While it's the lone Canadian province having a full-on debate about restricting Islamic face-coverings, Quebec is one of many places in the world implementing such sartorial clampdowns.

A look at the international portrait offers at least two interesting revelations.

First, Quebec's proposed burka restrictions would actually be middle-of-the-road in terms of severity, compared with similar laws being passed around the world.

Also, a glimpse at the varying reasons for the bans, from France to Tajikistan, provides as much insight about the societies passing the laws as it does about the people wearing the veil.

Under Quebec's bill, all public services would have to be given and received with an uncovered face.

Some Muslim groups and human-rights advocates say it's discriminatory, tramples on free expression and uses a legislative sledgehammer to stomp on the minuscule number of people who wear face-coverings.

Others say it doesn't go far enough.

“There is nothing in Quebec law that dictates we're secular here,” Christiane Pelchat, president of the government body tasked with monitoring gender equality, said during legislative hearings.

She wants the legislation to include a section that would make it clear religion has no place in public institutions.

Though the final form of Quebec's niqab law is still being examined in the legislature, and is far from settled, it will likely fall somewhere in the mainstream of similar laws elsewhere in the world.

Belgium's parliament is currently debating a proposal that would make wearing a face veil illegal; France is set to impose fines on women with a covered face; Egypt has limited face-coverings at universities; Tajikistan, meanwhile, has banned certain religious headwear.

The impetus for such bans can be strikingly different from one jurisdiction to the next. In Egypt, it's a way of stifling dissent against Hosni Mubarak's autocratic government. In Tajikistan, it limits what's seen as the foreign influence of Arabs in Central Asia.

In Quebec, Premier Jean Charest says the niqab represents an affront to two of the province's fundamental values: secularism and the equality of the sexes.

It is a common refrain heard throughout the debate here.

The law's supporters frequently raise the spectre of pre-1960s Quebec - which was among the western world's most religious societies, where women only got the right to vote in 1940 (a generation after the rest of Canada) and were forced to fight for it against a powerful, resistant clergy.

Supporters of the ban say they don't want a return to that era where religious fanaticism was widely tolerated, and where women were treated as second-class citizens.

The draft legislation would require women to uncover if they want to work - or obtain services - at the auto-insurance board, health department, or schools.

Similar arguments are being made in Europe, where countries going ahead with anti-niqab or burka legislation describe it as a matter of integration.

Belgium's lower house of parliament voted unanimously last month to ban both the burka and niqab.

“We cannot allow someone to claim the right to look at others without being seen,” said Daniel Bacquelaine, the Belgian politician who proposed the bill.

Failure to respect the ban would result in fines of between 15-20 euros - or up to a week in jail. The legislation still has to be approved by Belgium's upper house.

Belgium has a far smaller Muslim population than its neighbour, France, which is home to more than five million Muslims.

On Wednesday, French Justice Minister Michele Alliot-Marie rolled out a draft law banning Muslim face-coverings, the first formal step in a process to forbid such attire in all public places in France.

As in Belgium, offenders would face fines and in some cases could also have their citizenship reclassified.

The French government's stated rationale echoes the arguments circulated in Quebec, namely that face-coverings oppress women.

“Citizenship should be experienced with an uncovered face,” said President Nicolas Sarkozy. “There can be no other solution but a ban in all public places.”

There is, however, considerable concern the law could violate the French constitution.

Elsewhere in Europe, the application of face-covering bans has been tied to more explicitly reactionary politics.

A woman wearing a burka in the northern Italian town of Novara was detained last month, and fined 500 euros, for contravening a local bylaw against clothing that impedes easy identification in public buildings.

The bylaw was passed by the town's mayor, a member of the anti-immigration party Northern League. Novara's police chief has acknowledged that spot-checks there specifically target Muslims.

“There are still some people that refuse to understand that our community in Novara does not accept and does not want people going around wearing the burka,” said mayor Massimo Giordano.

Similar bans have entirely different connotations in predominantly Muslim countries.

An Egyptian court earlier this year upheld the government's ban on wearing Islamic face-coverings to university exams. A lawyer for the students challenging the ban said it supported “rape and sexual harassment.”

At the same time, a court last year struck down a ban on coverings in university dorms.

Such decisions are loaded with political significance given that the main threat to Mubarak's rule comes in the form of more fundamentalist Islamic groups such as the Muslim Brotherhood.

In Central Asia, Tajikistan recently opted to ban the hijab in public schools. The country is more than 90 per cent Muslim. But authorities there expressed concern it was a distinctly Arab symbol at odds with the Hanafi school of Islam native to the country.

Back in Quebec, the desire for a law regulating Muslim head dress comes amid a climate of suspicion.

A string of sensational newspaper headlines in 2007 launched a debate over so-called “reasonable accommodations” for minorities.

The most famous report involved a group of Muslim visitors to a sugar shack who managed to have the pork removed from the traditional pea soup. A tabloid newspaper carried pictures of the group.

As the media frenzy intensified Herouxville, a tranquil town of 1,300 in central Quebec, passed a municipal order warning that if any immigrants decided to live there they wouldn't be allowed to stone women.

A recent poll in the Journal de Montreal, the tabloid that led the way on those stories, suggested that only 20 per cent of Quebecers had a favourable opinion of Islam, compared with 42 per cent who had an unfavourable one.

After coming under intense pressure over identity issues, and criticism that it had taken an indifferent attitude, the Charest government moved earlier this year to legislate against the Islamic headwear.

An opponent of the legislation offers a much simpler explanation for the international stampede to ban the burka: pure and simple Islamophobia.

“It sends the message that these people are persona non grata,” Dominique Peschard, the president of Quebec's human rights league, told the legislative hearings last week.

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