(An earlier version of this article, titled “Gender Apartheid and the Discourse of Relativity of Rights in Muslim Societies” appeared in Courtney W. Howland, ed., Religious Fundamentalisms and the Human Rights of Women (New York: St. Martin’s Press, 1999)). 

I. Introduction
In modern times, women have moved from the margins to the center of history playing increasingly important roles in families, communities, and states across the world. As women became increasingly aware and assertive, their demands for equality, participation, and access elicited reactions that range from curtailing their right to the privacy of their bodies and minds to policies that deny them experiences that are essential to their ability to compete in society. The infringement of women’s rights is usually exercised in the name of tradition, religion, social cohesion, morality, or some complex of transcendent values. Always, it is justified in the name of culture.

Nowhere is this better demonstrated than in Muslim societies where over half a billion women live in vastly different lands, climates, cultures, societies, economies, and polities. Few of these women live in a purely traditional environment. For most of them modernity represents, above all, conflict among contradictory values and forces that compete for their allegiance and call them to contradictory ways of looking at themselves and at the world that surrounds them. The most taxing of these contradictions is the one between the everyday requirements of living in the contemporary world and the demands advanced by the fundamentalist worldview, which singles out women’s status and her relations to society as the supreme test of the authenticity of the Islamic order. Fundamentalist movements as varied as Jama`at- i Islami in Pakistan, Ikhwan al-Muslimin in Egypt, FIS in Algeria, and the ruling elite in the Islamic Republic of Iran, rely for their legitimacy on various renditions of tradition that they assume invests social structures and mores with an ethic of gender relations appropriate to Islam. This ethic is symbolized by the institutions of andarun and purdah, which, historically, have translated to gender apartheid in the Islamic world. The ethic and the symbols, however, are becoming increasingly porous as Muslim societies, including a significant number of Muslim women, outgrow and transgress traditional boundaries.

It is important to note that the status of women in society–socially, politically, legally, economically–has been fundamentally the same across history for a majority of the world’s population. Except for surface differences in manner and style, the basic arrangements for division of labor and power between men and women have been the same across the world. A woman’s rights over major decisions about her children’s future, place of residence, marriage, inheritance, employment and the like have been severely curtailed in most of the world during most of human history. ¹ Until the beginning of the 20th century, when New Zealand became the first country to give women the right to vote, there was no place on earth where women shared in the political process. Nor did they have the same chance to train for a job, get a job, or, once having gotten it, receive equal pay. Indeed, in some of these areas, especially in the area of ownership of land, Muslim women fared better than women in the West.² Significantly, the first fundamentalist movement started in the United States at the beginnings of the 20th century.³ Protestant fundamentalism came into existence very much in response to the modern age, and especially the new visibility and mobility of women. Everywhere, change in women’s status has meant a change in the culture of patriarchy. In other words, cultural change is both a byproduct and requisite of change in women’s status.

The contemporary threat to women and their rights in the Muslim world springs mainly from a resurgence of radical fundamentalist thought and politics in the last quarter of the 20th century. The fundamentalist resurgence forces Muslim women to fight for their rights, openly when they can, subtly when they must. The struggle is multifaceted, at once political, economic, ethical, psychological, and intellectual. It resonates with the mix of values, mores, facts, ambitions, prejudices, ambivalences, uncertainties, and fears that are the stuff of human culture. Above all, it is a casting off of a tradition of subjection. Islamism reduces this complex, historical struggle to a metaphysical question. It does so by casting society in an idealized Platonic “Form” and by equating culture with the dogmatics of religion. This representation is functionally supported by an important strain in contemporary international discourse that takes off from the Islamic fundamentalists’ assignment of private and public space to women rather than from freedom and equality as the core assumptions appropriate to modern times. Akin to a presumption of guilt in a court of law, this discourse reverses a universally accepted rule. To the extent that Islam, defined and interpreted by traditionist “Muslim” men, is allowed to determine the context and contour of the debate on women’s rights, women will be on the losing side of the debate because the conclusion is already contained in the premise and reflected in the process. This is the heart of the moral tragedy of Muslim societies in our time.

There are many reasons for the recent resurgence of Islamic fundamentalism, ranging from failure of socio-political and economic structures at home to neo-colonial pressures. To understand the reasons in each case of Islamist resurgence is important for devising appropriate strategies for improving women’s rights and status. However, no justification of the causes of economic failure, religious revival, or nationalist fervor may be validly used to justify the subjugation of women. My purpose in this article is to show that neither Islam nor the culture of Muslim peoples is per se an obstacle to women’s achieving rights. Rather, Muslim women face patriarchal structures that certain men in power or seeking political power misrepresent as religion and culture. The function of this misrepresentation is to keep women where they best serve the patriarchal priorities. Where the civil society has already somewhat developed, for example Iran, the fundamentalist clerics seek to force women back to conditions women have surpassed and, therefore, find unacceptable.

The resulting tension between the attempt at establishing various degrees of gender apartheid in Muslim societies and women’s determination to secure and preserve their human rights has led in recent years to widespread and continuous violence. In Afghanistan, the Taliban has in fact forced women into total segregation, denying them any right or venue to participate in the affairs of society. ⁴ In Algeria, a veritable war of attrition is raging where women are primary victims. ⁵ In Iran, the Islamic Consultative Assembly, the Majlis, passed a bill last year that makes it illegal for newspapers and magazines to publish pictures of women, even when veiled, on their front pages, ⁶ and another segregating hospitals and prohibiting male physicians to attend to female patients. ⁷ All this is justified in the name of religion and culture.

The Islamist revival has succeeded in turning its representation of Islam into a dominant discourse not only in most Muslim societies but also in the West. The Islamist discourse seeks to establish a particular rendition of Muslim religion as the true image of Muslim societies as they “actually” exist. This presumed image is then presented as the actual “culture” of the Muslim people. All “rights” then, including Muslim women’s, naturally flow from this culture. The Islamists present a cohesive, logical, and harmonious concept of women’s place in society containing set answers to women’s economic, social, ethical, and psychological needs. Gender apartheid is clearly defined in all laws and regulations pertaining to the role of women within the private and public spheres. Inheritance, dowry, guardianship, personal and professional boundaries, and other rules that limit women’s spaces and movements are all worked out so that women’s dependent and separate sphere is justified, protected, and perpetuated. Within this construct, women do not have rights as defined in the international documents of rights; rather, they have privileges that issue from the Qur’an, the shari`a, and the hadith, and supported by folklore and myth. ⁸ This vision is supported by the Western “Orientalist” understanding of Islam that tends to identify a concept of “Islamic ideal type” with the practice of living in the real Muslim world. ⁹The Orientalist construct plays into the hands of the Islamists insofar as the latter pretend that Islam is both ontologically and epistemologically different from other religions. The Islamists argue that Muslim societies are fundamentally different from Jewish, Christian, or other societies. Muslim societies, unlike the others, remain religiously authentic despite the West’s political hegemony and cultural onslaught. The non-Islamic traits in Muslim societies are aberrations resulting from colonial intrusion, and need to be eradicated.¹⁰

Statements by Muslim religious leaders about women’s rights, however, are rarely clear because of the ambiguity of meaning when words are used in different contexts. Terms such as freedom, equality, equity, justice, authenticity, humanity, legitimacy, law, law- abiding and the like are complex, and change meaning depending on who utters them and where and why. It is therefore essential to a fair understanding of them always to contexualize them. For example, to grasp the implications of Ayatollah Khomeini’s Islamic Government ¹¹ one must not only read it in its entirety but also place it within his worldview. Only then one begins to understand from where the authority for arranging the affairs of society issues, who is competent to interpret this authority, and why is it one’s obligation to obey the rule of the faqih, or the competent jurist. Furthermore, that understanding is reflected in the Constitution of the Islamic Republic, which, on the one hand, sets forth the structures and rules that are to implement it, and, on the other hand, uses phrases about civic rights that seem to be taken verbatim from any modern social democratic document. ¹² The so-called “moderate” Muslim leaders usually speak with even less clarity, or, because listeners tend to understand utterances in terms of their own frames of reference, are not easily understood. When Iran’s President Khatami speaks of qanunmandi, “the rule of law,” most observers assume that it denotes the commonly understood concepts in secular law, when, in fact, he means, as he himself has insisted, the law as contained in and derived from the Islamic Republic’s Constitution. ¹³ The confusion, resulting partly from contextual difference, partly from deliberate subterfuge, and partly from the receiver’s wishful thinking, however, is not always a handicap, because it creates room for dialogue.

II. The Relativist Discourse
The Islamist position on women’s rights is advanced on two levels–one internal, the other external to the Muslim community. Internally, the argument invokes Islam and the inviolability of the text. The formulation is intellectually rigid, but politically well organized and ideologically inter-connected across the Muslim world through chains of “traditions,” clerical fatwas, and periodic government resolutions and legislation. Muslim women in significant numbers and from all social strata are currently objecting to this interpretation of Islam. The dimensions of the struggle are being defined as Muslim women strive for rights across the globe: what these rights are, how they relate to Islam epistemologically, how they resonate with social and political power in specific Muslim societies, and how strategies that seek to promote them will or should be developed. High on the list are the ways and means of interpreting religious texts: how should women approach the issue, what sort of expertise is needed, how can the issue be bridged to grassroots leaders, how may the intelligence received from the grassroots be brought to the interpretive process? Scholars and activists are also looking into ways of educating the Muslim political elite: how to identify responsive decision-makers, how to communicate reinterpreted text, how to develop criteria for judging the limits of political engagement, how to help executives, legislators, and judges sympathetic to women’s human rights to implement change in the condition of women. They are also searching for appropriate patterns of mobilizing grassroots support, including ways of identifying women leaders at different levels, communicating methods of pressuring political decision-makers, and, most important of all, protecting women activists against moral and physical violence. The list, obviously not exhaustive, nevertheless signifies the dynamics of the relationship between women’s human rights, politics, and the Islamic texts.

Externally, the Islamist position meshes with the idea of cultural relativity now in vogue in the West, where relevant arguments are waged for reasons that usually transcend the problem of right in its elemental form. The argument from relativity is based on two sets of assumptions. The first has to do with our understanding of culture. Webster’s Dictionary defines culture as “the training and refining of the mind, emotions, manners, taste, etc.; the concepts, habits, skills, arts, instruments, institutions, etc. of a given people in a given period; civilization.” ¹⁴ There are two distinct strings of meaning in these definitions. The first suggests the best in the arts, manners, literature, music, philosophy, science and all the other refined attributes that a civilization has achieved. This meaning of culture is common to all societies. It is also the reason why people everywhere and always have been sensitive to the word itself.

The emotional attachment to this meaning of culture often creates misunderstanding when the second meaning is intended. The second set of meanings, namely, the concepts, habits, skills, arts, instruments, etc., constitutes the more modern meaning attached to the term and is originally an invention of the Western social scientists who studied primitive societies in modern times. ¹⁵ These societies exhibited social habits that had remained substantially unchanged over time. They resembled “ideal types,” or, rather, they were construed as ideal types which, nevertheless, actually existed. The idea of culture derived from these societies was then extended to the study of “traditional societies,” i.e., the non-Western peoples. A curious result of this process is that the Orientalists’ reports of traditional Islamic societies serve to support contemporary fundamentalist claims to legitimacy in so far as they suggest an ideal type Muslim society actually existing before it was corrupted by the West.

This interpretation of culture is inapplicable to contemporary Muslim societies. There are over a billion Muslims in the world living, as mentioned, under different laws and vastly different customs. Even though they all identify themselves as Muslims, they do not all understand or practice Islam in the same way. What is perhaps common to all is variety and contradiction resulting from uneven development. One must make a deliberate effort not to see the profound differences that exist–that have always existed–between the majority of Muslims who live in South and South East Asia and others who live in the Middle East, Central Asia, or Africa. Furthermore, all of these societies have undergone significant social, economic, and cultural change in the twentieth century. More importantly, each of these societies has experienced change unevenly. Consequently, in any Muslim society different social types hold different mixes of indigenous and imported values. Often, these mixes create new forms, which are neither Western nor traditional. One might say they are modern in the sense of contemporary. The modern Muslim society is a mix of values, mores, and emotional responses. This is why any system of government that wishes to force uniformity on this dynamic variety will necessarily have to use considerable violence. Because the fundamentalist Islam’s worldview is defined mostly by its treatment of women, wherever Islamism has assumed power or otherwise become politically active women have born the brunt of the violence.

The second error in the argument from relativity emerges from the difference in the foundations of the argument in the West and in the Islamist or other authoritarian circles. The relativity argument has been in vogue for some time in the Western academe. Its adherents base it on a claim to freedom of choice, particularly freedom to choose elements of cultures different from those of the white, Christian, European/American male. The claim assumes that the individual has the right to choose but governments or social forces are stifling this right. The moral force of the argument derives from a universalist conception of individual freedom and human rights.

The Islamist position is quite the opposite. It says essentially that there exists no right outside the cultural norms defined by a designated group of “experts” to which individuals may appeal. This position denies that there is such a thing as universal rights. Rather, it insists that all rights are derivatives of Islam as interpreted by a select group of men. Most Muslim women object to this rendition of Islam or their rights. The Islamists use the confusion resulting from the similarity in terminology to advance their position by introducing the idea of cultural imperialism–a politically and emotionally potent subject that is nevertheless irrelevant to the argument. By suggesting that the West has invented the idea of universality of rights in order to impose its way of life on others, the Islamists attempt to disparage the validity of the argument for rights in the eyes of their peoples, including women. In this, they have been assisted by other “authoritarian” leaders, ranging from the Chinese to those in the Vatican. ¹⁶ The central point in women’s human rights is simple. Muslim fundamentalists always posit the question of women’s rights within an Islamist frame of reference. That frame of reference determines the boundaries of the existence of every Muslim woman. The question I as a Muslim woman ask is: Why should I not have the right to determine how to organize my life? What gives another person the right to interfere in my personal life? Why is it that a Muslim cleric arrogates the right to forcibly place me in a preordained framework? Does he derive his authority from God? Does he derive it from the text? Does he derive it from tradition? I reject all these claims. I argue that as a Muslim woman I know in principle as well as any man what God ordains or what the text says. I argue that tradition is no longer a valid source because societies change, cultures change, I change, and I am both willing and able to discuss these points with him. Before we begin this discussion, I grant him every right to be who he wants to be; to do what he wants to do; to preach what he wants to preach. I only demand that he does not force me to do what he wants me to do against my wish, in the same way that I do not force him to do what I wish. And here is my frame of reference.

This frame of reference has nothing to do with the East, West, South, or North. It has nothing to do with color, creed, race, sex, or religion. There was a time when in the name of Christianity they burned women at the stake as witches because their behavior did not conform to the prevailing norms. Those who committed the murder justified their action by reference to Christian principles. Slavery was once the norm everywhere. Women were kept out of social and political decision-making across the world. But times have changed. Christians have changed. Jews have changed. Muslims have changed. To the extent that this change has made me aware of my person as having a specific identity that I recognize independently of my race, creed, nationality, or religion, to that extent I resent and reject being forced to do things that I do not wish to do by reference to any of these properties. Indeed, any act of forcing me to do something against my will is an act of violence. The frame of reference, therefore, has to do with acceptance of the reality of change. It has to do with the fact that there exists no longer a monolithic Islam if there ever was one. And that, therefore, to justify acts of violence by an appeal to Islam is disingenuous.

Clearly, this is not simply a question of law–religious or secular. Secular law may be as repressive as religious law. Rather, it has to do with the historical development of a kind of individual consciousness that defines the meaning of right. History moves from law to right; that is, from norms that have been given before the fact to norms that are established by participation and by dialogue among free individuals. Rights, therefore, can not be severed from freedom.

Considered in this light, right is not only a property of the relationship between government and individual. It is, more importantly, a matter of individual space within the social system. It is the ability of a woman to speak, to move, to work, and to choose freely. Millions of Muslim women in Muslim societies demand but are denied this leeway by their governments or by the more powerful members of their male-dominated societies. Islamists complain that “whereas the claims of democratization by the Nasserists, the Ba`thists, and the Marxists are believed, the Islamists continue to be distrusted and their intentions doubted.” I am not at all sure that Muslim women trust these groups. Nevertheless, there is a fundamental difference between the Islamists and all of these other movements, that is, the authoritarian nature of state-society relations notwithstanding, all of the above-mentioned systems validated, at least on paper, women’s claims to equal treatment under the law. Furthermore, none of these systems argued from principle that gender apartheid, women’s unequal and complementary place in society, is preordained by immutable law. How many Islamist leaders are willing to make a statement such as this unequivocally? How many Islamist leaders are willing to state unequivocally that women’s rights are theirs by virtue of the fact that they are human beings?
Right is also related to obligation, morally and instrumentally. This is the most central point to the concept of right, namely, that to demand it for yourself you must defend it for others. This also is an important aspect of the frame of reference. The statement sometimes made that rights are stressed now whereas historically the accent has been on obligation needs clarification. To the extent that obligation represents legitimacy you are never less obligated because you have rights. Rights, in fact, create obligation, because they are always intertwined with legitimacy. Simply put, we cannot have rights without obligation because we cannot have rights that are not reciprocal. But we can be forced to perform tasks under threats that are disguised as obligation. This is precisely what many women in contemporary Muslim societies are forced to suffer and valiantly object to.

Muslim women who strive for recognition of their rights are not oblivious to history. They realize that cultures do not change uniformly, and therefore there are others in Muslim societies, men and women, who interpret reality differently than they do. This fact of cultural multiplicity, important as it is politically, nevertheless does not alter the moral foundation of their position–the frame of reference that rejects force and violence in religion and which respects the identity, privacy, freedom, and integrity of the human individual. This position recognizes that religious experience is a personal experience, and that all enforcement of religion are essentially not religion but political acts of violence that are perpetrated by one group of people over another. The basic principle, therefore, that “I” as a human being have the right to choose is, by definition, a universal principle–it is morally true whether I live in New York, Beijing, Katmandu, or Tehran. The fact that in practice I may not be able to exercise it everywhere is a matter for political and social analysis and action.

This point leads us to the relativity of means, which is a matter essentially of politics and implementation. There are many different ways to promote human rights across the world. The efficiency of approach usually is geared to the prevailing cultural and political conditions. Clearly, all of us must seek dialogue. Not only because we need to communicate if we are to effect change, but, perhaps, also for a more fundamental reason. Right is not a property of any particular culture. It is a product of the evolution of human consciousness and the demands that the process produces. If so, then right has more to do with the possibility of individual choice than the choice itself. Thus, each culture may produce its system of rights, provided that the frame of reference, the universality of the possibility of choice and freedom, is maintained.

III. Conclusion
The international community now recognizes that women’s rights are human rights and human rights are women’s rights. These positions are recorded in several international documents, including, among others, the Universal Declaration of Human Rights (1948), International Covenant on Economic, Social and Cultural Rights (1966), International Covenant on Civil and Political Rights (1966), Convention on the Elimination of All Forms of Discrimination Against Women (1981), UN Declaration of the Elimination of Violence Against Women (1993), and the Vienna Declaration and Programme of Action adopted by the World Conference on Human Rights (1994). The main points of these documents were encapsulated in the Mission Statement to the Platform for Action of the Fourth World Conference on Women (Beijing, 1995), of which the first article is partly as follows:

The Platform for Action is an agenda for women’s empowerment This means that the principle of shared power and responsibility should be established between women and men at home, in the workplace and in the wider national and international communities. Equality between women and men is a matter of human rights and a condition for social justice and is also a necessary and fundamental prerequisite for equality, development and peace. A transformed partnership based on equality between women and men is a condition for people centered sustainable development. A sustained and long term commitment is essential, so that women and men can work together for themselves, for their children and for society to meet the challenges of the twenty first century. ¹⁷

This worldview has been reinforced in recent times by the changes that have occurred throughout the world–changes that constitute the reality of out time. The argument and symbolism now advanced by Islamist patriarchs under the guise of religion is very similar to the argument and symbolism advanced nearly a century ago by the fundamentalists in the West. The English and American suffragettes faced the same opposition, vilification, ridicule, and attacks on their morality as contemporary Muslim feminists. The crass infringement of women’s rights we see in the Muslim world has more to do with power, patriarchy, and misuse of religion as political weapon than with religion properly understood as individual faith. The Islamists draw on the discourse of relativity, now in vogue in the West, to deny or infringe women’s rights by introducing or perpetuating a system of gender segregation. This, we must oppose.

On the occasion of the 50th anniversary of the Universal Declaration of Human Rights, UN Secretary General Kofi Annan stressed the fundamental bond that ties human rights to human nature. He said human rights did not belong to any government, nor were they limited to any continent. Rather, they belong to everyone. He called for prompt action to prevent the violations of human rights, saying that it was not enough to tell the victims of human rights abuses that ”we have done our best.” He emphasized “the need to prevent such violations. ” ”I am here to tell you that the next century must be the age of prevention,” he said. ”Let this be the year in which the world once again looks to the Universal Declaration of Human Rights, as it did 50 year ago — for a common standard of humanity for all of humanity.”¹⁸

In this, I believe, he should receive our support.

In Women, Gender, and Human Rights: A Global Perspective • Marjorie Agosín (ed.) • Rutgers University Press • 2001

1. See generally WOMEN, RELIGION AND SOCIAL CHANGE (Yvonne Yazbeck Haddad & Ellison Banks Friendly, eds.) (Albany: State University of New York Press, 1985).
2. For example, until the mid-nineteenth century, at common law in the United States, once a woman married, her personal property became her husband’s property and her real property became subject to his control for the duration of the marriage. See CORNELIUS J. MOYNIHAN, INTRODUCTION TO THE LAW OF REAL PROPERTY 52-54 (St. Paul, Minn.: West Publishing Co., 1962.) In contrast, the Qur’anic legal system of centuries before gave a woman the right to own and manage property herself, and to keep possession of it after marriage. See JOHN L. ESPOSITO, WOMEN IN MUSLIM FAMILY LAW 24 (Syracuse, N.Y.: Syracuse University Press, 1982).
3. See Nancy T. Ammerman, North American Protestant Fundamentalism, in 1 THE FUNDAMENTALISM PROJECT: FUNDATMENTALISMS OBSERVED 1, 2 (Martin E. Marty & R. Scott Appleby, eds.) (Chicago and London: The University of Chicago Press, 1991).
4. For a description of the restrictions on women in public and private life, see PHYSICIANS FOR HUMAN RIGHTS, THE TALIBAN’S WAR ON WOMEN: A HEALTH AND HUMAN RIGHTS CRISIS IN AFGHANISTAN 30-34, 113-19 (Appendices A,B,C) (U.S.A.: Physicians for Human Rights, 1998).
5. See Karima Bennoune, S.O.S. Algeria: Women’s Human Rights Under Siege, in FAITH AND FREEDOM: WOMEN’S HUMAN RIGHTS IN THE MUSLIM WORLD 184 (Mahnaz Afkhami, ed.) (London and New York: I.B. Tauris & Co. Ltd., 1995).
6. See The Islamic Republic News Agency (visited Mar. 17, 1998) http://www.netiran.com/dailynews.html (English version)
7. See Dawn Corbett, Women Around the Globe Face Threats to Human Rights, Fall 1998, National NOW Times, at 11. This bill was rejected by the Council of Guardians, a higher legislative body, on the grounds that there were not enough funds to cover implementation, and it was sent back to the Majlis. See Segregated health services’ [sic] bill rejected in Iran, Deutsche Presse-Agentur, Oct. 14, 1998, available in LEXIS, World Library, Allwld file; Iranian authority rejects hospital segregation bill, Agence France Presse, Oct. 14, 1998, available in LEXIS, World Library, Allwld file.
8. See Mahnaz Afkhami, Introduction, in FAITH AND FREEDOM: WOMEN’S HUMAN RIGHTS IN THE MUSLIM WORLD, supra note 5, at 1-15.
9. The early European travelers to the Islamic Middle East called it the Orient, and thus they are generally referred to as the Orientalists. For a critique of Orientalist texts, see EDWARD SAID, ORIENTALISM (New York: Pantheon Books, 1978), who argues that Western scholarship on the Orient is based on racist assumptions and “ineradicable distinctions between the West and the Orient.” See ANN ELIZABETH MAYER, ISLAM AND HUMAN RIGHTS: TRADITION AND POLITICS 6 (Boulder/Oxford: Westview Press, 3d ed., 1999).
10. The present leaders of the Islamic Republic of Iran make a point of regularly emphasizing the perils of the West’s cultural invasion of all Muslim countries. They differ on how to face the challenge. For ongoing examples of the leaders making such presentations, see The Friday Sermons at Tehran University, which are translated and published by the Islamic Republic’s News Agency, http://www.irna.com/headlines.
11. See AYATOLLAH RUHOLLAH KHOMEINI, ISLAMIC GOVERNMENT (trans. Joint Publications Research Service) (New York: Manor Books, 1979). 
12. Compare art. 4 (“All civil, penal, financial, economic, administrative, cultural, military, political, and other laws and regulations must be based on Islamic criteria.”) with art. 3 (14) (“securing the multifarious rights of all citizens, both women and men, and providing legal protection for all, as well as the equality of all before the law”) of the CONSTITUTION OF THE ISLAMIC REPUBLIC OF IRAN OF 24 OCTOBER 1979 AS AMENDED TO 28 WORLD 18 (Albert P. Blaustein & Gisbert H. Flanz, eds.) (Dobbs Ferry, N.Y.: Oceana Publications, Inc., 1992), excerpts reprinted in MAYER, supra note 9, at 193-201 (Appendix A).
13. See CNN Special Event: Iran: A New Opening, CNN television broadcast, Jan. 7, 1998, available in LEXIS, News Library, Script File (Interview with Pres. Khatami).
14. WEBSTER’S NEW TWENTIETH CENTURY DICTIONARY OF THE ENGLISH LANGUAGE, UNABRIDGED 444 (n.p.: William Collins + World Publishing Co., Inc., 2d. ed., 1975).
15. See, e.g., BRONISLAW MALINOWSKI, A SCIENTIFIC THEORY OF CULTURE AND OTHER ESSAYS 1 (Chapel Hill: University of North Carolina Press, 1944). For a comparison of various theories of culture, see CHRIS JENKS, CULTURE (London: Routledge, 1993).
16. For example, the Vatican joined Islamists to protest the 1994 Conference on Population and Development, in Cairo, and its Programme of Action. See Mark Nicholson, Fears of Violence Stalk Cairo Conference, FIN. TIMES, Sept. 1, 1994, at 4.
17. Beijing Declaration and Platform for Action adopted by Fourth World Conference on Women, adopted Sept. 15, 1995, annex II, chap. 1, para. 1, at 10, U.N. Doc. A/CONF.177/20 (preliminary version), 35 I.L.M. 401, 409 (1996).
18.  See Hamshahri, Iranian Daily, (Persian version) http://www.neda.net/hamshahri/770713/siasi.htm.