Seen by some as a mark of religious freedom and others as an insult to women’s equality, the wearing of Muslim headdress like the niqab or the burka in public has stirred controversy in Canada as well as other Western nations.

Here’s a look at how the issue has played out in various jurisdictions.

Canada

On Dec. 12, Immigration Minister Jason Kenney announced that Muslim women in Canada must remove face coverings like the niqab or the burka before they can recite the oath of citizenship to become Canadians.

Meanwhile, an Ontario woman who wears the niqab is the subject of a case currently before the Supreme Court of Canada. Known only as “N.S.,” the woman is the complainant in a sexual assault case and wants to testify in court while wearing the face veil. Her defendants counter that for the purpose of cross-examination, they should be able to see her facial expressions.

In Quebec, the issue of Muslim headdress is at the centre of the “reasonable accommodation” debate. In the summer of 2011, Quebec’s Lac St. Louis Regional Soccer Association barred Sarah Benkirane, a referee, from the league because she wears a hijab.

In March of 2010, a woman born in Egypt complained to the Quebec Human Rights Commission after she was kicked out of a language class for new immigrants at the CÉGEP St-Laurent for refusing to take off her niqab in class. A month later, a 25-year-old permanent resident from India known only as Aisha was removed, for the same reason, from a language class at the Centre d'intégration multi-services de l’Ouest de l’Île in the Montreal suburb of Pointe-Claire.

In 2010, the Quebec government tabled Bill 94, which would prohibit women in front-line government agency jobs from wearing religious face coverings. The bill has not been passed.

France

In France, where secularity is enshrined in the constitution, religious apparel has been a point of contention for some time. The country introduced a ban on Muslim headscarves and other overt religious symbols at state schools in 2004, and in 2010, approved a bill that bans the wearing of the burka — or the full veil — in government offices, public transport, hospitals and schools.

Belgium

In 2010, Belgium enacted a ban on wearing the burka in public.

Netherlands

In April 2011, a Dutch court ruled that a Catholic school in the city of Volendam was within its rights to ban a 15-year-old girl from wearing an Islamic headscarf, saying it was a justified measure in preserving its Catholic character. Later in the year, Holland became the third European country to ban the burka in public.

Spain

There are no federal laws banning religious symbols, but the city of Barcelona enforces a ban on burkas in public places such as municipal offices, libraries and public markets.

Germany

In 2003, the country’s Constitutional Court ruled in favour of a teacher who wanted to wear an Islamic headscarf to school, but noted that individual German states were free to change their laws if they desired to.

Turkey

Since the 1920s, this Muslim majority country has gone to great lengths to separate church and state. As a result, the wearing of religious apparel has been much contested. In 1980, the government banned Islamic headdress in government institutions. In February of 2008, Turkish parliament amended the constitution to allow women to wear the hijab in universities, but later that year, the country’s Constitutional Court reinstated the ban. In 2010, the government relented, allowing women to wear headscarves in universities.