Comparing Policies on Indigenous Peoples: Canada, South Africa and the United States of America (name of author) (name of university or affiliation)

I - Comparing Policies on Indigenous Peoples: Canada, South Africa and the United States of America (name of author) (name of university or affiliation) introduction. INTRODUCTION

            The aim of this essay is to analyze the similarities and differences of government policies on multiculturalism in three countries; mainly, Canada, South Africa and the United States of America. This comparison will be done in two levels. The first is a comparison between Canada and South Africa, and the second is a comparison between South Africa and the United States of America. After comparing, this paper also seeks to find out which among these three countries can be said to be most progressive and which is most oppressive in terms of policies on multiculturalism.

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A. Canada and South Africa

            In comparing policies of multiculturalism in the governments of Canada and South Africa, it will be helpful to focus on, among a few other things that will be discussed later on, the monumental events linked to multiculturalism that took place in these two countries, signaling a monumental transition or change (or lack, thereof, as the case of Canada proves). In the case of Canada, this will be the failure of the Meech Lake Accord in 1987 which resulted in decades of long debates over the issue of Quebec’s secession, and the referendum that took place in 1995 concerning this secession. In the case of South Africa, the focus will be on the resistance of the colored people on the issue of “apartheid”.

            In Canada, the efforts of the Quebecois to get recognition for Quebec as a distinct society were done through the Meech Lake Accord in 1987, which failed. This sparked subsequent forms of resistance among the Quebecois, evident through the referendum that took place in 1995, which resulted in a 50.5% negative vote (Schaefer, 2007). This shows how even within Quebec, there is no consensus concerning the issue of separatism. Some, although sympathetic with concerns over preserving identity and culture, do not see secession as a solution to achieve the assertion of their identity (Schaefer, 2007). With this background, it is also evident that Canada’s policies on multiculturalism, although seeking to accommodate major groups in a pragmatic level (i.e. through freedom of language, etc.), is unwilling to make all-out concessions to the clamors of these groups.

            In contrast to the failed attempts at secession of the Quebecois, in South Africa, transition in response to the clamor of a distinct group appears to have been achieved more successfully. The success of the resistance to “apartheid”, a law of segregation among whites and colored people, may be attributed to steps taken by the government in 1990, specifically by Prime Minister de Klerk, to allow more freedom for colored citizens; such as, granting freedom to African National Congress (ANC) leader Nelson Mandela, the signing of the National Peace Accords, and the legalization of Black organizations (Schaefer, 2007).This was immediately followed by the 1992 referendum to end apartheid, which had a positive turnout.

            In these two events in Canada and South Africa, the difference in the outcome reached by both governments through policies lies mainly in the difference in the degree of oppression in status quo, and in the degree of change demanded by the groups involved (i.e. the Quebecois in Canada and the colored citizens in South Africa). In Canada, the laws in status quo can be said to be a great deal more accommodating towards the Quebecois, in the sense that it granted language rights and recognized the Francopole as a major linguistic group. In contrast, the policy of apartheid in South Africa was oppressive in the sense that it sought to reestablish a master-slave relationship among whites and blacks  (Schaefer, 2007) and took away certain freedoms from the blacks, such as voting. At the same time, the degree of change demanded in Canada is obviously of a greater degree than the demands of colored citizens in South Africa. What the Quebecois wanted was secession, to be completely independent of Canada, while in South Africa, the demand was to end apartheid and to bring back equal freedom among all citizens, regardless of color. Despite these, there is also a degree of similarity in the response of both governments to these demands. Both governments allowed for a referendum to allow the people to determine for themselves their own future. The main and striking difference lies on the results of these referendums.

            Another area of comparison may also be analyzed, such as the general approach towards multiculturalism in both countries at present. In Canada, even with the irony of English and French as official languages, the government still stands firm on its policy that no ethnic group must gain precedence over another (Schaefer, 2007). In South Africa, however, after ending apartheid, the government instituted a policy of “affirmative action”, giving precedence to colored citizens over other groups. This policy is criticized because it creates an opposite type of apartheid that is discriminatory towards non-colored citizens (Schaefer, 2007).

B. South Africa and the United States of America

            In the United States, policies on multiculturalism include language rights to citizens (Chen, 2008), specifically English and Spanish. Another significant thing to consider is the policy on immigration, with the passage of the Immigration and Nationality Act Amendments of 1965, which abolishes the limit on the number of immigrants per country, thus creating a more liberal environment catering to other cultures.

            In comparing the policies of the U.S. and South Africa, one significant parallelism is the presence of “affirmative action”. The difference is that in the U.S., this policy focuses more on taking into consideration gender and racial differences without necessarily favoring a certain racial group, while in South Africa, this policy necessitates that colored citizens are given precedence.

            Another important point of comparison will be the policy of “apartheid” or segregation. This was a policy in Nashville, Tennessee that attracted much resistance among colored citizens, in much the same was as South Africa. The outcome in both events is similar, favoring the abolition of this policy. However, the difference lies in the fact that this was not a national policy in the U.S. and that it took place in Nashville and not the entire country, as compared to South Africa.


            In order to measure the “progressiveness” or “oppressiveness” of policies on multiculturalism, certain factors must be considered. First, there must be an analysis on these policies’ general approach on indigenous groups; whether basic rights and freedoms are being granted, etc. Second, there must also be an analysis on the governments’ responses through policies towards major issues on multiculturalism. Using these two angles of analysis, the government that can be said to be most oppressive in its policies towards indigenous peoples is South Africa. Even while considering the abolishment of apartheid, its policy of affirmative action, while giving justice to those who were discriminated before, still promotes, to some extent, an opposite kind of discrimination against non-colored citizens.

            However, when it comes to assessing which government policy is most progressive, it will be more difficult to assess. In Canada, although there appears to be less satisfaction with the policies (evident because of issues on secession), there appears to be no blunt or direct attempt on the part of government policies to discriminate against any particular group. In the U.S., on the other hand, while being liberal with its immigration laws, there are states that still, to some extent, discriminate (evident through the case of Nashville, for example).

            Deciding on which of the two is more progressive will depend on which issues on oppression are more tolerable, and whose positive policies deserve greater merit. Doing this may be subjective, and it might be better to leave this conclusion to the reader’s own perception on cost-benefits.


Chen, M. , 2008-05-27 “Language Rights as Multiculturalism Policy in the United States” Paper presented at the annual meeting of the The Law and Society Association Online <APPLICATION/PDF>. 2009-03-04 from

Schaefer, Richard, (2007), Racial and Ethnic Groups, Eleventh Edition, (431-436, 445-450), Prentice Hall


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