedom of thought is one goal; another is to give all children the same chance in life regardless of cultural background (this ideal does not always work out as it should). The overall objective is assimilation into an ideal French society of liberty, equality and fraternity. But the principle is coming under increasing challenge from Arab immigrants from North Africa. In an Arab population of close to five million, including those born in France, only a small minority seems driven by Islamic fundamentalism. But militancy flashes just where the republic is at its wariest - in the classroom.

Aside from constant clashes over dress for gym classes and swimming, stand-offs between teachers and girls arriving veiled for class are everyday incidents in big-city suburbs crammed with council estates. This is a dire test for teachers, whose republican vows make them laIcite's front-line soldiers (not least when they themselves are Muslims, as they often are in the cities).

The current rumpus concerns two scarf-wearing teenage sisters who were barred from school in suburban Paris and expelled for good on 10 October for overdoing their display. Their father, a lawyer, is Jewish and their mother, of Algerian origin, practises no religion. So Lila and Alma Levy are acting on their own. Or are they? Religious conviction apart, teenage girls from big-city housing estates may wear the headscarf for a variety of reasons: as a hands-off warning to sexual aggressors, a token of rebellion, a show of identity, or a stand against discrimination. And the sisters logically ask, why single out the headscarf? French schools don't have uniforms; pupils wear what they want. What about girls coming to school in gothic gear with rings in their eyebrows? And boys parading their faith in Marseilles football club shirts?

All the same, the sisters' defiance has given rise to speculation that they are being manipulated by extremists. In the latest elections to France's Muslim Faith Council, fundamentalists displaced long-serving moderates in Paris. Tensions within the immigrant population sparked by the war on Iraq and developments in the Middle East have concentrated media attention on incidents related to religious fury - most recently the death of a teenage Arab girl, burnt alive in a suburban Paris dustbin by a boyfriend who accused her of defiling the rules of Islam by looking at other boys.

The veiled sisters dug in just as President Jacques Chirac, supreme guardian of republican ideals, was launching a commission to look into the problem of the veil and resolve how best to uphold laIcite. Its hearings in the French senate are televised live. A sense of emergency is gripping true republicans. "When I enter a mosque, I remove my shoes," argues Nicolas Sarkozy, the minister of the interior. "When a Muslim girl enters school, she must remove her veil." Sounds simple, but the logic is flawed. The mosque is a place of religion, school in France the very opposite.

To make matters still trickier, the conflict turns around legislation dating from 1905, which conclusively separated church from state. The act now looks its age but, because it hit straight at the Catholic Church and the vestiges of its political power, it allows those who now aim to outlaw the veil in schools to argue that France is faith-neutral and not out to discriminate against Islam.

The essential thing, they say, is for teachers to have clear rules to go by. Anything less saps their authority. At present they work to an ambiguous constitutional directive from the 1980s which says that Muslim girls can wear headscarves in school at a pinch - provided they aren't worn ostentatiously, or represent a threat to public order. Some ministers, like Francois Fillon (social affairs), want a law to ban the headscarf once and for all from schools and from the broader service of the republic (tax clerks, town hall staff). Others recognise that France today is a multicultural society, not the integrated one that laIcite strives for and French governments dream of. Sarkozy, a Hungarian immigrant's son who wants to succeed Chirac as president, fears that a legislated ban could create "martyrs". Better to find a more politically astute way to induce French Muslims to put aside their customs.

That could require laIcite itself to loosen up. The world has changed since 1905. There is much greater emphasis on individual liberties. Indeed women's liberty is at the heart of the current conflict. French values are affronted by the seeming oppression of Muslim women in the name of Islam, yet are also responsive to the idea of women who live in culture-clashing environments being able to take their own measures to head off harassment.

What about a return to school uniform? State school pupils wore blue smocks until at least the 1960s, when someone decided, it seems, that the offence to liberty outweighed the contribution to equality. France might also ease the problem by naturalising immigrants more freely; it wants everyone to toe a cultural line, yet is niggly about awarding nationality.

In the end, republican values may be best upheld by turning a blind eye. Headscarf-wearers driven by genuine religious conviction would then turn few heads, while those set on protest or provocation in schools would lose their stage and eventually tire of it. This is, ahem, the British solution. Alas for the republic, it is hard to think when the French last looked across the Channel for cultural guidance. My headmaster would have appalled them.