Abstract
The chapter introduces the phenomenon of external voting, defined as exercising voting rights by citizens who are temporarily or permanently residing outside their country of origin. We delimit this form of electoral participation from similar forms of transnational politics and discuss the history and diffusion of expatriate enfranchisement, now covering a majority of countries in the world. We then go through the different features of external voting—where is it present, what sorts of elections are covered, what are the modes of organizing elections, how are ballots counted in different political systems, and what the criteria of eligibility might be. Finally, we review the extant literature on external voting, originating in comparative politics and in migration studies, and highlight some gaps that this book seeks to fill.
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When someone says “democracy,” what is the first image that comes to your mind? Quite likely, many readers will answer—casting a ballot. Elections and voting are the core practices of democratic politics; they beat out the rhythm of political contests and provide the most important time horizon for elected policymakers. Votes—the term comes from the Latin word for a wish—constitute a clear expression of the people’s will in the dominant democratic imaginary. Logically, rule of the people must be based on voting. Elections epitomize the ideal of a popular rule to such an extent that even authoritarian dictatorships often hold them to legitimize their power and bask in democracy’s reflected glory (Knutsen et al., 2017).
Beyond the simple mechanics of selecting between pregiven options and throwing the ballot into a box at a polling station, what is also almost intuitively grasped is the connection between voting rights and citizenship. Apart from having a passport, exercising the right to vote is the visible expression of citizenship. As modern democracies developed, enfranchisement expanded, and voting rights were acquired by new groups to finally reach the standard of universal adult suffrage as a liberal democratic norm. For citizens, voting is presented as a right, as well as a duty; as of 2022, electoral participation is compulsory in 21 countries, including Belgium and North Korea, though subject to different sanctions (CIA, 2022).
Modern nation-states are spatially bound, that is, they exercise sovereignty over a clearly specified territory. This is a fairly recent blending of geography and politics where citizenship becomes tied to territory. Globally, of 190 surveyed countries, 37 states base citizenship rules mainly on jus soli, that is on birthright—anyone born in the state becomes a citizen (van der Baaren & Vink, 2021). Most of these countries are in the Americas. Meanwhile, a majority of states base their citizenship regulations on jus sanguinis—or by descent: anyone with a parent (sometimes a father only) becomes a citizen. However, Van der Baaren and Vink (2021) find that most states—and increasingly—have provisions to allow the inclusion of citizens based also on jus domicile—by residence, when people naturalize to become citizens, as well as provisions, for example, for the children of migrants to also allow them citizenship. While there may be different reasons for these developments, among them is the idea that residency and membership are closely connected, and thus also a foundation for political participation in society’s affairs.
Meanwhile, one of modernity’s key features, alongside the expansion of democratic enfranchisement, has been the increase in mobility and international migration. When citizenship, a political principle tied to territory, meets the fluid realities of human mobility, some important and difficult practical questions emerge. What if a citizen is temporarily abroad when an election is held? Or to complicate things—what if a citizen of state A resides permanently in state B, but wants to take part in elections held in their homeland?
This is the subject of our book, and in this introductory chapter, we begin by defining and delimiting external voting. We then briefly sketch its historical development and expansion, up until its contemporary status as a dominant feature in a majority of democratic as well as authoritarian electoral systems. We take a closer look at the way the external voting landscape is organized, which states grant their non-resident citizens voting rights, under what conditions, in what types of elections, and how the voting and then counting votes are organized. Further, we review the literature on external voting which has emerged on the frontiers of political science and migration studies and identify some gaps which this volume seeks to fill, before providing a run-through of the remainder of the book and in the next chapter, introducing the focus of our empirical analysis—Central European migrants in Western Europe.
Defining External Voting
Non-resident citizens’ participation in country-of-origin elections goes by many names. “Expatriate voting” (Escobar et al., 2015), “emigrant voting” (Ciornei & Østergaard-Nielsen, 2020), “out-of-country voting” (Brand, 2014; Globalcit, 2022), “overseas voting” (Jaca & Torneo, 2021), “absentee,” “extraterritorial,” or “diaspora voting” (Lafleur, 2015), “voting from abroad” (Ellis et al., 2007; Peltoniemi et al., 2022), or “at a distance” (Calderón, 2003) all describe similar practices, though with some possible differences. In this book, we use the most common term to describe it: external voting. We see it as a solid analytical term, not easily conflated with more ambiguous ones derived from everyday language. Unlike “expatriate voting,” it does not suggest a focus only on short-term or recent migrants. Unlike “voting from abroad” or “at a distance,” it does not emphasize the method of casting ballots—which may be by post, proxy, or digital—over the relationship of non-resident citizens with their country of origin. Furthermore, non-resident citizens may vote on the territory of their country of origin using provisions established for external voting.
The milestone 2007 IDEAS Handbook Voting from Abroad defines external voting as “provisions and procedures which enable some or all electors of a country who are temporarily or permanently outside the country to exercise their voting rights from outside the territory of the country” (Nohlen & Grotz, 2007, p. 65). Lafleur notes that due to the restrictive nature of early external voting legislation, its definition could be reduced to identifying three steps which describe the procedure: voter registration abroad, casting votes through several different modalities, and finally, the counting and allocation of these votes depending on election regulation (Lafleur, 2015, pp. 842–843). However, the qualitative and quantitative transformations of external voting practices in the last decades require a more nuanced definition, which Lafleur proposes as “the active and passive voting rights of qualified individuals, independently of their professional status, to take part from outside the national territory in referenda or in supra-national, national, or sub-national elections held in a country of which they hold citizenship but where they permanently or temporarily do not reside” (Lafleur, 2015, p. 843).
What these definitions share is the emphasis on casting votes from outside the territory when the election or referendum is held, limitations that can apply in terms of eligibility (e.g., length of residence abroad), the fact that voting rights apply to different kinds of elections, and that these rights may be active (casting a ballot) or passive (standing for election).
The reason why we put so much emphasis on the term’s delimitation and definition is that external voting remains poorly understood in public debate and, compared to other forms of electoral participation, received only limited attention in the academic literature. The rights linked to citizenship, which are focused on and nested in the individual, and those of residence, emphasizing spatial rootedness and boundedness of nation-states, create an unresolvable tension which explains why external voting is also politically controversial (Himmelroos & Peltoniemi, 2021; Michel & Blatter, 2021). It is also partly the reason for why it was not a feature of voting systems in many countries before the 1990s and is still subject to restrictions in some democratic states.
Meanwhile, a related but distinct issue is the question of immigrant voting in the country of residence, which has received growing attention. This falls outside the scope of our investigation, suffice to note that the people about whom we write—migrants voting in elections “back home” are the very same people whom others might write about in relation to voting in their countries of residence. Furthermore, it is worth noting that some people hold dual citizenship, as an increasing number of states also accept dual citizenship (Vink et al., 2019)—in this case, they may have voting rights in national elections both in the country of origin and where they are now living. Others might only have the citizenship of one, or the other, of these countries, with related voting rights. And many countries allow long-term residents, even if they are not citizens, to vote in local elections (see also Schmid et al., 2019). Meanwhile, “irregular migrants,” mostly asylum seekers, might not have any voting rights at all. Thus, the focus of our book is on a specific subset of elections which migrants might be voting in, namely those in their country of origin.
Expansion of Emigrant Franchise
The idea of extraterritorial representation of citizens, who are not present in their homeland during elections, predates modern democracy. Ellis points to ancient Rome under Emperor Augustus as the first example of proto-external voting, when senators of the 28 newly established colonies expressed their preferences for electing city offices in the metropole. In terms of voting modalities, it was a postal vote—sealed ballots were sent to Rome and joined the pool of other votes there (Ellis, 2007, p. 41). Another symbolic milestone for external voting is more modern, but not entirely “external.” During the American Civil War, Wisconsin—a Northern state—allowed absentee voting among its soldiers in the Union Army in 1862. They were voting from the US territory, but outside their state of origin. Finally, New Zealand, in 1890, and Australia, in 1902, made provisions for voting among seafarers, and Great Britain enfranchised its soldiers fighting in the trenches of World War I, allowing for absentee voting by proxy. During the Great War, also Canada and New Zealand made provisions for external voting among their servicemen. Limiting external voting rights to soldiers, seamen, diplomats, and civil servants is still practiced and sets the boundaries for external voting rights in many countries throughout the twentieth century (Ellis, 2007, p. 42; Lafleur, 2015, p. 842).
A less known case of expatriate, though not out-of-country, voting are the 1920 and 1921 referenda (plebiscites) organized on German-Polish ethnic borderlands, East Prussia and Upper Silesia. There, non-residents who were born in these areas but emigrated (mostly to the Ruhr basin) were allowed to travel to their localities of origin to cast a ballot in favor of either German or Polish sovereignty over the contested territory. Despite the difficulty of traveling at a long distance, some 100,000–150,000 expatriates turned up for the East Prussian plebiscite, and as many as 200,000 in the Upper Silesian plebiscite. In the latter case, 19.3% of total ballots cast by non-resident expatriates turned out to be a swing vote in favor of Germany in many localities and counties (Gołasz, 2020; Węcki, 2021).
The main problems of external voting at the time were technical. Collecting ballots overseas meant that for them to be included, elections had to be extended significantly. For instance, in the 1945 elections in the United Kingdom, where military personnel, seafarers, diplomats, and civil servants working abroad were allowed to vote, counting was delayed by three weeks to allow for their ballots to be delivered. Meanwhile, the levels of international migration in the mid-twentieth century, once displaced persons and prisoners of war returned home from World War II, were still modest. So was the number of independent nation-states and democracies holding competitive elections.
In the second half of the twentieth century, the world went through two major waves of democracy expansion. The first one followed decolonization in the 1960s and 1970s, the second—the fall of numerous dictatorships at the end of the 1980s and early 1990s, most importantly in the Communist bloc, but also elsewhere, for example, the Philippines, Paraguay, or South African Republic.
This last wave of democratization coincides with the diffusion of external voting rights. As Nohlen and Grotz note (Nohlen & Grotz, 2007, p. 65), even in some long-established democracies, like the United Kingdom and West Germany, citizens did not obtain external voting rights until the 1980s, or 1990s in the case of Japan. In other words, it was not only the increasing number of new democracies, but the emergence of what some scholars perceive as an international norm around external voting rights (Lafleur, 2015; Rhodes & Harutyunyan, 2010). The flip side, as we have already noted, is immigrant enfranchisement in host countries, which similarly to external voting can be seen either as a sign of deeper democratization or of undermining the core principles of the citizenship/territory nexus (Caramani & Grotz, 2015; Reidy, 2021).
These newly democratized states were often also contributors to increasing international migration. Indeed, developing and transition countries accounted for a large share of outward migration. Migration was also linked to international or civil conflict, and post-authoritarian or formerly war thorn countries had considerable political diasporas as well as groups of refugees abroad (Brand, 2006, 2010). Faced with significant numbers of citizens outside their borders, states were inclined to consider émigré enfranchisement, for normative as well as pragmatic reasons, such as to keep emigrants connected to homeland, sustaining the inflow of remittances and potential return migration in the future (Baser, 2016).
The pressure for political participation of migrants rises with the growing migrant population. The 2022 World Migration Report estimates that in 2020 there were some 281 million international migrants globally, constituting 3.6% of the world’s population (McAuliffe & Triandafyllidou, 2022). While the estimates of global migration are unreliable, this is a clear increase since 1990 when the figure was about 155 million or 2.87% of the global population, or in 2000 when the figure was about 172 million or about 2.83% of the global population, and more clearly since, with a rise to 221 million international migrants in 2010, or about 3.17% of the global population, and in 2015 to 249 million, or about 3.37% if the global population (IOM, 2022). This means that the share of international migrants of the global population is rising, as their number grows faster than total world population, albeit not at all dramatically, and still at just above 3% in 2020, meaning that more than 96% of the global population are, in fact, not international migrants. That said, the 281 million people who are international migrants constitute a higher number of people than the entire population of the fourth most populous country in the world, Indonesia, with some 275 million inhabitants. Thus, international migration is a force to be reckoned with.
In sum, the number of states that enfranchise their citizens residing outside national borders has grown rapidly over the past three decades, and particularly since the turn of the century (Fliess & Østergaard-Nielsen, 2021; Navarro et al., 2007; Turcu & Urbatsch, 2015). By 2007, some 115 countries and territories allowed for external voting—over a half of United Nations members. Currently, this number is at around 130 countries (Himmelroos & Peltoniemi, 2021; Peltoniemi et al., 2022).
External Voting Landscape: Countries, Elections, Criteria, and Modalities
Some two-thirds of states and territories allow for some form of external voting. This landscape is, however, very varied in terms of conditions for voting, modalities (how the voting can occur), and which types of elections are covered. There are also different regional patterns of external voting possibilities. Up to date datasets and overviews are difficult to maintain due to the regulations which may change from year to year and from election to election. However, the IDEAS dataset, covering 214 countries and related territories, lists 28 African countries, 16 countries in the Americas, 20 in Asia, 41 in Europe (Western, Central, and Eastern), and 10 in the Pacific region with external voting provisions in place, and five more where external voting is legally allowed but where it has not yet been implemented (Navarro et al., 2007).
A more recent dataset, prepared by the Global Citizenship Observatory (GLOBALCIT) at the European University Institute, looks at 28 European Union member states, 20 American countries, Australia, New Zealand, and Switzerland and provides updates on “conditions for electoral rights,” including external voting regulations (Globalcit, 2019). Of these 51 countries, in 2019 40 offered some provision for external voting. The most comprehensive source of data on external voting provisions is the recent Extraterritorial Voting Rights and Restrictions Dataset (1950–2020), where the authors note that “enfranchisement of non-residents is both multifaceted and dynamic. Countries that enfranchise non-resident citizens face an array of choices as to how voting will be facilitated and incorporated into the existing political system” (Wellman et al., 2022, p. 1).
External voting provisions may apply to five different types of elections: national legislative elections, presidential elections, referendums, and sub-national (e.g., local) elections as well as supra-national elections. The latter are only available in some EU member states, which allow non-resident citizens to vote on national Member of European Parliament (MEP) candidates from abroad—even though EU legislation gives all EU citizens the right to vote in European Parliament elections based on residence, not citizenship. The other case, as Lafleur points out, is the Andean Parliament (Lafleur, 2015, p. 845). Looking only at the first four types of elections, the IDEAS dataset lists as many as nine different combinations of external voting rights, where no country limited external voting rights to referenda only (although historically this limitation has occurred).
In terms of criteria of eligibility and entitlement for external voting, most restrictive countries (14 in 2007) limit these to diplomats and other officials on duty or military personnel. This group includes two states boasting a large historic diaspora—Israel and Ireland, the latter listed as the sole EU member state with such restrictive external voting rights.Footnote 1 Also Cyprus, Malta, and Denmark limit external voting eligibility to specific categories of expatriate citizens or based on length of stay abroad, and the intention of return (Globalcit, 2019).
There are five modes of external voting used: personal voting at a polling station in the country of residence (often a diplomatic mission); postal voting; voting by proxy (selecting a plenipotentiary who casts the émigrés ballot in the country of origin); voting by fax; and e-voting. Postal voting has also developed a subvariant, known as voting by a massager (Sweden) and with a witness (Finland) (Navarro et al., 2007; Wass et al., 2021; Weide, 2021). On top of these modalities, there is also a combination of ways in which electoral registration takes place, how and according to what principles it is organized, how early prior to the election one has to register, and so forth. Some countries only allow for in-person voting at polling stations abroad if a certain threshold number of registered voters is reached (e.g., 20 for Bulgaria, 30 for Brazil, but as many as 500 for Senegal) (Navarro et al., 2007, p. 25).
Finally, once external votes are cast, the question of where they go, how they are counted, and how émigré voters are represented in the political system remains. In some cases, all votes cast externally are summed up as part of a “diaspora” constituency (e.g., Czech Republic). In others, they are assigned to the locality of voter’s last residence (e.g., Hungary). Finally, they may be merged with votes cast by homeland voters, for example, in the capital (as is the case in Poland, where all external votes are added to Warsaw 1 district). Some 12 countries secure political representation of emigrants in their parliaments. Some of them (e.g., Capo Verde and Italy) distinguish between the countries of residence of voting migrants and reserve a certain number of seats, for example, for those living in the Americas and Europe (see also Laguerre, 2015).
The European Union is a particularly interesting case for external voting, and as of 2020, almost all European countries allow their nationals to cast ballots outside their territories (Commission, 2020). The peculiarity of the EU, and more specifically the Schengen area (which includes, e.g., Norway but does not include Ireland, Bulgaria, or Romania), is that one of the Union’s key freedoms—freedom of movement—undermines the notion of residency. EU citizens can live for years in other EU member states without formally losing residency in countries of origin and often without registering in host countries. Enfranchised automatically in local and supranational elections in countries of residence, they enjoy more political rights than many non-EU migrants who spent more time in respective host countries.
What Do We Know About External Voting? Migration Studies Meet Political Science
Despite the globally expanding émigré enfranchisement and the clear potential impact of migrant votes on politics in some regions, external voting has been, according to Lafleur, a “research topic attracting little scholarly attention” (Lafleur, 2015, p. 840). Several years since these words were written, the situation has not changed significantly, even though external voting lies at the intersection of two academic disciplines—comparative and migration studies to an extent, in the domain broadly labeled transnational political practices (Østergaard-Nielsen, 2003) or just political transnationalism (Boccagni et al., 2016).
While there are significant exceptions from this apparent disinterest (see, for example, Brand, 2010; Collyer, 2014; Escobar et al., 2015; Finn, 2020; Goldberg & Lanz, 2019; Lafleur & Sánchez-Domínguez, 2015), it appears that comparative politics students are yet to acknowledge the significance of emigrant electoral engagement, while migration scholars need to overcome their reticence toward formalized political practices and institutions. Furthermore, many studies of migrant electoral behavior concern the way immigrants vote in the elections of their countries of residence, even though there are still significant barriers to immigrant enfranchisement (Barker & McMillan, 2017; Kayran & Erdilmen, 2021). The disproportionate attention paid to immigrant voting versus external voting is explained, for example, by data availability and the interest within receiving societies.
However, as the editors of a recent special issue of Frontiers in Political Science dedicated to voting from abroad note, “with more citizens living and working outside of their home country and new technologies making it ever easier for emigrants to participate in the homeland politics, the topic of emigrant voting is highly relevant” (Peltoniemi et al., 2022, p. 2).
Fliess and Østergaard-Nielsen (2021) summarize the extant literature in four categories, which are also to some extent chronologically arranged “waves” of research. The first wave concentrated on the normative debate on legitimacy of external voting, followed by studies of why states grant emigrant voting rights. Third wave comprises studies on the creation of special emigrant representation systems. The fourth and most recent wave according to these authors moves beyond the state as the main unit of analysis, for example, by unpacking the role political parties play in the enfranchisement process and in oversees voter mobilization (Kernalegenn & van Haute, 2020; Umpierrez de Reguero & Dandoy, 2021). A somewhat specific offshoot here is the literature on authoritarian states and diaspora mobilization, which also includes the question of external voting (Baser & Féron, 2022; Böcü & Baser, 2022; Koinova, 2021).
Several studies, like Lafleur and Sánchez-Domínguez (2015), explore the determinants of external voting, but knowledge on why migrants vote the way they do is still limited. However, even a passing look at the voting outcomes in different national elections, and the number of votes cast abroad reveals an additional puzzle: a grand majority emigré voters do not participate in elections (Ciornei & Østergaard-Nielsen, 2020; Hutcheson & Arrighi, 2015; Jaca & Torneo, 2021; Szulecki et al., 2021). This suggests that beyond asking why migrants vote the way they do, we also need to ask the more fundamental question: why they vote, or not, in the first place, and inquire into the determinants of electoral turnout in external voting. This clearly means moving beyond the four waves that Fliess and Østergaard-Nielsen have identified. Rather than concentrating on the legitimacy of external voting, diffusion of voting provisions and explanatory factors behind them, we want to inquire about the way migrants use the opportunity that external voting enfranchisement gives them.
We therefore see a fifth wave emerging, to which we hope this book will contribute—studying how external voting is practiced, including voting results, turnout, and the meaning of this form of political engagement for migrants in terms of their political expression connection to their countries of origin.
This brings us to the core puzzles which drive this new wave of research and motivate our book. How do migrants use their external voting franchise? What parties and candidates do they vote when they have the opportunity? And finally, do the results of external voting differ systematically from domestic results? Another set of questions relates to the turnout. While media coverage of some expatriate votes emphasizes their scale and possible influence on homeland politics, existing research, as was already noted, and anecdotal evidence from many elections, suggests that external voting suffers from very low turnout. If that is the case, what can explain why (so few) migrants take part in homeland (electoral) politics? How do the migrants themselves see this form of political engagement and what does external voting tell us about migrant political participation? Finally, on a more theoretical level, how is it related to political remittances?
What does the literature tell us so far? First of all, research on external voting in country-of-origin election is dominated by national case studies of either specific countries of origin or countries of residence (Boccagni, 2011; Burean & Popp, 2015; Escobar et al., 2015; Finn, 2020; Gamlen, 2015; Goldberg & Lanz, 2019; Itzigsohn & Villacrés, 2008; Lafleur & Chelius, 2011; Lafleur & Sánchez-Domínguez, 2015; Leal et al., 2012; Lesińska, 2018; McIlwaine & Bermudez, 2015; Mencütek, 2015; Mügge et al., 2019; Peltoniemi, 2018; Sevi et al., 2020).
Where larger comparative studies exist, they focus on explaining the emergence and horizontal diffusion of external voting rights, that is—why do sending countries grant expatriates the right to vote in the first place (Arrighi & Lafleur, 2019; Caramani & Grotz, 2015; Collyer, 2014; Collyer & Vathi, 2007; Erlingsson & Tuman, 2017; Hartmann, 2015; Hutcheson & Arrighi, 2015; Lafleur, 2011, 2015; Palop-García & Pedroza, 2017; Rhodes & Harutyunyan, 2010; Umpierrez de Reguero et al., 2021; Wellman, 2021). Another issue attracting attention has been the impact of party mobilization and party activity abroad (Burgess & Tyburski, 2020; Fliess, 2021; Kernalegenn & van Haute, 2020; Lazzari, 2019; Østergaard-Nielsen et al., 2019; Umpierrez de Reguero & Dandoy, 2020). Electoral turnout has also been the object of analysis, though studies of the factors that can account for turnout and results beyond a single country of origin or residence remain scarce (Chaudhary, 2018; Ciornei & Østergaard-Nielsen, 2020; Ognibene & Paulis, 2021; Pallister, 2020; Szulecki et al., 2021).
The focus on state agency (granting external voting rights) and homeland political parties has so far meant the limited or denied political agency of emigrants in the study of external voting. While research on remittances beyond money transfers, that is, “social” as well as “political remittances,” has expanded greatly in the past quarter century (see, for instance, Kessler & Rother, 2016; Krawatzek & Müller-Funk, 2020; Leblang, 2017; Levitt, 1998; Levitt & Lamba-Nieves, 2011), the understanding of external voting as a mode of political engagement with the “homeland” is still very limited (but see De Lazzari, 2021; Erdal et al., 2022; Lafleur, 2013, Chap. 6; Peltoniemi, 2018; Tabar, 2014).
This book offers a comparative analysis of external voting practices—that is both election results, turnout, and insights on the way migrants perceive external voting as a mode or transnational political engagement. We draw on two datasets built within the framework of the DIASPOlitic project, collecting all elections for Central European “sending countries,” divided by external voting results among expatriate voters in Western European “host countries,” as well as interviews with Polish and Romanian migrants living in Norway and Spain. The next chapter introduces our empirical case, external voting among Central-Eastern European migrants living in Western Europe, and we outline the context of their political engagement, namely, the apparent democratic backsliding in many countries of the region. Further, the chapter introduces the research project on which the book is based, describing its quantitative and qualitative components, data gathering procedures, and methods used for analyzing the data.
The next empirical chapters address the puzzles we have presented earlier. Chapter 3 asks how migrants vote when they have the opportunity and whether the results of external voting differ systematically from domestic results. Chapter 4 interrogates why (so few) migrants take part in homeland (electoral) politics and what external voting tells us about migrants’ transnational political participation. The Conclusion brings together insights from both these empirical endeavors, but also introduces a normative question—should nonresident citizens have the right to vote? We seek to answer it drawing not only on the existing studies in law and political philosophy, but also the findings of our project and migrants’ own perceptions of external voting legitimacy.
Notes
- 1.
Not counting Greece, which is among the five countries that have legal provisions for external voting but has not implemented them in practice. However, since residence does not exist as a legal category in Greek electoral regulation, non-resident citizens can vote if they are present in the country and can stand as candidates.
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Szulecki, K., Erdal, M.B., Stanley, B. (2023). Introduction. In: External Voting. Migration, Diasporas and Citizenship. Palgrave Macmillan, Cham. https://doi.org/10.1007/978-3-031-19246-3_1
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