Getting to Know the Other: Niqab-Wearing Women in Liberal Democracies

: Governments around the world have gone to great lengths to discourage and prohibit wearing of the niqab, often relying on the justiﬁcation that this form of Muslim women’s dress represents and produces the oppression of women. Setting aside that these prohibitions are themselves detrimental to women’s equality, this article focuses on the voices of women who wear the niqab or face veil. I describe and analyze how women explain their decision to wear the niqab based on interviews in seven liberal democracies. For most women, the primary motivation for wearing the niqab is religious, though supplementary reasons are also offered. The niqab is an embodied practice that represents a personal spiritual journey. Women’s explanations for why and when they wear the niqab suggest a complex intermingling of doctrinal knowledge and practical lived experience that negotiates religion day to day. Women often pair their religious agency with a sophisticated rights-based framework to justify their sartorial choices. Women refute the idea that the niqab makes them submissive. Their empowered interpretations of their religion and their conviction to lead a life that is different from most, in countries with pervasive anti-Muslim racism, suggest a great deal of independence and courage. This research offers nuance to the depiction of women who are typically portrayed monotonously, dispelling inaccurate stereotypes used to support discriminatory decision making about niqab-wearing women.


Introduction
Popular understandings of Islam often assume that the religion, its authorities, and many Muslims themselves are deeply patriarchal. 1 Women who wear the headscarf (hijab) and face veil (niqab) are pointed to as manifestations of this gender inequality. Governments around the world and particularly in Western liberal democracies have gone to great lengths to discourage and prohibit these forms of religious dress, often relying on the justification that these garments represent and produce the oppression of women (Bakht 2022, pp. 292-93). Setting aside the fact these prohibitions are themselves detrimental to women's flourishing or that other religious and secular perspectives can be harmful to women's equality, this article focuses on the voices of women who wear the niqab or the face veil. The framing of the niqab from the perspective of the wearer reflects wider debates of what religion is, what its boundaries are, how religious practices are defined in relation to concepts of equality and how those in liberal secular states engage with the visibly religious.
Most people living in liberal democracies have likely never met or a had a conversation with a woman who wears the niqab. Yet the absence of any direct experience with the niqab or the women who wear it does not prevent a wide variety of opinions about its meaning (Amiraux 2016, p. 44). Indeed, there is a great deal of mostly inaccurate information and hostile arguments about the wearing of religious clothing promoted by feminists, secular activists, journalists, intellectuals, university students, expert witnesses, judges, ministers and local and national elected officials (Amiraux 2016, p. 44). Politicians in particular have initiated many of the stereotypes and negative assumptions about niqab-wearing women and fabricated "issues" where none existed (Malik 2014, p. 238). 2 In this article, I describe and analyze how women explain their decision to wear the niqab based on interviews of niqab-wearing women in seven liberal democracies. For most women in these studies, the primary motivation for wearing the niqab is religious, though supplementary reasons are also offered. The niqab is an embodied practice that represents a personal spiritual journey. It is a constant reminder of the pious disposition that wearers want to cultivate and, as such, is not simply a religious symbol, but an act of worship. Women's explanations for why and when they wear the niqab suggest a complex intermingling of doctrinal knowledge and practical lived experience that negotiates religion day to day. In explaining their reasons for donning the niqab, women often pair their religious agency with a sophisticated rights-based framework to justify their sartorial choices. Women refute the idea that the niqab makes them submissive. Contrary to the belief that they are forced to wear it, women often choose to do so despite the wishes of their families. Their empowered interpretations of their religion and their conviction to lead a life that is different from most, in countries that have a pervasive problem of anti-Muslim racism, suggest a great deal of independence and courage. I hope this research will offer some nuance to the depiction of women who have been typically portrayed monotonously; that non-wearers of the niqab might begin to understand these women as complex and multifaceted, like the rest of us. I have written elsewhere about the devastating consequences of niqab bans both to the women directly affected but also to diverse societies (Bakht 2020, pp. 115-39). While I do not intend to repeat those arguments here, I am hopeful that a focus on women's accounts will dispel inaccurate myths and stereotypes used to support discriminatory decision making about niqab-wearing women.
For this article, I drew on interviews that I conducted with niqab-wearing women in Ontario and Quebec (Bakht 2020, pp. 15-36) as well the excellent research by other scholars who have interviewed niqab-wearing women in Canada, the United States, France, England, Belgium, Denmark and the Netherlands. I also relied on other sources that centered the viewpoints of niqab-wearing women including op-eds written by women themselves 3 and affidavits 4 of niqab-wearers filed in conjunction with constitutional challenges of exclusionary laws and policies. 5 In my study of niqab-wearing women, I conducted semi-structured interviews with nine women who wear face veils in Ottawa and Mississauga, Ontario, and Montreal, Quebec, provinces where there is a significant Muslim population. I met in person or conducted video interviews with all of the women from July 2016 to November 2017. Each interview was approximately one to one-and-a-half hours in length. My interviews are qualitative research and I do not make any claims about representativeness. However, my observations coincide strongly with many of the conclusions made by scholars in the aforementioned studies of niqab-wearing women in Europe and the United States, in which the combined total number of niqab-wearing women interviewed was approximately 330. 6 Of my nine interviewees, four resided in Ontario and five in Quebec. Eight of the interviewees were born into Muslim families and one converted to Islam in her twenties. Most of the interviewees identified as Sunni Muslims, though some considered themselves non-denominational Muslims. Four of the women were mothers and five did not have any children at the time of the interview. They ranged in age from nineteen to fifty-nine, with the majority falling between the ages of twenty and thirty-six. Six of the interviewees were immigrants who have lived in Canada most of their lives (and have Canadian citizenship), with one having arrived in Canada recently (with permanent resident status). The other two interviewees were born in Canada. Most of the interviewees were university educated. One had not completed high school. Eight of the interviewees were women of colour.

Religion as the Central Motivation for Wearing the Niqab
In Muhammad v Enterprise Rent-A-Car, 7 Ginnah Muhammad refused to remove her niqab when asked to do so by the judge of a small claims dispute in Michigan. Judge Paruk responded by saying the niqab was "not a religious thing . . . [but] a custom thing." 8 It is surprising that a white male, non-Muslim judge would presume to tell a racialized, Muslim woman litigant, about whom he knows very little, what the garment she is wearing means. Setting aside the egotism of such behaviour, he likely meant to delegitimize the niqab by characterizing it as merely customary or cultural since religious freedom is protected under US law and cultural rights are not. The idea that the niqab is not anchored in Islam is a common discourse used by disparate groups for differing reasons. Well-meaning liberals assume the niqab is an oppressive and patriarchal practice. Moderate Muslims do not wish to be associated with the niqab and its symbolic connection as an illiberal, extreme practice. Finally, there are those who argue that the niqab should be legally banned because it heralds and enables the rise of radical or fundamental Islam (Piela 2021, p. 65). The religious versus cultural framing of the niqab has been used by scholars of Islam and religious authorities to both support and oppose the niqab. 9 Each of the interview-based studies conducted with niqab-wearing women in liberal democracies revealed similar reasons for wearing the niqab. Religion was central to most women's decisions to don the niqab in the Netherlands (Moors 2014, p. 28), Denmark (Østergaard et al. 2014, p. 59), Belgium (Brems et al. 2014, p. 82), France (Unveiling the Truth 2011 and Bouteldja 2014, p. 115), the United Kingdom (Bouteldja 2014, p. 148), Canada (Clarke 2013;Bakht 2020) and the United States (Piela 2021). They stated that their primary reason for wearing the niqab was religious: to further their spiritual journey, to become a better Muslim or to deepen their relationship with God. Women expressed a "yearning for the experience of being closer to God" (Piela 2021, p. 77). An affiant to the constitutional challenge of Bill 62 in Quebec, Salma Siddiquea, said that she wears the niqab to reach a higher spiritual place. For women in the Netherlands, wearing a face veil was part and parcel of their commitment to become a better Muslim (Moors 2014, p. 28). In Denmark, "[f]irst and foremost, all the women highlighted that they wore the niqab because it was an expression of their love of God" (Østergaard et al. 2014, p. 59). Many Canadian interviewees said that the face veil was not a message to the outside world (Bakht 2020, pp. 15-36). Wearing the niqab was something done for themselves or for God: Fauzia stated, "Most people, I think, feel that we are imposing the niqab. . . . But I'm just practicing my right and showing my emotions inside" (Bakht 2020, p. 20) In most cases in France and England, the adoption of the face veil is the consequence of a spiritual journey, with many relating their desire to deepen their relationship with God. 10 The perspective that the face veil represents a personal spiritual journey corresponds with the views of women in Belgium, for whom the niqab was not about proselytism (Brems et al. 2014, p. 82).
One woman in Piela's study said that she ceded her autonomy to God. "I keep wearing the niqab because God has given me the strength, no one can do this on their own" (Piela 2021, p. 72). The personal surrender or submission (Piela 2021, p. 74) 11 to God imbued her with the strength and resilience necessary to wear the niqab (Piela 2021, p. 74). Canadian niqab-wearer, Alia, who first started wearing the niqab "as an experiment" because her mother wore the niqab, said the following about her reasons for wearing the face veil: "I'm Muslim and a Muslim means somebody who submits to God. And I believe that every time I put on the niqab, I am in a state of worship . . . every minute I have it on, I am being rewarded for it. I feel I'm . . . closer and connected spiritually to God and I feel whole when I wear it" (Bakht 2020, pp. 19-20).
Wearing the niqab for these women was not simply the result of an already formed orientation with respect to modesty. Instead, it is a practice that is a constant reminder of the pious disposition they want to cultivate. "[T]he outward behaviour of the body constitutes both the potentiality and the means through with interiority is realized" (Mahmood 2005, p. 159). For some, the embodied practice of wearing a face veil created a particular emotive state. The sacred became vividly real and present by the experiencing body (Piela 2021, p. 83) such that the niqab was not simply a religious symbol, but an act of worship.
Several women used religious language to explain how they moved toward more modest dress, a headscarf and finally the face veil. This series of steps toward the niqab was reflected amongst interviewees in the Netherlands, for whom "sartorial changes were part of a longer-term process in which piety becomes increasingly central to their lives" (Moors 2014, p. 30). Clarke also found that many women saw the niqab "as a stage in one's personal religious development-and face-veiling as a challenging commitment and test of faith" (Clarke 2013, p. 29). The niqab enabled these women to shape their current and future selves. "[W]hen she wears the niqab, she is the person 'she aspires to be,' even if she is 'not that person yet'" (Piela 2021, p. 85). In a sense, the niqab offers a practical coherence in everyday life in that it is effective in helping to accomplish a desired end (McGuire in Piela 2021, p. 83).
Because there is a difference of opinion among believers and scholars of Islam regarding the obligatory nature of the niqab, many of the women used their own judgment to assess the evidence for themselves, keeping with the Islamic legal tradition of ijtihad or independent reasoning. 12 Mehreen noted, "I wasn't of the view that it's obligatory. I wanted to do it. It's like an extra prayer that you do. You do the five prayers and then you do the extra. So it's completely optional" (Bakht 2020, p. 19) 13 . In Clarke's Canadian study, she also found that though several women did not feel the niqab was absolutely required by Islam, they still wore the niqab as a higher or special kind of dedication to God (Clarke 2013, p. 29). One woman explained that wearing the niqab was like "going the extra mile" in her worship, noting this logic was her own, in the sense that covering the face was not mandated by the Quran (Piela 2021, p. 77). Salma Siddiquea said "Other followers of Islam have different beliefs and I respect that . . . I respect other people's choices. Even though these choices might run contrary to my faith . . . ." 14 Zareen stated, regarding other women's decisions about what to wear: "I don't have a right in Islam to tell her that she's wrong" (Bakht 2020, p. 20). In Belgium, the main driver for wearing the face veil was a desire to excel in piety. "The large majority do not see it [the niqab] as an obligation, but rather as a voluntary commitment to a higher level of Islamic practice" (Brems et al. 2014, p. 82).
The women in these studies appeared to be very conscious of the significant interpretative diversity about the niqab and that niqab wearing is a source of internal debate amongst Muslims. For many women, wearing the niqab was not a straightforward decision. American and British women spoke of years of reflection and a "lengthy process of spiritual discernment" (Piela 2021, p. 81). Most of the Canadian women also engaged in prolonged individual study to acquire more Islamic knowledge and to determine whether wearing the niqab was right for them (Bakht 2020, pp. 18-19). Islamic education based on personal research was not uncommon and there was a strong sense that experiential knowledge was important and did not necessarily stand in conflict with traditional scholarly interpretations of Islamic rules with respect to modesty (Piela 2021, p. 82). As one woman noted, "That's the whole concept of faith is sometimes you don't really understand or know everything, but you don't need to understand or know everything, because, you know, this kind of defeats the purpose. It's realizing, you know, in spite of understanding . . . " (Piela 2021, p. 73). On coming to her own religious perspective, Ayesha said: So I felt like I had to do my own research if I'm going to understand this religion. Because obviously when you're born into something, you don't really have a choice in being Muslim or not being Muslim. So you have to go and do your own thing sometimes and think. If someone's going to ask you why you're Muslim, you should have your own reason for why you're Muslim instead of doing it by the book. (Bakht 2020, p. 19) Another Canadian interviewee acknowledged that she received the niqab as a gift from a friend who knew the garment intrigued her, but that she consulted the work of scholars and put much thought into her decision to wear the niqab (Bakht 2020, p. 20).
Understanding the niqab's origins as an Islamic practice varied in its importance to the women interviewed. Some niqab-wearing women in Denmark referred to the Prophet's wives as motivation for wearing the niqab (Østergaard et al. 2014, p. 59). Similarly, to wear the niqab was seen by some Canadian interviewees (Bakht 2020, p. 20) as a "sunnah" 15 (Brown 2009), emulating the ideal behaviour of the Prophet Muhammad's wives 16 (Østergaard et al. 2014, p. 59). Zahra attached higher spiritual value to early Muslim women's independent and generous application of the "hijab verse" and wanted to emulate them by taking personal responsibility for her own interpretation of the verse: "[T]he women themselves heard the verse and they understood it to mean to cover themselves in a certain way . . . it was their initiative to take that on" (Piela 2021, p. 74). She admired their willingness to interpret the verse broadly without compulsion from anyone (Piela 2021, p. 74). By contrast, one woman specifically denied this motivation, indicating that the Prophet's wives likely wore the niqab so as to make it difficult for those who might want to attack the Prophet (via his wives) to differentiate between women (Bakht 2020, p. 20).
Women's narratives collapsed the categories of doctrinally authorized knowledge and lived religion. For example, some women positioned themselves as "slightly different" in terms of their Islamic schooling, which affected their perspectives on Islamic practices (Piela 2021, p. 81). One Salafi 17 (Inge 2016, pp. 2, 11) woman specifically compared Islamic evidence in favour of the obligatory versus recommended positions on the issue of niqab wearing. While her opinion was framed by Salafi perspectives, which is often associated with the view that the niqab is mandatory, she did not support this view. This coincides with Inge's findings that the practice of niqab wearing among British Salafi women is common, but by no means ubiquitous (Inge 2016, p. 152). Women's individual understandings of religious obligations coincide with Islam's less centralized and more pluralistic system of belief.
In using religious reasoning to explain their motivations for wearing the niqab, women used two of the most important sources of Islamic law, the Quran and the Hadith. They furthered their Islamic education based on personal research. By focusing on linkages with historic context and the spiritual transformative effect of the niqab on their sense of self, the women also engaged in individual attempts at ijtihad or legal reasoning in coming to their decision to veil and in justifying it. Their personal experiences, as the next sections highlight, also played a role in rationalizing their choices. Their experiential knowledge did not necessarily stand in conflict with traditional scholarly interpretations of Islamic modesty rules (Piela 2021, p. 82). As Asad has noted, "[a] practice is Islamic because it is authorized by the discursive traditions of Islam, and is so taught to Muslims-whether by a an alim, khatib, a Sufi shykh or an untutored parent" (Asad in Piela 2021, p. 82). Thus, to dismiss women's niqab wearing as merely cultural is to seriously misapprehend Islamic interpretation and women's legitimate efforts at it. By questioning the legitimacy of their religious agency, non-niqab-wearers undermine the embodied practices of this minority of women.

Supplementary Motivations for Wearing the Niqab
Although religious reasons predominated, some women gave supplementary explanations for why they wore the niqab. For one Canadian interviewee, Ayesha, while wearing the niqab was partly about religious conviction, she identified an outward meaning or message to those who might observe her: I feel like for me these days it's more just like an identity thing.... I'm not just doing it for God even though that is partly my intention . . . . Mostly my intention is just to show that even as a niqabi I can do the same thing as you, right? Because the only people putting the barrier on my capabilities are people who don't understand niqab fully . . . . I don't put these barriers on me . . . . I don't feel like Muslim women should shy away from their identity or how they want to dress just because other people don't understand [emphasis added]. (Bakht 2020, p. 21) Ayesha acknowledged that her reasons for wearing the niqab might shift depending on the context. Religious motivations, while present, were not the primary force, as her use of the term "these days" suggests. For Ayesha, the niqab functioned as a powerful marker of identity, and she was keen to create an image that dispelled typical notions of the niqab-wearer as conservative and reserved. In Clarke's study, a significant number of online respondents chose "Muslim identity" as a reason for adopting the face veil. Studies have shown that for many Muslim women in Western non-Muslim countries, the hijab functions as a marker of identity (Clarke 2013, p. 32 andLitchmore andSafdar 2016). The niqab, it seems, plays a similar role in both proclaiming and forming identity.
Other supplementary explanations offered for wearing the niqab include that it "helped me become a better person," to which Mehreen referred in part to appropriate social interactions between men and women (Bakht 2020, p. 21). The niqab not only reminded her about suitable relations between the sexes, but she noticed that it signaled to men to treat her with more respect, which she appreciated. Canadian women in Clarke's study commented that the niqab freed them from the confines of fashion and having to waste hours perfecting one's hair or applying makeup (Clarke 2013, p. 36). Zakia commented that she "felt more protected" when she wore the niqab. Though she did not directly discuss avoiding unwelcome male attention, she alluded to feeling "freer" in her movements when she wore the niqab 18 (Bakht 2020, p. 22). Some women in Denmark felt that wearing the niqab lived up to an ideal of Muslim female behaviour, which included hiding one's beauty to male outsiders and avoiding problematic sexually charged attention (Østergaard et al. 2014, p. 60). Interestingly, in Belgium, several women rejected harassment by men as a motive for wearing the niqab, stating they got touched more and that it "excites the imagination of some people" (Brems et al. 2014, p. 83). Canadian interviewee Ayesha declared: "Women in niqab get raped too, you know . . . It has nothing to do with the way people dress" (Bakht 2020, p. 22).
In the Netherlands, some young girls put on the face veil "for fun" or to try out its effects, but where that was their only motivation, they also quickly gave it up again (Moors 2014, p. 30). Although the niqab is often linked with extreme political views, niqab-wearing women in Denmark disassociated with such linkages: "We do not do it for political reasons. I cannot be bothered to single out myself every day in a society that is predominately non-Muslim so I can make a political statement! That's really not going to motivate me for too long" (Østergaard et al. 2014, p. 61). By contrast, Canadian niqab-wearer Aima Warriach has stated, "I wear niqab as an act of defiance against the patriarchy that keeps telling me what to wear because somehow they know what it means to be liberated from 'Taliban-like oppression'"(Aima in Yousef 2016). Similarly, a woman in France who admitted to not being a practicing Muslim before France's niqab ban was passed said about wearing the niqab: "This is my way of saying 'no' to a government that has robbed me of my freedom" (Heneghan 2015).
Some women offered non-religious reasons with humour to frame why they wore the niqab: "I don't get sunburnt" or "I don't get a chill on my nose" (Piela 2021, p. 67). The use of humour has been described as a stigma management technique that compensates for power imbalances between the stigmatized and their interlocutors (Piela 2021, p. 68). The discourse of non-Christian piety is so foreign to Western audiences that women also relied on secular or pragmatic reasons to justify the niqab (Piela 2021, p. 68). Some women are reluctant to discuss religious beliefs because of having to constantly challenge stereotypes linking Islam to terrorism (Piela 2021, p. 67). Fernando has argued that religious discourse is often unintelligible to secular actors, thus women who veil mobilize the language of rights and freedoms to advocate for their right to wear the niqab (Fernando 2010, p. 32). Piela suggests that the reason why women highlight the notion of choice and personal autonomy is that they recognize the need to slip out of religious discourse to effectively challenge the framework of submission that is thrust upon them by virtue of wearing a niqab (Piela 2021, p. 99). In other words, they need to engage with secular-liberal discourses because of attempts in the west to restrict their religious autonomy (Piela 2021, p. 91). My own view is that women in liberal democracies are equally versed in religious and secular rights-based reasoning, that they do not see them as contradictory, and are able and comfortable in applying both to their daily ethical conduct.
While there may be exceptions among women, for whom other factors overshadow the religious motivation for wearing the niqab, and perhaps only temporarily, it is difficult to reduce the niqab to these supplementary explanations. A plethora of factors may play a role in the initial decision or provide a partial explanation for adopting the niqab. However, a spiritual quest or pursuit of piety appears to motivate most women to keep the niqab on for long periods of time (Moors 2014, p. 30;Bouteldja 2014, pp. 149-50). Some scholars have noted the fact that the niqab is worn as a practice to cultivate piety and submission to God is its most important framing, rather than the emphasis on its voluntary, individually chosen character, structured by liberal sensibilities (Amir-Moazami 2014, p. 274; Mahmood 2005). One must be conscious of not ascribing a false political consciousness to interviewees (Bilge 2010, p. 19) 19 , but many women spoke in the language of individual choice. It is possible that switching from religious to secular liberal discourse in justifying the niqab was for the purpose of engaging with secular audiences. But it is also possible that a sharp religious agency or consciousness is not necessarily exclusive of the liberal matrix. Some would say that niqab-wearing women must "be actively multilingual" (Piela 2021, p. 115). I would suggest that this state of being is an authentic representation of their full selves. Women's motives for wearing the niqab are fluid and contextual and where they are multiple, they do not negate each other (Piela 2021, p. 70).

Intermittence and Flexibility Regarding Niqab Wearing
Contrary to the typically held view that wearing the niqab in public (or in front of men one is not related to) is something one does consistently, some niqab-wearing women would wear the niqab intermittently. The applicant in SAS v France wore the niqab in public and in private, but not systematically. "[S]he chose to do so, depending in particular on her spiritual feelings." 20 In the Denmark study, it was noted that wearing a niqab is not necessarily something static but may change over time and according to changing life circumstances (Østergaard et al. 2014, p. 51). Similarly, in France, the wearing of the face veil was not found to be a permanent practice for every woman: Nine respondents do not wear the veil on a regular basis for three main reasons: the general socio-political climate, work regulations, or family tensions. Some women, when interviewed, had stopped wearing the veil for what they believed would be a temporary period. Even among those who always wear it, some had begun by only putting it on for certain occasions, such as going to the mosque. (Unveiling the Truth 2011, pp. 12-13) 21 Despite deeply held beliefs about the niqab and the willingness to wear it irrespective of the sometimes very severe social, political and legal consequences, 22 several women articulated a great deal of flexibility regarding when a niqab could be removed. For example, many Canadian interviewees, as well as several of the affiants in the Bill 62 constitutional challenge, noted that they are willing to remove the niqab for short periods of time to identify themselves or for security checks at border crossings. All preferred to show their face to women officials, but some were willing to show their faces briefly to male officials as well. In Belgium, many women indicated their willingness to take off their face veils in front of male officials to identify themselves (Brems et al. 2014, p. 103). 23 This willingness to adapt suggests, as other scholars have noted, that religious practices are not necessarily fixed and often evolve in function of context (Selby et al. 2018, p. 20).
One interviewee stated that if the laws in Canada required her to testify in court while not wearing her niqab, she would do so, but not before fighting for her legal right to wear it (Bakht 2020, p. 31). 24 Another interviewee discussed the importance of seeing the face in certain situations. She hoped to become a social worker one day and thought there may be times when a male client may want to see her face to connect with her before revealing a personal story; and in such a situation, she would make an exception (Bakht 2020, p. 31). 25 Alia takes a pragmatic approach to removing her niqab in the current political landscape. She wears her niqab to university and most other outings, but not when she goes to work. Alia works at a call center, speaking to customers on the telephone. The niqab ought not to pose an impediment to her ability to perform her duties. However, she notes, "I'm living in Canada, I'm a student, I'm broke, right? So obviously I'm not so strict that I'm going to make it very impractical for me to live in this society" (Bakht 2020, p. 31). Woman negotiate between different principles to come to a resolution that makes sense to them. In Denmark, Amina who wore the niqab for twenty-five years was left as the sole breadwinner of the family after her husband died. In order to pursue her teacher training, she was told that she would need to remove her niqab. Though she felt divided between her wish to wear the niqab and her wish to pursue her education, she ultimately decided that the search for knowledge was an obligation in Islam in a way that wearing the niqab was not (Østergaard et al. 2014, pp. 64-65). These women are thus able to legitimize removal of the niqab while still supporting themselves and their families, though perhaps not without personal emotional consequences (Østergaard et al. 2014, p. 65). 26 Women's explanations for when they wear the niqab and when they do not suggest a complex intermingling of doctrinal knowledge and practical lived experience that negotiates religion day to day. Women do not approach their religion as a pre-determined blueprint for their lives. Asad has argued that Islam is a discursive tradition made up of a heterogenous collection of beliefs, practices and morals (Asad 2009, pp. 20-21). Thus, women rationalize and actively mediate their engagement with Islamic doctrine. By the same token, one cannot explain everything they do in terms of Islam (Asad 2009, p. 22).

Adopting the Niqab: A Personal and Positive Decision
Decisions about clothing are always made in relational contexts that often influence and/or constrain individual behaviour. But the majority of niqab-wearing women interviewed in Western liberal democracies have strongly distanced themselves from any suggestion of physical force or social coercion. All of the Canadian women interviewed in the Bakht study stated that they made the decision to wear the niqab without any social pressure from family members, but as a matter of free choice in their personal religious journey (Bakht 2020, p. 18).
Indeed, in contrast with the pervasive view that women are forced to wear the niqab by domineering men in their families, many of the Canadian women noted that their fathers or husbands opposed their niqabs and would have preferred that they not wear it (Bakht 2020, p. 23;Clarke 2013, p. 42). This perspective coincides almost identically with niqab-wearing women in Europe. 27 The in-depth testimonies in the United Kingdom revealed that when parental pressure had been applied, it was always to convince daughters to remove the veil (Bouteldja 2014, p. 131). Though the niqab is often perceived as reflecting and reproducing hierarchical power structures, and this apparent compulsion is used as the primary basis for niqab bans, in fact most of the responses from niqab-wearing women in the seven countries where women's voices have been studied undermine this assumption.
Mehreen said that her husband would prefer that she not wear the niqab because "you know he ends up getting the weird looks. And it's automatic. [They assume] he's making me do it" (Bakht 2020, p. 23). Similarly, Zareen's family was very concerned about her wearing the niqab during one of the controversial Canadian debates. "I know like my family was under stress, too. They were concerned, at that time. People were [telling my husband], like make your wife . . . [take off the niqab. He said,] she has made up [her] mind . . . and she will not listen to me!" (Bakht 2020, p. 23).
Lynda Clarke points to a narrative of a woman in France being forced by her abusive husband and in-laws to wear a niqab (Clarke 2013, p. 61). Eva Brems also cites a Belgian case of a woman who had been forced to wear the niqab (Brems et al. 2014, p. 84). The rarity of these cases seems to reinforce rather than discredit the general finding that women typically choose to wear the niqab. Canadian women interviewed said that they did not know of a woman who had been coerced into wearing the niqab. In Denmark, women were irritated by the suggestion that they are forced by their husbands to wear niqab (Østergaard et al. 2014, p. 42). If parental or familial pressure was present, it was typically applied to persuade women not to wear or to remove the niqab (Bouteldja 2014, p. 131). 28 Two Canadian women stated that when they began wearing the niqab, they hid it from family members, knowing that their parents would not approve (Bakht 2020, p. 26). In France, many young women also initially wore the niqab secretly for fear of parental disapproval (Bouteldja 2014, p. 132). One woman made wearing the niqab a prerequisite to agreeing to marry a potential suitor (Bakht 2020, p. 26). 29 Interviewees showed a keen appreciation for the illogical reasoning used to undercut their choice of dress. Waheeda said "I don't steal, I don't lie, I don't hurt people . . . . I just want to have the right and to be sure that everyone knows that I have the right to live my life as I want" (Bakht 2020, p. 24). They were very aware that they were not harming anyone by wearing the niqab and that they exercised agency in making informed, reasoned and deliberate choices. 30 As one scholar put it, "The empirical research suggests . . . that they [niqab-wearing women] make this choice not because they are being told to do so by men, but because they are modern, emancipated women who make up their own minds about what they wear and how they present themselves in public" (Moors 2014, p. 211).
Several of the Canadian interviewees were the first among their family and friends to wear the niqab. Being a "niqab pioneer" drew more surprise and opposition from family members, at least initially (Bakht 2020, p. 25;Østergaard et al. 2014, p. 43). Family members were concerned about women's safety and security given the public hostility experienced by veiled women. Alia's decision to wear the niqab was questioned by extended family, even though her mother wore the niqab, because they thought that at age 15 she was too young to make such a decision. By age 19, most of her family had accepted her decision (Bakht 2020, p. 25). Aseeyah's family thought her niqab was a phase. They thought it was "something a young person does to express herself," but that it would go away (Bakht 2020, p. 25). 31 Interestingly, in the United Kingdom, most niqab-wearing women had relatives or friends who wore the face veil before they made their decision to adopt the niqab and hence they experienced less disapproval from friends and family for wearing it. In all the other European countries where women's views were studied, women were typically making highly individual decisions to begin wearing the face veil. That is, they did not know other face veil wearers when they began wearing the niqab and thus were often met with more disapproval in their social and familial environments (Bouteldja 2014, p. 139).
Women in these studies did not associate the niqab with oppression or unequal relations between men and women. Rather, they saw the niqab as an expression of strength and courage, and for many, wearing the niqab reflected a deepening of their faith, which made them happy and fulfilled. Significantly, each of the Canadian women linked the niqab with highly positive connotations (Bakht 2020, p. 20). Several of the women spoke of being inspired or feeling enthusiastic to wear the niqab (Bakht 2020, p. 20). One interviewee said it made her "feel precious" (Bakht 2020, p. 20). Another said, "I feel that . . . I'm complete with it on" (Bakht 2020, p. 20). These comments also reflect what niqab-wearing women in Denmark noted, particularly that wearing the niqab made them feel strong, honourable and self-confident (Østergaard et al. 2014, p. 60). In the Netherlands, women said wearing the face veil "had a strong positive effect on them," making them "feel good," like they were "floating through the air" and "experiencing a feeling of inner peace" (Moors 2014, pp. 30-31). In Piela's American and British study, all the women interviewed said wearing the niqab was their choice-they emphasized the freedom they felt the niqab gave them within their existential ethical framework of piety (Piela 2021, p. 113).

Conclusions
Listening to the voices of niqab-wearing women reveals that many assumptions made by dominant groups about these women are simply inaccurate. They are not compelled to wear face veils by anyone or anything other than their own conscience. They make the deep religious commitment to wear the niqab despite the negative attention and hostility it brings to their lives (Peritz 2013;Frisk 2015). Their motivations for wearing the niqab are varied, yet strong commonalities are exhibited in that personal religious reasons predominate. The niqab is an embodied practice that represents a personal spiritual journey. It is a daily prompt that reminds the wearer of the pious disposition that she wishes to cultivate. Some women described it as an act of worship. Women's explanations for why they wear the niqab employ an intermingling of doctrinal knowledge and practical day-to-day lived experience. Women demonstrate a great deal of flexibility regarding when they wear the niqab. Women often pair their religious agency with a sophisticated understanding of their rights and freedoms in liberal democracies. The conviction to wear the niqab and to be conspicuously different in non-Muslim countries is courageous to say the least.
Understanding the niqab from the perspective of the wearer and taking those views seriously could have an enormously positive impact on how diverse liberal states engage with Muslim women and minority communities generally. That certain individuals would be prevented from going about their daily lives because of a sartorial disagreement cannot be acceptable in democracies that claim to protect human rights. The treatment of niqabwearing women speaks to the kind of society we want to live in. We must leave open the possibility that our political and social certainties might be transformed in the process of getting to know the Other.

11
The concept of submission is understood by niqab-wearing women unambiguously as submission to God, in contrast to wifely submission, a notion that characterizes some Christian evangelical movements. 12 For a historiography of ijtihad, see Emon (2018, p. 181). 13 Bakht (2020, p. 19). Moors found that women in the Netherlands also noted the importance of acquiring Islamic knowledge before coming to their own opinion about whether the niqab was required of them. "[E]ven if it is not obligatory, it is a good deed." Moors (2014, p. 31). 14 NCCM v Québec, (Affidavit of Salma Siddiquea), paras 5, 11. 15 The Arabic word "sunnah" means tradition or the way of life prescribed as normative for Muslims based on the teachings and practices of the Prophet Muhammad. 16 Some niqab-wearing women in Denmark also made reference to the Prophet's wives as a motivation for wearing the niqab. Østergaard et al. (2014, p. 59). 17 Salafis are members of an orthodox Sunni Muslim sect advocating a return to Islam's imagined "unadultered" original form. Inge (2016, pp. 2, 11). 18 Amir-Moazami has noted that the face-veiled woman almost deliberately transgresses the position of the "gaze" by the fact that she can see without being seen herself. This provides her with a "disturbing agency". Schirin Amir-Moazami (2014, p. 275). See also (Razack 2018). 19 Bilge has argued that the linking of veiling and political resistance as central is often produced by researchers who project their own affinities on participants and thereby contribute to the erasure of religious discourses from women's narratives. (Bilge 2010 Unveiling the Truth (2011, pp. 12-13). 22 Several affiants to the Bill 62 constitutional challenge said that they will not remove their niqabs even where the law requires it, meaning they will not be able to work in the public service and will not receive important public services. These women have said that they would rather be confined to their homes than be forced to remove their niqabs. See for example, NCCM v Québec. Clarke described the attachment to the face veil of two women who said that if a law banning niqabs was implemented, they would try to move to another location rather than "stay at home and not go out at all". Clarke (2013, p. 24). 23 A small minority of Belgian women would only remove their face veils in front of women officials. Brems et al. (2014, p. 103). 24 Bakht (2020, p. 31 For a similar rationale by a counselor in the UK who wears a face veil, but who removes it when she counsels couples, see Bouteldja (2014, p. 124). 26 The impact on women who typically wear the niqab and are forced to remove it for lengthy periods of time should not be underestimated. Khadija from Denmark said that she began to feel a kind of "schizophrenia" when she did not wear the niqab regularly in public and that people's harsh reactions to her inconsistent behaviour depressed her and disturbed her spirituality. Østergaard et al. (2014, p. 65). 27 For Belgium see Brems et al. (2014, p. 84); for the Netherlands see Moors (2014, p. 32); for England and France see Bouteldja (2014, p. 133); for Denmark see Østergaard et al. (2014, p. 61). For the United States see Piela (2021, p. 10). 28 Several of the affiants to the Bill 62 constitutional challenge also indicated that they choose (and are not required by family members) to wear the face veil and that they do so for a variety of reasons. See NCCM v Québec, (Affidavit of Asma Tanvir) at paras 4, 7; NCCM v Québec, (Affidavit of Fatima Ahmad), paras 7-8; NCCM v Québec, (Affidavit of Jasmin Akhter), paras 9-10; NCCM v Québec, (Affidavit of Mahvish Ahmad) at paras 3-5; NCCM v Québec, (Affidavit of Nasima Aktar), paras 5-7; NCCM v Québec, (Affidavit of Marie-Michelle Lacoste), paras 6, 9, 11, 15, 16. 29 Similarly, in Denmark one of the women pointed out that she made her future husband's acceptance of the niqab a prerequisite of marriage. Østergaard et al. (2014, p. 61). In Belgium, there were some cases where husbands asked their wives to wear the niqab and they agreed to this request. Brems et al. (2014, pp. 83-84). 30 Angela Campbell has persuasively argued that women in polygamous marriages, surrogates and sex workers exercise resilience, resistance and agency, and make reasoned and deliberate choices, even when they live and work within oppressive or patriarchal contexts. Campbell (2013, pp. 2-3). By emphasizing that niqab-wearing women voluntarily choose to wear the niqab, I am not suggesting that a feminist analysis must end here. Like Campbell, I believe we must move beyond a simplistic investigation of whether women choose or have been coerced into a controversial lifestyle and examine the social and legal conditions that allow oppression to persist. 31 She has worn the niqab for some 39 years while living in three different countries and raising her four children.