STRIKING a balance between personal and religious freedom, and the ideals of common citizenship, is proving to be an enormous test for all European countries with large Muslim populations—especially when some seem determined to assert, or even caricature, the practices of their homelands.

Certain things are easily settled: virtually everybody in Europe agrees in abhorring female genital mutilation, as practised in bits of Africa; or the harsh punishment of children in Koranic schools, which has occurred in Britain. But in recent months a third controversy has shown up contrasts between European countries and within them. This is over female headgear—and in particular, forms of dress in which all, or virtually all, the face is hidden. These include the head-covering burqa; and the commoner niqab, in which only a slit is left for the eyes. The burqa, imposed on Afghan women by the Taliban, has become a catchall term for headgear in which the face is wholly or mainly concealed.

Last month 136 of Belgium's 138 lower-house legislators (who agree on little else, leaving their country near paralysis) voted to outlaw the burqa. Belgian police already have the right to stop people masking their faces, under an old security law; and in some cities this right is invoked to issue warnings to burqa-wearers, who number only a few dozen in the country. So it is hard to see what need the law serves. But a parliamentarian in Brussels said it created a rare moment of “pride in being Belgian” by “smashing the lock that has left quite a lot of women in slavery.” He hoped at least four European countries would follow.

This week France's parliament approved a resolution deploring full-face cover, and legislation is due shortly. In Switzerland one of the 26 cantons has voted to work for a nationwide ban; the justice minister, Eveline Widmer-Schlumpf, backs a ban, at least in cantons that want it. The Dutch authorities considered outlawing the burqa, then stepped back. But in Europe as a whole, the idea of making people show their faces is no longer a xenophobic fantasy, but a mainstream political project.

With a fresh election due in June, Belgium's law is on hold; but it may be the first of many European bans on “all clothing hiding the face totally, or mostly.” Belgian women who wear the burqa in public will risk a modest fine or even seven days' jail. In Italy a woman was fined €500 ($630) last week for wearing the burqa in a town where the Northern League mayor had barred clothing that hinders police checks.

The resolution passed by French legislators has no legal force but it has huge symbolic impact. Recalling the 1789 Declaration of Human Rights, it says the all-over veil “puts women in a relationship of subordination to men”. On grounds of “dignity” and “equality between men and women”, it judges the garment “contrary to the values of the republic”. A law to ban the burqa will go to cabinet on May 19th.

In some places such moves have been promoted by the far right. Italy's Northern League, which wants a national burqa ban, is xenophobic. In Britain the anti-European United Kingdom Independence Party is the only party to agitate for a burqa ban. Ed Balls, a minister in the outgoing Labour government, said it was “not British” to tell people what to wear in the street. Jack Straw, a senior Labour figure who once voiced dismay over women who hid their face when meeting him, is still “fundamentally opposed” to a ban. And Barack Obama said in Cairo last year that Western countries should not be “dictating what clothes a Muslim woman should wear”.

In France, by contrast, the backers of a ban are neither extremists nor fringe feminists. It was first mooted by Nicolas Sarkozy, the centre-right president, who said last year that the burqa was “not welcome” on French soil. The first to call for a parliamentary motion was André Gerin, a Communist. This week's resolution won broad support, including from the Socialists.

In many ways, the French move is the most intriguing test. France is home to Europe's biggest Muslim minority, numbering 5m to 6m. It expects immigrants, or their offspring, of all faiths to adapt to French ways, not the other way round. France holds dear the ideal of laïcité, a strict ban on religion in the public arena that emerged from anticlerical struggles in the 19th century. It was in the name of laïcité that France banned the Muslim headscarf (and other “conspicuous” religious symbols) in state schools in 2004.

But France's leaders do not cite laïcité as a reason for the burqa ban; to do so, they note, would mean accepting that hiding female faces is mandated by Islam. Most influential Muslims in France, including the French Council of the Muslim Faith (CFCM), an official body, and Fadela Amara, a female Muslim minister, reject that reading. Mohammed Moussaoui, head of the CFCM, says “no Koranic text prescribes the wearing of the burqa or niqab.”

So the upcoming law—stating that “nobody may wear clothing that masks the face in any public place”—has been justified on two other grounds. One is security, and the need to be identifiable. (There was consternation earlier this year when two men clad in burqas robbed a post office near Paris.) The other is human dignity and equality between the sexes. “This is not a religious question,” argues Jean-François Copé, parliamentary leader of the ruling UMP party. Most French people view the burqa as a clear token of oppression; if libertarians defend it, this is seen as implying softness on ills such as domestic violence.

Recent news has reinforced that view. This week, in a town west of Paris, police arrested a man suspected of forcing his wife to wear the burqa, and of raping and beating her. (With such cases in mind, the upcoming French law would reserve the harshest penalties for a man found to have made his wife wear the burqa.) Mr Copé firmly rejects the idea that France is unjustifiably curbing liberty. He notes that: “On Fifth Avenue, you do not have the liberty to walk down the street completely nude.”

The motives of young French Muslim women—sometimes more inclined to hide their faces than their mothers were—are hotly contested. Many French analysts say a “re-veiling” trend among young girls reflects manipulation by zealots. Although no more than 2,000 women in France cover their face, the phenomenon is growing. Dounia Bouzar, a French Muslim anthropologist, told a parliamentary inquiry that many of the women were young. Intelligence sources say two-thirds are French nationals, and nearly a quarter converts. Many come from North Africa, where there is no face-covering tradition.

So France's leaders are determined to press ahead. Two risks stand out. First, the ban, which some see as a ruse by Mr Sarkozy to woo far-right voters, may stigmatise Islam and create a defensive reaction. (This is why Mr Moussaoui, who dislikes the burqa, opposes a ban.) As the debate took off, a mosque in south-east France was sprayed with gunfire.

Second, it is unclear how the ban would work in practice. The Conseil d'Etat, the highest administrative court, has questioned the legal basis for the ban. And what about foreigners? Mr Copé says that the ban would apply to visitors too: but would women from the Gulf states be hauled away from smart boutiques?

And then there are other problems: how could one prove that a woman wore a burqa under orders from her menfolk? And isn't there a risk of such women facing further isolation in the home? That would be an odd result for a law designed in part to ensure sexual equality.