ABSTRACT
Britain differs from both Germany and Italy by virtue of a colonial history which dominated early post-war immigration. This background, together with an inclusive approach to citizenship based on territory rather than blood,1 meant that migrants’ rights were more commonly addressed through concerns about ‘race relations’ than as part of immigration law. Britain also differs from Germany and Italy in having no written constitution – which has been one source of expansion for migrants’ rights elsewhere (Guiraudon, 1998) – and in having no land border with the rest of Europe. Indeed, Britain’s island geography and mentality have been apparent in its resistance to full involvement in the emergent EU asylum and immigration regime.
