« The Naturalization of Greeks in the Romanian Principalities of Wallachia and Moldavia: Disputed Meanings, Contested Interpretations », in A. CUŞCO, Fl. SOLOMON, K. CLEWING (ed.), Migration and Population Politics during War(time) and Peace(time)..., Cluj-Napoca 2021: Mega, p. 65-87

Lidia  Cotovanu

In one respect, the three volumes reviewed here are similar to one another: they are all sceptical of the idea of mass migrations, and ambiguous about the concept of ethnic identity and the possibility of inferring it from archaeological evidence. This reflects current intellectual fashion, and there are, of course, good scholarly reasons for the doubts and uncertainties expressed in these volumes. It is, however, an irony that exactly at the point where identity has become the key question of the post-modern world, and migration is fast becoming the key issue of post-Soviet Europe, academic archaeologists and historians have lost their own convictions and fail to provide the historical guidance that the general public is looking for. There is some evidence that the pendulum of the academic debate is swinging back. This is partly due to the use of scientific techniques, primarily DNA analysis. But there is another irony here. The first results from recent Y-chromosome analyses suggest large-scale population replacement in England following the Anglo-Saxon immigration. In other words: the most modern technique returns us to the oldest model. Those who ducked when the pendulum swung by just over a decade ago should prepare to duck again.

This paper offers a conceptual framework in terms of which the current Pontic Greek experience of displacement from the Soviet Union can be interpreted in a historically informed way, by addressing two sets of issues: methodological and substantive. With respect to the former, I argue that 'refugeeness' is a modern phenomenon associated with the formation of nation states, entailing thus a necessary correlation between 'nationalism' and 'refugees'. This accounts for the mobility pattern of the Pontic Greeks from the Ottoman Empire to the Caucasus through the 19th century as an instance of migration rather than refugeeness. In turn, I seek to establish the historical and conceptual links between 'nationalism' and the cultivation of 'national identity' as part of the modern Greek state's irredentist policy which supports all current claims to 'repatriation' and the Greek homeland. Yet, this bears no necessary historical relation to 'ethnic identity claims' which show themselves to be contingently construed and relationally specified. Substantively, in view of these peoples' repeated uprootings, any attempt to define their movements in terms of volition is insufficient to capture the complexity of their experience which often acquires dramatic proportions, as in the recent case of the Greeks from Central Asia, which includes phenomena of social nmn^'i and historical gaps in the group's collective consciousness. Both features turn them into refugees.

Migrations, transfers and population changes have taken place between states from Balkans and Anatolian area in the first half of the twentieth century. This process had as a result the appearance of new ethnicities having the place of origin as a central identity marker. Although under a general theory, each case must (also) be treated in its specific. The present paper approaches the case of Arvanites from Tyhero, Greece, a village near the river Evros, the border with Turkey. The conclusion is that their identity in relation to a place of origin, situated not far away beyond Evros, is retreating in the face of an identity connected to the entire region of Thrace.

MIGRATION AND POPULATION POLITICS DURING WAR(TIME) AND PEACE(TIME) CENTRAL AND EASTERN EUROPE FROM THE DAWN OF MODERNITY TO THE TWENTIETH CENTURY Migration and Population Politics during War(time) and Peace(time) Central and Eastern Europe from the Dawn of Modernity to the Twentieth Century Edited by Andrei Cușco, Flavius Solomon, Konrad Clewing Editura MEGA Cluj‑Napoca 2021 The Proceedings of the International Conference Migrations and Identity in European History: Communities, Connections, Conflicts, organized by the Romanian Academy in Iași on 26–28 September 2019, supported by the Alexander von Humboldt Foundation and the Romanian National Authority for Scientific Research, CNCS – UEFISCDI, project number PN‑III‑P1‑1.2‑PCCDI‑2017‑0116. DTP and cover: Francisc Baja © The authors, 2021 Cover image: Teodor Boian, Târgul din Iași [The Iași Fair] (1875‑1880), oil painting on canvas, National Museum of Art of Romania, Bucharest. Source: Sorin Iftimi, Orașul Iași în imagini vechi/Jassy in Old Images (Bucharest: DAR Development Publishing, 2020). Descrierea CIP a Bibliotecii Naţionale a României Migration and population politics during war(time) and peace(time): Central and Eastern Europe from the dawn of modernity to the twentieth century / ed.: Andrei Cuşco, Flavius Solomon, Konrad Clewing. – Cluj‑Napoca: Mega, 2021 Conţine bibliografie. – Index ISBN 978‑606‑020‑330‑8 I. Cuşco, Andrei (ed.) II. Solomon, Flavius (ed.) III. Clewing, Konrad (ed.) 94 Editura Mega | www.edituramega.ro e‑mail: mega@edituramega.ro Contents List of contributors 7 Introduction 9 TOWARDS A NEW HISTORY OF MIGRATIONS: REASSESSING METHODS AND RESEARCH AGENDAS Alexander Rubel Migrationsgeschichte als Weltgeschichte. Ein Plädoyer für neue Akzente in der historischen Migrationsforschung unter Einbeziehung der Vor- und Frühgeschichte 25 THE BIRTH OF NEW ELITES: POLITICAL AND INTELLECTUAL MOBILITY IN THE MODERN ERA Lidia Cotovanu The Naturalization of Greeks in the Principalities of Wallachia and Moldavia: Disputed Meanings, Contested Interpretations 65 Simion-Alexandru Gavriș Foreign-Born Bureaucrats in the Principality of Moldavia in the Early 19th Century 89 Leonidas Rados Forging the Modern Romanian Intellectual Elite: Andrei Vizanti as a Student in Iași and Madrid 109 Flavius Solomon In Search for a New Homeland: Narodnik Émigrés in Romania during the 1870s 147 Andrei Cușco Zamfir C. Ralli Arbore and Constantin Stere Between Anarchism, Populism, and Nationalism: Two Cases of Russian Political Émigrés to Romania in the Late 19th and Early 20th Century 177 SEARCHING FOR THE LOST HOMELAND: POPULATION MOVEMENTS IN INTERWAR EUROPE Konrad Clewing Zwischen allen Stühlen? US-albanische Erfahrungen vom Auswandern und Rückwandern im frühen 20. Jahrhundert 203 Tatiana Ilarionova Migration as Salvation: Contributions to the History of Germans and Jews in Russia and Southeast Europe between the World Wars 231 Gábor Egry Magyar Returnees and Political Radicalization in Post-World War I Hungary 253 Mehmet Hacısalihoğlu Blurring Borders Between Religion and Ethnicity: Turkey’s Migration Policies towards the Balkans in the Interwar Period (with Special Reference to Bulgaria) 271 IDENTITY PROJECTS AND POPULATION POLITICS DURING WORLD WAR II AND IN ITS AFTERMATH Ottmar Trașcă The Impact of the Second Vienna Award on the Demographic Situation in Transylvania. Forced Population Displacements in a Contested Space, 1940–1944 301 Philippe Henri Blasen „Vor allem eine Kirche deutscher Menschen“: die evangelische Landeskirche A.B. in Rumänien und die Taufe der Juden (1940–1944) 335 Dorin Dobrincu ‘A Famine Like No Other:’ The Swedish Rädda Barnen Society and Its Assistance to the Children of Eastern Romania, 1946–1948 359 MIGRATION AND RESHAPING OF IDENTITIES IN POST-COLD WAR EUROPE Péter Varga Jüdisch-deutsche Literatur der dritten Nachkriegsgeneration – eine Migrantenliteratur? 389 Index 401 The Naturalization of Greeks in the Principalities of Wallachia and Moldavia: Disputed Meanings, Contested Interpretations* Lidia Cotovanu rom the very start, after their foundation as states (in the 14th century), the Romanian Principalities turned into migration areas (broadly) and, given geopolitical developments in South-Eastern Europe over the next centuries, they remained so until the emergence of the modern Romanian nation-state in the 19th century. In the context of Ottoman advances into the Balkans and consequent disappearance of the South-Slav states, the Romanian Principalities became havens for Christian refugees from across the Danube. As new power pockets emerged to the north of the Danube, many members of the South-Slav noble, military and merchant classes, and even peasants, became available to fill in much-needed human resource vacancies in Wallachia and Moldavia: they ended up playing a significant role in the consolidation of the political-administrative machinery of the two emerging states, the growth of trade networks as well as demographic growth and much-needed taxpayer pools.1 As the Ottomans F * Greek version: “Η πολιτογράφιση (naturalisation) των Ρωμιών / Γραικών στις Παραδουνάβιες Ηγεμονίες: ένα ψευδές ιστοριογραφικό πρόβλημα”, in Panagiotis G. Kimourtzis, Anna B. Mandylara, and Nikolaos Mpoumparis, eds., Η Ιστορία, μία καλή τέχνη. Κείμενα αφιερωμένα στον Γ.Β. Δερτιλή (Athens: Asini, 2021), 95–115; the editors have modified the paper’s title (thus altering its meaning) without consulting me. 1 The topic is further developed in my doctoral thesis: Lidia Cotovanu, Migrations et mutations identitaires dans l’Europe du Sud-Est (vues de Valachie et de Moldavie, XIVe – XVIIe siècles), Unpublished PhD thesis, École des Hautes Études en Sciences Sociales [EHESS] (Paris, 2014); Cotovanu, “À la recherche de nouveaux contribuables: politiques publiques de colonisation rurale avec des ‘étrangers’ (Valachie et Moldavie, XIVe – XVIIe siècles)”, Revue des études sud-est européennes 53, nos. 1–4 (2015): 33–69; Cotovanu, “Gestionari epiroți ai cămărilor domnești: cazul negustorilor Igumenos de la Ioannina și al familiei lor extinse (sfârșitul 65 L i d i a C ot ovanu established and consolidated their power on the banks of the Bosphorus, the Romanian Principalities fell under the political and ecclesiastical control of Constantinople. As such, they became lands of socio-political and professional opportunity for the sultan’s Christian subjects. During the 14th and 15th centuries, immigration was dominated by the SouthSlavs, however this changed by mid–16th century, when growing numbers of Greek-speaking Ottoman subjects, largely from Epirus, Thessaly and Macedonia, established a new migratory trend which endured until mid–19th century. Throughout this period, migrants from the Greek lands managed to occupy prominent positions in government and administrative structures and the economy of the two Romanian lands.2 Starting from the second half of the 16th century, a new figure emerged in the Wallachian and Moldavian political discourse: the “Greek” as an undesirable alien and vehicle for foreign domination over the two principalities, which retained their political-administrative and legal autonomy vis-à-vis the Porte. In the eyes of Wallachian and Moldavian natives, the “Greeks” were to be “blamed”’ for all the ills afflicting the two principalities: they undermined all “good customs” (obiceaele cele bune), grabbed a disproportionate amount of the economic revenue, exploited the peasants, corrupted the ruling princes, etc. This became an established trope in 17th-century local historiography and was consistently promoted by political figures opposing Ottoman power and Porte-appointed rulers.3 secolului al XVI-lea – începutul secolului al XVIII-lea”, in A. Timotin (ed.), Dinamici sociale și transferuri culturale în Sud-Estul european (secolele al XVI-lea și al XIX-lea) (Bucharest: Editura Academiei Române, 2019), 147–63. 2 On the “Greek” migrations to Wallachia and Moldavia, see Radu Păun, Pouvoirs, offices et patronage dans la Principauté de Moldavie au XVIIe siècle. L’aristocratie roumaine et la pénétration gréco-levantine, Unpublished PhD thesis, EHESS (Paris, 2003); Andronikos Falangas, Présences grecques dans les Pays roumains (XIVe – XVIe siècles). Le témoignage des sources narratives roumaines (Bucharest: Omonia, 2009); Ștefan Petrescu, Migraţie şi Ortodoxie în Europa de Sud-Est de la “destrămarea” societăţii fanariote la constituirea comunităţilor greceşti în prima jumătate a secolului al XIX-lea (Bucharest: Muzeul Național al Literaturii Române, 2013); Cotovanu, Migrations, with comprehensive bibliography. 3 The principle of double election of the monarch applied in the Romanian Principalities: first, he was anointed by “divine grace”, and secondly he was elected by the boyar class from several candidates chosen from among the country’s ruling dynasty and subsequently endorsed by the entire country: Păun, Pouvoirs, offices et patronage, 37–83; Păun, “La circulation des pouvoirs dans les Pays Roumains au XVIIe siècle: repères pour un modèle théorique”, in New Europe College Yearbook, 1998–1999 (Bucharest: NEC, 2001), 263–311; Oana Rizescu, Avant l’“État-juge”: Pratique juridique et construction politique en Valachie au XVIIe siècle (Bucharest: Notarom, 2008), 317–24, 350–51. Consequently, the ruling princes appointed by the Porte were legitimated in the context of the two principalities’ political dependency on the sultan; however, their appointment was illegal in terms of the Wallachian and Moldavian laws and traditions: Rizescu, Avant l’“État-juge”, 169–72. 66 The Naturalization of Greeks in the Principalities of Wallachia and Moldavia Many princes accused of being too “enamoured of the Greeks” lost their throne in the aftermath of coups d’état.4 “Assimilation”, “Naturalization”, “Putting Down Roots” (împământenire) Contemporary Romanian historiography has remained inertially focused on the “Greeks” rather than other communities which migrated and settled the principalities in the intervening centuries. Researchers have focused specifically on the “Greeks”’ infiltration of their host country’s power structures,5 their strategies of integration and upward mobility,6 their family alliances,7 commercial activities,8 Lidia Cotovanu, “Chasing away the Greeks”: The Prince-State and the undesired foreigners (Moldavia and Wallachia, end of the 16th – beginning of the 18th Century)”, in Olga Katsiardi-Hering and Maria A. Stassinopoulou, eds., Across the Danube: Southeastern Europeans and Their Travelling Identities (17th–19th Centuries) (Leiden – Boston: Brill, 2016), 215–52. 5 Nicolae Iorga, Byzance après Byzance: Continuation de l’histoire byzantine (Paris: Balland, 19923); Andrei Pippidi, Tradiţia politică bizantină în Țările române în secolele XVI – XVIII (Bucharest: Corint, 20012); Păun, Pouvoirs, offices et patronage, passim. 6 Matei Cazacu, “Stratégies matrimoniales et politiques des Cantacuzène de la Turcocratie (XVe–XVIe siècles)”, in Cazacu, Au carrefour des Empires et des mers: Études d’histoire médiévale et moderne, eds. Emanuel Constantin Antoche, and Lidia Cotovanu (Bucharest – Brăila: Istros, 2015), 443–65; Andronikos Falangas, “Ascension et stratégies sociales dans le Sud-Est Européen aux XVIe – XVIIe siècles: de quelques Épirotes anoblis dans les Pays Roumains”, in Interbalcanica. Rapports des Congrès (Athens: National Committee for South-East European Studies, 2006), 73–86; Gerd Frank, “Grecii din Moldova între integrare şi asimilare (sf. sec. XVI – prima jumătate a sec. XVII): Modele de ascensiune socială”, in Ion Toderaşcu, ed., Etnie şi confesiune în Moldova medievală (Iaşi: Editura Universității „Alexandru Ioan Cuza”, 2006), 179–265; Radu Păun, “Les Gréco-Levantins dans les Pays Roumains: voies de pénétration, étapes et stratégies de maintien”, Studia Balcanica. “Vizantija. Bălgarija. Evropa. Izsledovanija v cest na Prof. Vasilka Tăpkova-Zaimova” 25 (2006): 304–16; Păun, “Les grands officiers d’origine gréco-levantine en Moldavie au XVIIe siècle. Offices, carrières et stratégies de pouvoir”, Revue des études sud-est européennes 45, no. 1–4 (2007): 153–95; Gheorghe Lazăr, “„De la boutique à la terre”. Les marchands “grecs” et leur stratégie d’insertion sociale (Valachie, XVIIe siècle)”, Studii şi materiale de istorie medie 26 (2008): 51–67. 7 Radu Păun, “Stratégies de famille, stratégies de pouvoir: les Gréco-Levantins en Moldavie au XVIIe siècle”, in Ionela Băluță, Constanţa Vintilă-Ghițulescu, and Mihai-Răzvan Ungureanu, eds., Social Behaviour and Family Strategies in the Balkans (16th – 20th Centuries). Comportements sociaux et stratégies familiales dans les Balkans (XVIe – XXe siècles). Actes du colloque international, 9–10 juin 2006, New Europe College, Bucharest (Bucharest: NEC, 2008), 15–38; Gheorghe Lazăr, “La route vers la haute société: les marchands et leurs stratégies matrimoniales (Valachie, XVIIe – XVIIIe siècles)”, in Băluță et al., eds, Social Behaviour and Family Strategies, 39–57. 8 Ioan Caproşu, O istorie a Moldovei prin relaţiile de credit până la mijlocul secolului al XVIII-lea (Iaşi: Editura Universității „Alexandru Ioan Cuza”, 1989); Cătălina Chelcu, “Implicarea elementului grecesc în economia Moldovei în vremea lui Petru Şchiopul”, in Leonidas Rados, ed., Interferenţe româno-elene (secolele XV – XX) (Iaşi: Fundația Academică “Al. D. 4 67 L i d i a C ot ovanu legal status9 (which in fact made no distinction between “Greeks” and other local subjects), as well as the discourses and practices of rejection targeted against them,10 etc. In these studies, the Greeks’ “assimilation”, “naturalization” and “putting down roots” (împământenire) are generally taken as evidence of certain forms of socio-cultural dilution of the “allogenous” (i.e. non-native) elements amounting to “Romanianization”. The opposition between (Romanian) majority vs. minority has often been deployed (anachronistically, given that, in fact, it draws on contemporary ethno-national discourse) in the analysis of all forms of integration of the aliens having settled permanently in the Principalities. When the Orthodox “minorities” in question belonged to the less numerous – and, as such, deemed less “visible” – communities (Bulgarians, Serbs, Albanians), the term used was “assimilation” into the majority population. It is a handy analytical shortcut whenever “assimilation” as such is not the researcher’s main focus. Things get more complicated when research focuses on the “Greeks,” because they were long-term settlers who became highly visible in the socio-political and economic structures of the Principalities. “Greek” Xenopol”, 2003), 49–60; Cristian Luca, “L’importazioni di merci levantine nella Venezia del seicento e del primo settecento: la cera e i pellami provenienti dai Principati romeni”, in Cristian Luca, Gianluca Masi, and Andrea Piccardi, eds., L’Italia e L’Europa centro-orientale attraverso i secoli (Brăila – Venice: Istros, 2004), 321–61; Luca, “The Rise of the Greek ‘Conquering Merchant’ in the Trade between the Eastern Mediterranean and the Romanian Principalities in the Sixteenth and Seventeenth Centuries”, Journal of Mediterranean Studies 19 (2010): 311–34; Gheorghe Lazăr, Les marchands en Valachie, XVIIe – XVIIIe siècles (Bucharest: Institutul Cultural Român, 2006). 9 Jean D. Condurachi’s study Câteva cuvinte asupra condiţiei juridice a străinilor în Moldova şi Ţara Românească până la Regulamentul Organic (Bucharest: Editura Cultura, 1918) examines the legal status of aliens in general. See also Olga Cicanci, “Statutul social-juridic al grecilor ‘împământeniţi’ (secolele XVI – XVII)”, Cercetări de Istorie şi Civilizaţie Sud-Est Europeană 3 (1986): 114–23; Cristian Luca, “Il regime giuridico dei mercanti stranieri in Valacchia e in Moldavia nel Cinque-Seicento”, in Alberto Castaldini, ed., L’eredità di Traiano. La tradizione instituzionale romano-imperiale nella storia dello spazio romeno. Atti del Convegno Internazionale di Studi, Bucarest, Istituto Italiano di Cultura – Accademia Romena, 6–7 giugno 2007 (Bucharest: Istituto Italiano di Cultura, 2008), 195–208. 10 Constantin Şerban, “Les préliminaires de l’époque phanariote”, in Symposium “L’époque phanariote”, 21–25 octobre 1970. À la mémoire de Cléobule Tsourkas (Thessaloniki: Institute for Balkan Studies, 1974), 29–39; Eugen Stănescu, “Préphanariotes et Phanariotes dans la vision de la société roumaine des XVIIe – XVIIIe siècles”, in Symposium “L’époque phanariote”, 347–58; Constantin Rezachevici, “Fenomene de criză social-politică în Ţara Românească în veacul al XVII-lea (I): Prima jumătate a secolului al XVII-lea”, Studii şi materiale de istorie medie 9 (1978): 58–84; Rezachevici, “Fenomene de criză social-politică în Ţara Românească în veacul al XVII-lea (II): A doua jumătate a secolului al XVII-lea”, Studii şi materiale de istorie medie 14 (1996): 85–117; Andronikos Falangas, “On Greek-Romanian Antagonism during the First Half of the 17th Century”, Modern Greek Studies Yearbook 28–29 (2012–2013): 91–107. 68 The Naturalization of Greeks in the Principalities of Wallachia and Moldavia immigration into the Romanian Principalities was a long-drawn, uninterrupted process which augmented the local Greek presence constantly over the centuries, thus making the use of term “assimilation” problematic. The concept of “assimilation” short-circuits both the gradual nature of integration and the multi-faceted (juridical, fiscal, social, cultural, linguistic, etc.) processes whereby the immigrants inserted themselves in what was still, for all intents and purposes, a sovereign entity. Consequently, when referring to the “Greeks”, researchers speak of their “naturalization” [Rom. naturalizare < Fr. naturalisation] or their “putting down roots in the country’s soil”, for which they use the term împământenire, a term originating in Romanian diplomatic language from the 17th century onward.11 In historiography, both terms carry legal connotations.12 Yet, to this day, there has been no scholarly attempt at disentangling the meanings of these terms, at examining the nature of the designated object or its analytical relevance.13 What did it mean to be naturalized in the age of the South-East European prince-state,14 assuming that what then occurred may be indeed defined as naturalization? Was naturalization synonymous with the local concept of împământenire (putting down roots)? If this is not the case, what did putting down roots mean according to the views of Danubian princes and their subjects? Within the limited scope of the present small-scale study, I aim to outline the history of the two concepts and verify their analytical usefulness for an examination of the past migration and settlement of “Greeks” (and other “allogenous” populations) on the territories of Wallachia and Moldavia. This approach aims to contribute to conceptual history as applied to the Romanian space and, more generally, to South-Eastern-Europe, as Citing all the alternative usages of the two terms in the Romanian historiography would be fastidious. However, it is noteworthy that in 1896 Al. D. Xenopol favored the native term împământenire (Istoria Românilor din Dacia Traiană, t. VII, ed. I. Vlădescu, Bucharest, 19293, 98), whereas in 1918, Condurachi, Câteva cuvinte, 51, 53, 54, used naturalizare and împământenire interchangeably. 12 The term împământeniți, used by Olga Cicanci in the title of her study, cited in footnote 9 above, remains in fact an empty concept, given that the author does not define the term împamântenire and that she proposes to study the “Greeks’ legal status” once they had already “put down roots” in the principalities, as suggested by the past participle she uses, împământeniți, which designates a fait accompli. 13 See the recent study by Constantin Iordachi, Liberalism, Constitutional Nationalism, and Minorities. The Making of Romanian Citizenship, c. 1750–1918 (Leiden – Boston: Brill, 2019), 31–84, where the argument draws on older, pre–2000 secondary sources, rather than on critical examination of archival documents. 14 Term borrowed from Păun, “La circulation”, designating the state based on divine right, structured around a sovereign monarch elected “by the grace of God” and governing by devolvement of power to noble appointees. Thus, the prince-state (État-Prince) is distinct from the nation-state (État-Nation), built around the sovereignty of the people and representative government. 11 69 L i d i a C ot ovanu well as to the methodology of historical research. Historicizing concepts, positioning them within the context of their production, is a key operation if one is to choose the most appropriate analytical tools for socio-historical research.15 The “Greeks” collective denominator should itself be examined semantically for differences in its meanings during the periods prior to the foundation of South-East European nation-states, as opposed to the implications assigned by contemporary historians. However, this is a topic which deserves a full-scale investigation on its own.16 Within the brief space available to me in the present study, I simply wish to underscore that, in the period considered here, the term Greek (Rom. grec, corresponding to Gr. Ρωμαίος / Ρωμιός) designated any Greek-speaking resident of the Romanian Principalities who had migrated from a Greek-speaking area, i.e. from “the Greek Land” (Ţara Grecească) or from “Rumelia” (Rumelia, Rumeli), as these regions were called in the contemporary documents. These areas were under the church jurisdiction of the Patriarchate of Constantinople. As a collective term, “Greeks” semantically covered both Orthodox populations speaking only Greek and those who spoke Greek in addition to their own native language (Albanians, Aromanians, Slavs, etc). It all depended on the individual performing the act of identification, background knowledge and expectations, on the interests they defended and degree of closeness to the power circles. If the individual came from the “Greek Land”, classification also depended on their interest to publicize or obscure their self-perceived “Greekness”. 15 James Tully, ed., Meaning and Context: Quentin Skinner and his Critics (Cambridge: Polity Press, 1988); Iain Hampsher-Monk, Kaiun Tilmans, and Frank Van Vree, History of Concepts: Comparative Perspectives (Amsterdam: Amsterdam University Press, 1998); Reinhart Koselleck, “Histoire sociale et histoire des concepts”, in Koselleck, L’expérience de l’histoire, ed. Michael Werner, translated from German by Alexandre Escudier (Paris: EHESS, 1997), 101–19; Koselleck, The Practice of Conceptual History: Timing History, Spacing Concepts (Stanford: Stanford University Press, 2002). From among the few studies on conceptual history published in Romania, see Sorin Mitu, ed., Re-searching the Nation: The Romanian File: studies and selected bibliography on (Cluj: International Book Access, 2008); Victor Neumann, and Armin Heinen, eds., Key Concepts of Romanian History. Alternative Approaches to Socio-Political Languages (Budapest – New-York: Central European University Press, 2013). 16 On this topic, I take the liberty of referring readers to my own studies: Cotovanu, Migrations, Part Two; Cotovanu, “Chasing away the Greeks”, passim; Cotovanu, “Οι πολλαπλές αναπαραστάσεις των “Ρωμαίων” / “Γραικών” στις Παραδουνάβιες Ηγεμονίες: η μαρτυρία του Ματθαίου Μυρέων (αρχές του 17ου αιώνα)”, in Οlga Katsiardi-Hering et al., eds., Έλλην, Ρωμηός, Γραικός: Συλλογικοί προσδιορισμοί και ταυτότητες (Athens: Evrasia, 2018), 413–29. 70 The Naturalization of Greeks in the Principalities of Wallachia and Moldavia Naturalization, a Term Originating in the French Code de la nationalité The term naturalization, as applied in South-East-European historiographies, including the Romanian historical discourse, is drawn from the terminology of the Droit français de la nationalité, which emerged from the French Revolution. With the introduction of the Nation souveraine concept, designating a self-governing nation with a representative government, the pressing need arose for defining the specific features of the Nation, the limits of its sovereignty and criteria for belonging to it. As far as individuals were concerned, it was essential to establish who belonged to the Nation and, for those who did not, what requirements they needed to meet in order to be accepted into national membership. This was the start of a lengthy process of reflection and ideological and legal construction of the Nation, which involved defining the criteria and norms for attaining membership within the national community. The outcomes of this theoretical project, which lasted well into the 20th century, were, on the one hand, the Constitution de la République, which prescribed the fundamental features of the sovereign Nation, and, on the other, the Code de la nationalité, which established the norms for acceptance into and integration of and within the Nation. The Nation was defined as the embodiment of a community of people, endowed with the fundamental right of governing itself. Defined as such, the Nation is cohesive and indivisible and is equipped with a State, which takes decisions and acts on its behalf. It has a territory which circumscribes its political constituency, historical heritage and sites of communal life, it has a language and culture of its own, as well as a set of symbols and rituals designed to reinforce the citizens’ allegiance to its unitary and culturally homogeneous body. Once the characteristics of the Nation and the criteria for national membership had been defined, means had to be found for encouraging its members to want to live together, to respond to the principle of national solidarity and to the state’s calls for patriotic defense, and, if necessary, for the ultimate sacrifice in defending the national territory, institutions and values. To this effect, the political-legal, linguistic and cultural concept of the Nation was supplemented by an additional notion based on the family model and its genealogical structure. According to this view, the national community of language and, more generally, culture, is also a community of common origins and common blood. In this way, a sense of national belonging as created by a unique language and culture was reinforced by a concept of the nation as a natural, hereditary community originating in common ancestors. In association with the State representing it and its 71 L i d i a C ot ovanu territory, the Nation is thus perceived as the mère-patrie (the motherland), its language is la langue maternelle, the mother tongue of its members who in turn perceive themselves as brothers (conscription and wars disseminated and reinforced this self-perception). This makes the Nation a closed structure with an exclusionary system of national belonging. This means that the members of the Nation have only one official collective affiliation which they possess by virtue of their filiation, their descent from the national body, devised, as we have seen, as a community which is political as well as cultural. Thus, in its twin dimension, national belonging is a fact of nature, an innate – and as such inescapable – characteristic. And, while it cannot be discarded at will, it also cannot be acquired without genealogical justification such as adoption, with reference to the foreigner’s acculturation and his or her willingness to live in his or her “adoptive” country.17 However, the organicist view of the Nation is merely an ideological construct which only binds individuals to their borders in the abstract and only if the individuals themselves adhere voluntarily to that ideology and are willing to pay the ultimate price if called for. This adherence is put to the test on a large scale in the context of wars waged on behalf of the Motherland-Nation against an enemy presented and perceived as a figure of unmediated “otherness”. But the individual’s will may falter and may not be enough to ensure the continuity of a shared national sentiment, the stability of national frontiers and territorial integrity; to put it shortly, it may not be enough to guarantee the survival of the State itself. In order to fix the Nation’s abstract frontiers in people’s minds and thus ensure its For the organicist conception of the Nation, including the French nation, see Gil Delannoi, and Pierre-André Taguieff, eds., Théories du nationalisme (Paris: Kimé, 1991); Joël Roman, Introduction in Ernest Renan, Qu’est-ce qu’une nation? et autres essais politiques, ed. Joël Roman (Paris: Presses Pocket, 1992), 32–3; Étienne Balibar, and Immanuel Wallerstein, Race, nation, classe. Les identités ambiguës (Paris: La Découverte, 1997); Gil Delannoi, Sociologie de la nation. Fondements théoriques et expériences historiques (Paris: Armand Colin, 1999); Anne-Marie Thiesse, La création des identités nationales. Europe XVIIIe – XXe siècles (Paris: Seuil, 20012); Thiesse, Faire les Français. Quelle identité nationale? (Paris: Stock, 2010), 22–4, 27–34; Anthony D. Smith, Naţionalism şi Modernism. Un studiu critic al teoriilor recente cu privire la naţiune şi naţionalism, trans. Diana Stanciu [Nationalism and Modernism: A Critical Survey of Recent Theories of Nations and Nationalism (London – New York, 1998)] (Chişinău: Epigraf, 2002), 136; Dominique Schnapper, La communauté des citoyens. Sur l’idée moderne de la nation (Paris: Gallimard, 20032), 18–9, 165–222; Patrick Weil, Qu’est-ce qu’un Français? Histoire de la nationalité française depuis la Révolution (Paris: Gallimard, 20044), Parts Two and Three; Fabrice Patez, “La nation moderne ou la souveraineté ethno-démocratique”, available online at http://halshs.archives-ouvertes.fr/halshs-00010213 (accessed 10.10.2013); Michael Herzfeld, L’intimité culturelle. Poétique sociale de l’État-nation (Laval: Laval University Press, 2007), 129–45; Hélène Bertheleu, “Sens et usages de ‘l’ethnicisation’”, Revue Européenne des Migrations Internationales 23, no. 2 (2007): 12–4, available online at http://remi. revues.org/4167 (accessed 02.02.2012). 17 72 The Naturalization of Greeks in the Principalities of Wallachia and Moldavia survival, the State had to “find the juridical tools which not only ascribe nationality but help its transmission from one generation to the next”.18 In its currently accepted definition, legal nationality is, as Patrick Weil argued, “le lien qui relie par le droit un État à sa population constitutive” or, in other words, “le lien juridique et politique qui rattache un individu à un État souverain”.19 The population, as embedded in the State, is the Nation’s social body, conceived as a political and cultural community organically forged to withstand time. The individual is bound to the State by virtue of his or her membership of the sovereign Nation. The Droit de la nationalité establishes the membership criteria within a national body characterized by a set of culturally specific features, language being its core emblem (in this context, the sovereign State is simply the organ of power which acts on behalf of a legally constituted Nation, and it does so through the voice of citizens entitled to universal suffrage).20 National belonging is regulated and validated by the norms of the Code de la nationalité, specifically designed to “attach the individual to the sovereign State”. The State, therefore, assumed the powers of assigning an official individual identity to each of the Nation’s members via law and bureaucratic procedures, in addition to his or her unique linguistic/cultural affiliations acquired via sociological integration within the family and the national education and administrative systems.21 Throughout the 20th century, the creation of a personal identification system based on identity papers and its application across the entire national body imparted materiality to individuals’ national affiliation, thereby guaranteeing the organic and bureaucratic reproduction of the national body. Weil, Qu’est-ce qu’un Français?, 13. Weil, Qu’est-ce qu’un Français?, 13; Trésor de la Langue Française informatisé, available online at http://atilf.atilf.fr/tlf.htm, entry “nationalité”. 20 Nationality, which designates membership of the political and cultural nation, is not to be confused with citizenship, which designates access to civic rights (the right to vote and to be elected), although, with the generalization of universal suffrage in the majority of today’s nation-states, the application of the two principles is currently more or less overlapping. One must, therefore, be a national before becoming a citizen: Gérard Noiriel, “Sociohistoire d’un concept. Les usages du mot ‘nationalité’ au XIXe siècle”, Genèse 20 (1995), 4–23; Weil, Qu’est-ce qu’un Français?, 18; Thiesse, Faire les Français, 10. 21 Effectively, the register of sociological integration (intégration sociologique) and that of juridical integration (intégration juridique) of/ to the Nation are not to be confused (Dominique Schnapper, Qu’est-ce que l’intégration? (Paris: Gallimard, 2007). However, there is some overlapping, to the extent that juridical integration is managed in such a way as to guarantee efficacy of sociological integration and enshrine the outcomes in law. Some states included among the access criteria to nationality via naturalization the command of the official language and a minimal knowledge of the national history, culture, institutions and values: Weil, Qu’est-ce qu’un Français?, 13–4; Abdellali Hajat, “La barrière de la langue. Naissance de la condition d’assimilation linguistique pour la naturalisation”, in Didier Fassin, ed., Les nouvelles frontières de la société française (Paris: La Découverte, 20122), 53–77. 18 19 73 L i d i a C ot ovanu The legal tools used to assign nationality and ensure its transmission across generations are in perfect accord with the organic character inherent to the sovereign Nation itself. Here they are, in order of their effectiveness: – the jus soli or place of birth (the fact of having been born on a territory over which the national State is exercising, has exercised or intends to exercise its sovereignty); – the jus sanguinis or line of descent (Fr. filiation) (nationality transmitted via a parent or a more remote ancestor); – past, present or future residence within the past, present and future borders of the national State; – marital status (marrying a resident of a foreign State in order to acquire the nationality of the spouse).22 The use of these four legal tools spread out from the Code de la nationalité français, which had adopted them in the 19th century (jus sanguinis in 1803 and jus soli in 1889),23 across the rest of the Nation-States, every one of which selected and combined the features which best served their demographic, economic and foreign policies, as well as their other interests.24 However, whichever strategy was chosen, the ultimate outcome aimed at “nationalizing” individuals (both locals and immigrants) according to the organicist logic modeled on the family metaphor and kinship structures, either biologically or fictionally constructed: – through birth 1) on the national territory and 2) from a parent or forebear recognized as being a member of the national body; both of these criteria ensured the child’s sociolinguistic and cultural integration within the Nation during the early stages of his or her socialization;25 Weil, Qu’est-ce qu’un Français?, 13. The rules for determining French nationality, previously included in the Code de la nationalité, were transferred to the Code civil after 1993: https://www.senat.fr/rap/l99–132/ l99–1321.html (accessed 22.07.2019). 24 Patrick Weil has argued that France had known the jus sanguinis since the late 16th century, as applied to the king’s subjects who could have different languages and cultures; it was also France where the modern concept of jus sanguinis was invented, namely with regard to members of a sovereign Nation which was linguistically and culturally homogeneous. The Code civil napoléonien was an inspiration for the German legislative system, which accepted the jus sanguinis in 1841 and used it until 1998, when it was supplemented by the jus soli: Patrick Weil, “Nationalities and Citizenships: The Lessons of the French Experience for Germany and Europe”, in David Cesarani, and Mary Fulbrook, eds., Citizenship, Nationality & Migration in Europe (London: Routledge, 1996); Weil, “L’accès à la citoyenneté: une comparaison de vingt-cinq lois sur la nationalité”, in Nationalité et citoyenneté, nouvelle donne d’un espace européen. Travaux du centre d’études et de prévision du Ministère de l’Intérieur, May 2002, no. 5, 9–28; Weil, “Citoyenneté et nationalité à l’épreuve de la construction européenne”, in Nationalité et citoyenneté, 175–89; Weil, Qu’est-ce qu’un Français?, passim. 25 To quote Françoise Masure, “Des Français paradoxaux. L’expérience de la naturalisation des enfants de l’immigration maghrébine”, in Fassin, Les nouvelles frontières, 584–8, the 22 23 74 The Naturalization of Greeks in the Principalities of Wallachia and Moldavia – within the family, via 1) marriage to a national, and after a legally prescribed period of communal life, aimed at integrating the non-native spouse within the national sociocultural community, or 2) adoption of a foreign child by a family of nationals, which acts as a medium of national integration. – through naturalization, in the sense that a foreigner is accepted into the national body as if born there and belonging naturally within it by virtue of having complied with the mandatory residence period designed to ensure his/her sociocultural integration within the Nation. This is the background to the construction of the legal fiction of naturalization, a procedure aiming to nationalize the alien after the required period of legal residence on national soil, a period which supposedly brought him or her closer to the status of native. The Code civil français, still in use today, has retained the term “naturalisation” (§ 5, Art. 21.15 – 21.25).26 Once it adopted the political template of the Nation-State, modern Romania – issued from the Union of the Principalities of Wallachia and Moldavia (1859), with the subsequent addition of Transylvania, Bukovina, and Bessarabia to its territory (1918) – also adopted the model of the French Droit de la nationalité, which was incorporated into the Romanian Constitution and remained in force until 1924.27 The legislation was gradually adapted to local political realities and choices as new social categories were added to the national body and new territories came within Romanian jurisdiction.28 The borrowing interview conducted for the naturalization procedure “must establish that naturalization only applies to the ‘already French’”, and that the applicants were to be advised to change their name or adapt it to the usage of the Nation they wished to join”. 26 Available online at: https://www.legifrance.gouv.fr/affichCode.do;jsessionid=C1B6DBE FCBE7375811664D9432E1890A.tpl gfr32s_2?idSectionTA=LEGISCTA000006165459&cidTe xte=LEGITEXT000006070721&dateTexte=2019072 (accessed 22.07.2019). 27 Pompiliu Eliade, De l’influence française sur l’esprit public en Roumanie. Les origines. Étude sur l’état de la société roumaine à l’époque des règnes phanariotes (Paris: Ernest Leroux, 1982); Alexandre Tilman-Timon, Les influences étrangères sur le droit constitutionnel roumain (Bucharest: Librairie du Recueil Sirey, 1946). See also Ioan Stanomir, Nașterea Constituției. Limbaj și drept în Principate până la 1866 (Bucharest: Nemira, 2004); Radu Carp, “Influența Codului civil francez: sistemul de drept românesc în context comparat”, in Florin Țurcanu, ed., Modèle français et expériences de la modernisation. Roumanie, XIXe – XXe siècles (Bucharest: Institutul Cultural Român, 2006); Manuel Guțan, Transplant constituțional și constituționalism în România modernă, 1802–1866 (Bucharest: Hamangiu, 2013); Guțan, “The Legal Transplant and Building of the Romanian Legal Identity in the Second Half of the 19th Century and the Beginning of the 20th Century”, Romanian Journal of Comparative Law 18, no. 1 (2017): 62–99. 28 For the processes of adoption and adaptation of the French Droit de la nationalité in Romania see, more recently, Dietmar Müller, “Cetățenie și națiune, 1878–1882. Evreii ca alteritate în dezbaterea cu privire la articolul 7 din Constituție”, in Venera Achim, and Viorel Achim, eds., Minoritățile etnice în România în secolul al XIX-lea (Bucharest: Editura Academiei Române, 2010), 201–26; Liviu Neagoe, Cetățenie, națiune și etnicitate. O perspectivă comparată (Cluj-Napoca: Avalon, 2014); Neagoe, Antisemitism și emancipare în secolul al 75 L i d i a C ot ovanu – or transplant29 – of foreign models and principles was accompanied by adaptation of the juridical vocabulary to the new national ethos. The earliest Romanian Constitutions employed the customary terms pământenie and împământenire (putting down roots) and the neologisms cetățenie (citizenship), naționalitate (nationality), and naturalizare (naturalization) interchangeably as synonyms to designate citizenship or nationality – terms applied to the embedding of the national or nationalized individual within the State – and naturalization as legal fiction and bureaucratic act of national integration (act de naturalitate / 1859).30 In 1924, the Romanian Nationality Law (Legea Naţionalităţii Române) was voted and incorporated into the Civil Code (Codul civil).31 The ancient term împământenire (putting down roots) disappeared from the text of the new law – once the right of all citizens to landed property was established – to be supplanted by the French-derived term naturalizare.32 After 1948, the latter was to be used in competition with încetățenire (citizenship attribution)33 and, after 1991, with acordare la cerere (granting of citizenship on demand),34 still in force today. It is noteworthy that the term naturalization did not enjoy a long career in the Romanian legal language. Presumably, it entered the Romanian historiographic vocabulary from French-language studies in medieval and early modern history: one must remember that, starting from the 19th century and throughout the 20th century, French was the hegemonic language in South-East European medieval studies. To this date, it remains the official language of the Association Internationale d’Études Sud-Est Européennes. To conclude, the term naturalization, created because of the need to nationalize foreign nationals who settled within the sovereign space of the nation-state, and still in use today as such, has no connection to XIX-lea. Dileme etnice și controverse constituționale în istoria evreilor din România (Bucharest: HASEFER, 2016); Constantin Iordachi, Citizenship, Nation and State-Building: The Integration of Northern Dobrogea into Romania, 1878–1913 (Pittsburgh: University of Pittsburgh Press, 2002); Iordachi, Liberalism, 85. 29 A term employed by Guțan, Transplant constituțional, passim. 30 Neagoe, Cetăţenie, 79–121, with a bibliography. 31 Dimitrie G. Maxim, Naturalizarea în România după Constituțiune și Noua Lege a Naționalităței (Bucharest: Socec, 1925), 242; Neagoe, Cetăţenie, 233–6, 238. 32 The term naturalization is still present in the text of the 1938 Constitution, Ch. II, Art. 11: http://legislatie.resurse-pentru-democratie.org/constitutie/constitutiunea-din–1938.php (accessed 25.07.2019). 33 Decree no. 25, 7 July 1948, Section II, Art. 10: http://www.monitoruljuridic.ro/act/decretnr–125-din–7-iulie–1948-pentru-cetatenia-romana-emitent-marea-adunare-nationala-publicat-n-monitorul–37721.html (accessed 25.07.2019). 34 Romanian Nationality Law no. 21/1991, Ch. II (Acquisition of Romanian citizenship), Art. 8 (On demand), and Ch. III (Procedure for the attribution of Romanian citizenship): http://legislatie.just.ro/Public/DetaliiDocument/121439 (accessed 15.09.2019). 76 The Naturalization of Greeks in the Principalities of Wallachia and Moldavia realities preceding the emergence of nation-states around 1789. The term, in its nationalizing meaning, belongs to the contemporary “world-system” (I. Wallerstein). Naturalization during the French Ancien Régime The term naturalization was not an absolute novelty in the 19th century. The Droit de la nationalité français borrowed it from the juridical glossary of the Ancien Régime, adapting it to refer to the body of the nation, as an entity endowed with political rights.35 As I have argued earlier, in the context of the nation-state, the legal fiction of naturalization serves to integrate the foreigner into the national body as if born there, i.e. as if born on national soil (according to jus soli) or as if born of parents who are nationals (according to jus sanguinis). Undoubtedly, it was not from the legal vocabulary of the Ancien Régime that Romanian historians borrowed the term naturalization. Rather, they borrowed it from the contemporary language of the nation. However, it might be methodologically instructive to examine the term’s old semantic connotations in order to see whether the institutional realities it covered had any correspondence in Wallachia and Moldavia in the period considered here. The ancient legal fiction of naturalization is directly connected to the application of the Roman law-inspired jus soli to the establishment of the political link between individuals and the State or King. It is by virtue of this right that, as early as the 14th – 15th century, the kings of France granted so-called lettres de bourgeoisie (letters granting burgher rights) to foreign subjects, which in effect amounted to a “veritable act of naturalization”.36 From that period onwards, in competition with feudal lords, the king asserted his sovereignty by making the jus soli a pre-condition to acquiring rights of inheritance, both for those bequeathing their assets and the recipients. This meant that, in order to inherit or be able to transmit one’s assets, one had to be born in the Kingdom and have legitimate heirs, i.e. children born on the Kingdom’s territory. If these conditions were not met, the king used a right which in French juridical language came to be known as droit d’aubaine (escheat), which practically meant that the monarch could confiscate the assets of the deceased foreigners who had no children born in the Kingdom. This condition forced foreigners to apply to the king for lettres de naturalité, which effectively placed the beneficiaries Bernard D’Alteroche, “Les origines médiévales de la naturalisation”, in Marie-Claude Blanc-Chaléard, Stéphane Dufoix, and Patrick Weil, eds., L’étranger en question du Moyen Âge à l’an 2000 (Paris: Le Manuscrit, 2005), 17–42. 36 Bernard D’Alteroche, “L’évolution de la notion et du statut juridique de l’étranger à la fin du Moyen Âge (XIe – XVe siècle)”, Revue du Nord, 2, nos. 345–346 (2002), 232; D’Alteroche, “Les origines médiévales”, 20, 21, 22. 35 77 L i d i a C ot ovanu under royal jurisdiction and thereby transformed them into subjects of the king, as if born in the Kingdom.37 From the 14th century onwards, the foreigner was no longer defined in relation to towns or feudal lords, but in relation to the Kingdom. That was precisely the time when the lettres de naturalité were introduced and gradually started supplanting the lettres de bourgeoisie. “Naturalization no longer ties the beneficiary to a town, but exclusively to the Kingdom”.38 This shift lifted limitations on testamentary rights and impediments to inheritance from deceased foreigners who had no children born on the territory of the Kingdom. Thus, the 16th century witnessed the generalization of the principle according to which the status of the foreigner was defined in relation to the Kingdom and was subjected to a common legal system: in principle, all individuals born outside the French territory had to obtain a lettre de naturalité if they wanted to make a bequest to collateral kin living in France and avoid confiscation of their assets by the king if they had no heirs born in the Kingdom.39 The definition of the foreigner as someone born outside the Kingdom and the introduction of the lettres de naturalité produced, as if in a mirror image, the definition of the sujet du Roi and defined the pathways to the acquisition of this status through the jus soli: from early 14th century, all persons born on French territory were considered rightful subjects of the King (régnicoles).40 37 Marguerite Boulet Sautel, “L’aubain dans la France coutumière”, in L’Étranger. Recueils de la Société Jean Bodin, t. X (Paris: Librairie encyclopédique, 1958), 65–100; Michel Reulos, “Les aubains”, in Marie-Thérèse Jones-Davies, ed., “L’étranger: identité et altérité au temps de la Renaissance”. Actes des Colloques des 8–9 décembre 1995 et 15–16 mars 1996 (Paris: Klincksieck, 1996), 29–35; Caroline Javanaud, “Le statut de l’étranger dans le Royaume de France, du Moyen-Âge à la Révolution”, in Regards sur le droit des étrangers (Toulouse: Toulouse University Press, 2010), 17–30; Bernard D’Alteroche, De l’étranger à la Seigneurie à l’étranger au Royaume, XIe – XVe siècle (Paris: LGDJ, 2002), passim. 38 D’Alteroche, “L’évolution”, 234, citing, for the lettres de naturalité granted from the 16th to the 18th century, Jacques Boizet, Les lettres de naturalité sous l’Ancien Régime (Paris: Maurice Lavergne, 1948); Jean-François Dubost, “Significations de la lettre de naturalité dans la France des XVIe et XVIIe siècles”, EUI Working papers 90, no. 3 (1990): 1–37; Françoise Mighaud-Fréjaville, “Être naturalisé dans la vallée de la Loire (1450–1501)”, AnnuaireBulletin de la Société de l’histoire de France (2011): 3–13. For more recent publications on the topic, see Jean-François Dubost, and Peter Sahlins, Et si on faisait payer les étrangers? Louis XIV, les immigrés et quelques autres (Paris: Flammarion, 1999); Peter Sahlins, “La nationalité avant la lettre. Les pratiques de naturalisation en France sous l’Ancien Régime”, Annales. Histoire Sciences Sociales 55, no. 5 (2000): 1081–108; Sahlins, Unnaturally French: Foreign Citizens in the Old Regime and After (Ithaca – London: Cornell University Press, 2004); see also D’Alteroche, De l’étranger, passim; D’Alteroche, “Les origines médiévales”, 33–40. 39 D’Alteroche, “L’évolution”, 239–45. 40 Sahlins, Unnaturally French. On the jus soli as an innovation of medieval jurists, see D’Alteroche, “Les origines médiévales”, 26–33. 78 The Naturalization of Greeks in the Principalities of Wallachia and Moldavia In practice, the lettres de naturalité were sought by rich foreigners who had vast patrimonial assets to bequeath or by merchants who handled large amounts of capital and large quantities of goods: “the application for letters appears to be the exception rather than the rule”.41 Nevertheless, such legal procedures led to the emergence of specific legislation concerning naturalization and a system of legal ‘production’ of the Français, to be monitored by the State.42 Consequently, in the Kingdom of France, naturel and naturalisation were legal categories operating in the narrow succession rights area for foreigners (chiefly, rich ones), as conditioned by the jus soli. In its ancient meaning, naturalization produced natural subjects of the King (sujets naturels du Roi), so that these foreigners could enjoy rights as testators and inheritors, as if born in the Kingdom. After 1789, however, the scope of naturalization changed: it now produced national citizens (citoyens nationaux), as if born on national territory or from parents who were nationals. Putting Down Roots in the Country’s Soil In light of the observations above, it is easier to estimate the analytical relevance of the term naturalization for the study of the “foreigners’” political-legal integration in the Principalities of Wallachia and Moldavia, which, as historians of Romania’s ancient law unanimously agree,43 lacked the droit d’aubaine. However, historians have missed the fact that, in the absence of the droit d’aubaine, in the Principalities, succession rights were not conditioned by the jus soli, i.e., by the requirement to have been born on the country’s territory. Wallachian and Moldavian sources on inheritance norms and practices show that in the two Principalities both local subjects and subjects of foreign powers enjoyed the right to inherit, provided that the latter were of the Orthodox faith, as required by local custom. Published in 1652, the Wallachian Law Code stipulated that possible A nuance added by Simona Cerutti, “À qui appartiennent les biens qui n’appartiennent à personne? Citoyenneté et droit d’aubaine à l’époque moderne”, Annales. Histoire Sciences Sociales 62, no. 2 (2007): 361 and passim; Cerutti, “Le droit d’aubaine et la construction des ‘étrangers’ à l’époque moderne (État savoyard, XVIIIe siècle)”, in Bruno Lemesle, and Michel Nassiet, eds., Valeurs et Justice. Écarts et proximités entre société et monde judiciaire du Moyen Âge au XVIIIe siècle (Rennes: Rennes University Press, 2011), 159–76. The study also shows that under the Ancien Régime, the state did not have a monopoly on the political and legal integration of foreigners. Professional corporations and local communities also played an important role in this process. On this topic see also Cerutti, Étrangers. Étude d’une condition d’incertitude dans une société d’Ancien Régime (Paris: Bayard, 2012). 42 Peter Sahlins, “Sur la citoyenneté et le droit d’aubaine à l’époque moderne. Réponse à Simona Cerutti”, Annales. Histoire Sciences Sociales 63, no. 2 (2008): 383–98. 43 See, more recently, Iordachi, Liberalism, 37. 41 79 L i d i a C ot ovanu heirs, even those residing abroad, could claim their inheritance within a period of thirty years after someone’s death. It was only when no claimants came forward that the estate of the deceased was “inherited” by the sovereign, i.e., it became public domain.44 For example, the estate of Ceacârlo “the Greek” from Moldavia, who died without issue, remained unclaimed by inheritors for twenty-five years after his death.45 Usually, the monarch gave these vacant goods (bona vacantia) to subjects and allies as a reward for loyal service or donated them to local religious institutions. Ceacârlo’s estate was donated to another foreign-born subject, the customs tax collector (Rom. vameş) Condrea, for services rendered to the monarch.46 It is worth emphasizing that in the Principalities, the right to inherit did not overlap with usufruct, i.e. the right to enjoy full ownership of the inherited assets. Contrary to practices in old-regime France (see above), it was not the right of inheritance, but the right of ownership which was subjected to conditions and limitations of access. In addition, access was determined not by the jus soli, i.e., by birth in the country, but, on the one hand, by confession – one had to be Eastern Orthodox – and, on the other, by permanent residence in the country.47 These two criteria – faith and residence/domicile – in fact yielded two categories of foreigners: a) internal (Armenians, Jews, Catholics),48 subjects of the monarch who paid taxes according to the Îndreptarea legii (1652), critical edition (Bucharest: Editura Academiei Române, 1962), Glava (chapter) 280, 273. 45 Documente privind Istoria României, Serie A, Moldova [henceforth: DIR, A], t. XVII/3 (1616– 1620) (Bucharest: Editura Academiei Române, 1956), no. 313, 255–6 (30 March 1618). 46 DIR, A, t. XVII/3 (1616–1620), no. 313, 255–6 (30 March 1618). Condrea colonized the village he received as a gift with “foreign” settlers: DIR, A, t. XVII/4 (Bucharest: Editura Academiei Române, 1956), no. 315, 257–258 (1 April 1618), no. 378, 307 (18 January 1619). 47 Pace Mustafa A. Mehmet, who argues the following in “Despre dreptul de proprietate al supuşilor otomani în Moldova şi Ţara Românească în secolele XV – XVIII”, Cercetări istorice, new series, 3 (1972): 78: “Non-Muslim Ottoman subjects habitually enjoyed rights of possession of properties, including building plots, shops and other assets in villages and towns, a fact confirmed by ancient and more recent sources”. In his turn, Iordachi, in Liberalism, 37, 38, argues, erroneously, that land ownership was the preserve of nobles (“but lacked the right to buy landed estates, a privilege that was reserved for the nobility”; “the only limitations concerned the acquisition of land, since this played an important role in granting nobility status”). It is true that noble status was partly founded on land ownership, but this right was not reserved exclusively for nobles. There were many merchants and free peasants in the Principalities who enjoyed full ownership of land; any foreigner had the right to purchase land, provided that he was of the Orthodox faith, was a freeman and resided in the country permanently. For the merchant class and its relation to land ownership, see Gheorghe Lazăr, “De la boutique à la terre”, 51–67. 48 For the legal status of Armenians, Jews, and Catholics in the Principalities, see Şerban Papacostea, “Jews in the Romanian Principalities during the Middle Ages”, Shvut 16 (1992): 59–72; Petre Ş. Năsturel, “L’attitude du Patriarcat œcuménique envers les Arméniens des Pays roumains (fin XIVe siècle – début XVIe siècle”, in Năsturel, Études d’histoire byzantine et post-byzantine, eds. Emanuel Costantin Antoche, Lidia Cotovanu, and Ionuţ-Alexandru 44 80 The Naturalization of Greeks in the Principalities of Wallachia and Moldavia religious corporation they belonged to, and b) external, politically dependent on another state (such as Ottoman, Hungarian, Polish, Venetian, French subjects etc.), who were passing through or residing temporarily in the Principalities. It was not, therefore, enough to have inherited in order to own land or other immovable assets; to exercise ownership, one had to share the state’s official religion and permanently reside on the Wallachian or Moldavian soil. As an example, let me mention the case of treasurer Penişoară from Ioannina in Epirus, a dignitary in the service of the ruling Prince Vasile Lupu (r. 1634–1653); he died in Moldavia without issue. It was his sister, Alexandra, who travelled from Ioannina to claim his landed property. However, as soon as she came in possession of the estate, she had to sell it before returning to Ioannina, where she resided permanently.49 This shows that, because she was not a resident of Moldavia, she had to sell the goods inherited from her brother. A similar example is that of Chirco, wife of the late Proca cămăraş (manager of the ruling prince’s treasury), who acted in agreement with her daughter Beca and her son-in-law Gheorghe Saulea. They had inherited a section of the village Aluniş, which was the landed property of cămăraş Proca, but, because they were “foreigners from another country, from Rumelia” (fiind ei striini, de altă ţară, de la Rumele), they had to sell it, and ultimately, they sold it to the country’s ruling prince himself, Constantin Brâncoveanu.50 There is an abundance of such cases in the archival sources. It is precisely this condition of acquiring access to landed property – permanent residence – which gives us a clue as to what împământenire was: a pathway to the foreigner’s integration into the sovereign space of Wallachia or Moldavia by becoming a protected subject of the local ruling prince. It is therefore a subject’s relation to the land which determined his/her legal status and access to such status. The requirement was to settle permanently “on the country’s soil” (în pământul ţării). Hence the Tudorie (Brăila: Istros, 2019): 429–41; Violeta Barbu, “Dreptul de protectorat al puterii seculare asupra misionarilor şi comunităţilor catolice din Ţările Române în secolul al XVII-lea (I)”, Studii şi materiale de istorie medie 25 (2007): 135–58; Barbu, “Dreptul de protectorat al puterii seculare asupra misionarilor şi comunităţilor catolice din Ţările Române în secolul al XVII-lea (II), Studii şi materiale de istorie medie 26 (2008): 69–89; Iordachi, Liberalism, 39–41. 49 Documenta Romaniae Historica, A, Moldova [henceforth: DRH, A], XXVII (1643–1644), eds. Nestor Ciocan et al. (Bucharest: Editura Academiei Române, 2004), no. 251, 230 (<post 28 February 1644>), no. 397, 381 (12 August 1644). 50 Condica Marii Logofeţii (1692–1714), ed. Melentina Bâzgan (Bucharest: Paralela 45, 2009), no. 56, 71–2 (June 1696). Constantin Brâncoveanu, in his turn, offered the donated estate to the Monastery of Hurezu, which he had founded: Biblioteca Academiei Române, Documente istorice (The Romanian Academy Library, Historical Documents Coll.), CMLXXX/67 (1 June 1696). 81 L i d i a C ot ovanu etymology of the term împământenire (< Rom. pământ, land, soil), still used in the 19th and early 20th century to designate the pathway to politicaljuridical integration within the Romanian sovereign space. Except for the Muslims – for reasons I shall not dwell on here51 –, all foreign subjects who resided permanently in Wallachia and Moldavia became subjects of the local ruling prince and, as such, were granted the right to purchase land, as well as political and civil rights. In his recent study on the formation of Romanian modern and contemporary citizenship, Constantin Iordachi makes an error when translating the term “pământean” as “native” and including in the category of pământeni “all the Principalities’ local inhabitants who were born on their territory or who obtained naturalisation” – all the more so as he does not explain what “naturalization” means in the Romanian Ancien Régime.52 The term “pământean” did not imply birth on the Wallachian/Moldavian soil either in the political discourse of NorthDanubian elites before 1750 (which is the terminus post quem in Iordachi’s study) or the legal norms which defined the ties between local subjects and their prince-state. Permanent residence in the Principalities and loyalty to the sovereign were the only criteria for becoming “pământean”, i.e., a subject enjoying civil and political capacities to various degrees, which depended on religion and personal freedom. Above all, one should not confuse the following phenomena: 1) the political discourse of exclusion targeting competitors – more specifically, the “Ottoman Greeks” – on the basis of their foreign birthplace (venetici);53 2) the legal connection between the prince-state and its subjects, as determined by permanent residence on the country’s territory; 3) the civil and political capacities resulting from one’s status as a political subject; 4) the management of persons’ movements across the borders, which required a high degree of political autonomy (this was not the case in the Principalities, compared to Russia, for On the legal status of Muslims in the Romanian Principalities, see Condurachi, Câteva cuvinte, 76–96; Ioan-Radu Mircea, “Sur les circonstances dans lesquelles les Turcs sont restés en Valachie jusqu’au début du XVIIe siècle”, Revue des études sud-est européennes 5, nos. 1–2 (1967): 77–86; Mehmet, “Despre dreptul de proprietate”, 65–81; Valentin Al. Georgescu, and Petre Strihan, Judecata domnească în Ţara Românească şi Moldova (1611–1831), Part One: Organizarea judecătorească, t. I (1611–1740) (Bucharest: Editura Academiei Române, 1979), 57–61; Georgescu, and Strihan, Judecata domnească în Ţara Românească şi Moldova (1611– 1831), Part One: Organizarea judecătorească, t. II (1611–1831) (Bucharest: Editura Academiei Române, 1981), 53–8; Maria Matilda Alexandrescu-Dersca Bulgaru, “Sur le mariage entre les Turcs ottomans et les Roumains (XVIe – XIXe siècles)”, Recherches sur l’histoire des institutions et du droit 6 (1981): 15–7; Alexandrescu-Dersca Bulgaru, “Sur le régime des ressortissants ottomans en Moldavie (1711–1829)”, in Alexandrescu-Dersca Bulgaru, Seldjoukides, Ottomans et l’espace roumain, ed. Cristina Feneşan (Istanbul: Isis, 2006), 439–80. 52 Iordachi, Liberalism, 31–84, and, for the quote, 34. 53 Iordachi, Liberalism, 34. 51 82 The Naturalization of Greeks in the Principalities of Wallachia and Moldavia example). As I have argued elsewhere,54 despite the “anti-Greek” political discourse, the sultan’s Christian subjects loyal to Constantinople could not be blocked from political and legal integration or from participating in the power structures of the two Principalities until well into the 19th century. However, the right to permanent residence on the country’s territory, from which, in theory, only Muslims were excluded, came at a price: it entailed several obligations for the grantees. The main was payment of taxes, just like in the case of the other residents: a) the tithe (Rom. dijmă, zeciuială de dijmă), with origins in the Old Testament and ecclesiastical practices,55 should be interpreted as an expression of gratitude to the ruling prince for the privilege of enjoying the usufruct or full possession of the purchased land;56 b) contribution to the haraç, a due paid by the country to the sultan. Taxation thus became a key element in the process of împământenire: in order to acquire the right of putting down roots, one had first to settle in Wallachia or Moldavia and register for fiscal residence there. This amounts to saying that the local ruling prince was not interested in the language or the birthplace of foreigners who wished to become his subjects: in other words, he did not impose either a jus soli or a jus sanguinis. Foreigners who settled permanently in the Principalities and wished to be granted the monarch’s protection, and ultimately also the right to own land, were simply expected to pay their taxes. To quote Moldavia’s Prince Alexandru cel Bun, the foreigner was expected “to suffer the burden of taxes together with the local community” (să sufere cu târgul). He made these comments in 1418, when he allowed Armenian merchants arriving from Poland to settle in Moldavia and open shops where they could con54 Cotovanu, “Chasing away the Greeks”, passim. This work is not discussed by Iordachi, Liberalism. 55 Philippe Simonnot, Les papes, l’Église et l’argent. Histoire économique du christianisme des origines à nos jours (Paris: Bayard, 2005), 12–5. 56 In the Principalities, there were two categories of tithe: one was an income tax, levied on the totality of an individual’s assets, and assimilated to a pro anima donation – a gift to the Church, generally made at the end of one’s life; the second was a tithe paid annually to the monarch as a price for the use of one’s land. On the former, of Byzantine origin (Jean De Malafosse, “La part du mort à Byzance”, in Études d’histoire du droit canonique dédiées à Gabriel Le Bras, t. II, Paris: Sirey, 1965, 1311–16; Florentia Evangelatou-Notara, “Αδελφάτον. Ψυχικόν. Evidence from Notes on Manuscripts”, Byzantion 75, 2005: 165–70), see: Artur Gorovei, Partea sufletului. Un vechi obicei al poporului român (Fălticeni: “J. Bendit”, 1925); Emanuel Săvoiu, Contribuţiuni la studiul succesiunei testamentare în vechiul drept românesc (Craiova: Ramuri, 1942), 78–80; Cristina Codarcea, Société et pouvoir en Valachie (1601–1654) entre la coutume et la loi (Bucharest: Editura Enciclopedică, 2002), 317–8; Andreea-Roxana Iancu, Le rêve de perpétuité. Transmission du patrimoine entre stratégie successorale et pratique dévotionnelle (Valachie, fin du XVIIIe siècle – début du XIXe siècle), Unpublished PhD thesis, EHESS (Paris, 2010), 57, 166, 310. On the latter, see Ovidiu Sachelarie, and Nicolae Stoicescu, Instituţii feudale din Ţările române. Dicţionar (Bucharest: Editura Academiei Române, 1988), 158–9, entry “dijmă”. 83 L i d i a C ot ovanu duct their retail business.57 Because the central power lacked the resources to check the compliance of all new taxpayers under its jurisdiction, many potential taxpayers slipped through the net of the state’s revenue collectors. This led Wallachia’s Prince Leon Tomşa, under pressure from the land’s boyars, to request in 1631 that all “Greek” residents who owned landed estates and were married on the country’s territory be registered in local fiscal circumscriptions and establish their permanent residence there. In addition, they were to “join the community and pay their share to the country’s common need, like all the other local subjects” (să tragă cu târgul la nevoia ţării ca şi moştenii locului; să să lipească la cetele ţărâi şi să lăcuiască în ţară).58 In these documents from 1631, Leon Tomşa added that even those who had spouses and homes in their countries of origin (şi-i va fi fămeia şi casa într-altă ţeară) could acquire settlement rights in Wallachia if they paid taxes locally and showed loyalty to their “adoptive” country. If they failed to comply, they were threatened with the confiscation of their assets and expulsion from the territory.59 The requirement to register for fiscal residence in Wallachia and Moldavia as a prerequisite for acquisition of the pământean / subject status and thereby acquisition of land is reflected in its very opposite: any absence from the territory, beyond a specifically defined period, was penalized with the confiscation of all assets left behind.60 Confiscation of assets could Mihai Costăchescu, Documentele moldoveneşti înainte de Ştefan cel Mare, t. II, Documente interne. Urice (Ispisoace), Surete, Regeste, Traduceri (1438–1456), Documente externe. Acte de împrumut, de omagiu, tractate, solii, privilegii comerciale, salv-conducte, scrisori (1387–1458) (Iaşi: Viaţa Românească, 1932), no. 176, 630–7. 58 Documenta Romaniae Historica, B, Ţara Românească [henceforth: DRH, B], t. XXIII (1630– 1632), ed. Damaschin Mioc (Bucharest: Editura Academiei Române, 1969), no. 255, 406– 9. Rizescu, Avant l’“État-juge”, 171, is wrong when she states that “the principle of fiscal domicile” was introduced in Wallachia by the ruling Prince Matei Basarab (1632–1654). Like in neighboring Moldavia (see footnote above), this principle was in fact as old as the Land of Wallachia itself. 59 DRH, B, t. XXIII, no. 255, 406–9. For reasons which I discussed elsewhere, Leon Tomşa’s orders were never put into practice and did not bring any changes to the customary provisions for the political-legal integration of foreigners in the Principalities: Cotovanu, “Chasing away the Greeks”, passim. Wallachia’s ruling Prince Ștefan Racoviţă issued a similar proclamation in 1764, which, like Prince Tomşa’s, remained without any practical effect: document published in Uricariul cuprinzătoriu de hrisoave, anaforale şi alte acte atingătoare de Moldo-Valahia din suta a XV-a şi până în zilele noastre, t. V, ed. Theodor Codrescu (Iaşi: Buciumul Român, 1862), 336–40; comments in Iordachi, Liberalism, 77–8. 60 This legal provision of Byzantine origin was incorporated into the law codices in force in Wallachia and Moldavia in the 17th century: Carte românească de învățătură (1646), critical edition (Bucharest: Editura Academiei Române, 1961), Pricina (case) 1, § 14, p. 56; Îndreptarea legii (1652), Glava (chapter) 296, Zac. (section) 14, 282. I do not know specifically the statutory time limit beyond which an absent Wallachian or Moldavian subject who had fled abroad had his wealth confiscated. Presumably, this period depended on the speed with which the monarch learned about the case details and the goods left behind. It is 57 84 The Naturalization of Greeks in the Principalities of Wallachia and Moldavia be applied to foreign-born subjects returning to their country of origin, as well as to native-born subjects (boiar pemintian ori mazil, sau alţii ce să va înstrăina la altă ţară şi va rămănea moşiia aicea).61 This was the penalty inflicted in 1557 on a certain Stoica from Wallachia, who had fled to the town of Brăila, “in foreign lands”.62 Another example is that of the widow of Macrea “the Greek” who, in 1644, refused to pay the debts of her late spouse and “had fled to the Turkish Land, where she had remarried”: consequently, her lands at Maxen, Jăleşti and Negreasca were expropriated “to the benefit of the seigneurie”.63 Yet another relevant case is that of Andrei the standard-bearer (Rom. stegar), who, with his brother Doni and their neighbour Chicoş, all residents of Moldavia, had fled to the “Turkish Land”, thereby abandoning their fiscal place of residence (şi-au lăsat cisla). The village parts they owned were given to their fellow-villager Nechifor, who had taken the responsibility of paying the fugitives’ taxes. However, upon their return to the country, the former owners were allowed to take their possessions back, provided they reimbursed Nechifor.64 Summing up, the process of putting down roots (împământenire) essentially involved: settling permanently in the country and paying one’s taxes, according to the tax category one belonged to (irrespective of tax systems and tax collection rules’ specificities, which varied across countries and over time). While complying with these rules, one earned the status of pământean, alternatively defined as a “man of the land” (om de ţară), a “man of the seigneurie” (omul domniei), “resident” (şăzător cu casa). Semantically, the term împământenire equally covered the political ties between the subject and the prince-state – i.e., a specific status – and the pathway to this status via the act of establishing one’s tax residence in the country – i.e., a concrete action. The fact that the process of împământenire did worth remembering that the monarch was always in search of vacant goods with which to reward those of his allies and clients who had been loyal to “the seigneurie and to the country”. A late example, from September 1763, shows that the period in question could be as long as 30 years: Ispisoace şi zapise, t. IV/2, Documente slavo-române (1692–1694), ed. Gheorghe Ghibănescu (Iaşi: “Dacia” P. & D. Iliescu, 1915), 115–8 (16 September 1763), with editor’s comments, 118–25; the case is also cited by Valentin Al. Georgescu in Bizanţul şi instituţiile româneşti până la mijlocul secolului al XVIII-lea (Bucharest: Editura Academiei Române, 1980), 228. 61 Ispisoace şi zapise, t. IV/2, 115–8. 62 Documente privind Istoria României, B, Ţara Românească, t. XVI/3 (1551–1570) (Bucharest: Editura Academiei Române, 1952), no. 86, 75 (9 November 1557); comments in Constantin C. Giurescu, Istoricul oraşului Brăila (Bucharest: Editura Ştiinţifică, 1968), 91. 63 Biblioteca Academiei Române, Documente istorice, CCXCIX/114 (1 August 1644); summarized in Catalogul documentelor Ţării Româneşti din Arhivele Statului, t. V (1640–1644), eds. M.-D. Ciucă et al. (Bucharest: Editura Academiei Române, 1985), no. 1409, 591. 64 DRH, A, t. XX (1629–1631), eds. Ioan Caproşu, and Constantin Burac (Bucharest: Editura Academiei Române, 2011), no. 641, 692 (20 October 1631). 85 L i d i a C ot ovanu not entail uniform capacities and privileges (in the political and economic fields, notably) for all subjects is a different matter, which, for reasons of space, cannot be addressed here.65 Similarly, I shall not dwell on the various social, informal criteria, such as marriage, court office, work, property, etc., which could provide alternative pathways towards fiscal integration to those foreigners who settled permanently in the Principalities.66 As a conclusion to the above, I would like to emphasize that, when speaking of the legal integration of the foreign-born – including the “Greeks” – within the pre-national sovereign space of Wallachia and Moldavia, the correct term to use is împământenire, meaning putting down roots by establishing one’s fiscal residence and by becoming a taxpayer in the country. This process is more complex than a mere settlement on the country’s soil. Conversely, the legal fiction of naturalization is an attribute of the nationstate introduced after 1789. The two terms designate radically different realities, pertaining to “world spaces” that are distinct from each other. The principle of împământenire, as outlined in the present study, remained in force until the Peace of Küçük Kaynarca of 1774, a date which witnessed the opening of foreign consulates in the Principalities (the Russian consulate opened in 1782, the Austrian in 1783, followed by the Prussian consulate in 1784, the French in 1795, the English in 1800, etc.). This For further details on this topic, I refer readers to my unpublished doctoral thesis, Migrations, 432, and, in particular, to the bibliography. 66 Cotovanu, Migrations, 428–31. Contrary to Iordachi’s argument in Liberalism, 63, marriage and ennoblement alone were not enough to provide pathways to the acquisition of status as a subject – “to naturalization”, according to the author. They simply opened the way to land ownership and tax integration: marriage integrated the new subject within a community of (family) property, whereas ennoblement via office offered access to the privileged, tax-exempt boyar class. Not all foreign-born subjects of the Danubian ruling princes were married, noble or ennobled. For the sake of analytical finesse, it is worth keeping in mind distinction between the legal principle as a source of status (in our case, the payment of taxes as a prerequisite for becoming a political subject) and the pathways offering access to status (specifically, tax integration). More recently, Constanţa Vintilă-Ghiţulescu, in “Marié à un ‘étranger’, marié à l’étranger”, Bulletin de correspondance hellénique moderne et contemporaine 1 (2019) (available online at: http://journals.openedition.org/bchmc/296), discusses the role of marriage as a pathway to the integration of “foreigners” (in the sense of migrants “from abroad”) within Wallachia’s social structures, without addressing the topic of the juridical integration of “foreigners” and the pathways to their transformation into local subjects. The expression “naturalization by absorption”, borrowed from M.D. Sturdza, has no analytical value. Marriage as a pathway to social integration and access to office for the Christian subjects of the Ottoman Empire was studied in detail as early as 2003 by Radu Păun in Pouvoirs, offices et patronage, Part Two; Păun, “Les Gréco-Levantins dans les Pays Roumains: voies de pénétration, étapes et stratégies de maintien”, in Studia Balcanica. “Vizantija. Bălgarija. Evropa. Izsledovanija v cest na Prof. Vasilka Tăpkova-Zaimova” 25 (2006): 304–16. The list of case studies discussed by Romanian historians is too long to cite here. 65 86 The Naturalization of Greeks in the Principalities of Wallachia and Moldavia was a milestone in the history of the Principalities, marking a shift in the definition of local subjects and foreigners.67 Until that date, the two lands had known only two categories of foreigners on their territory: internal foreigners, so defined on the basis of their tolerated, non-Orthodox faith, and external foreigners, subjects of foreign states who were in transit or had temporary residence in the Principalities. The opening of consulates created a third category, that of the so-called sudiţi or supuşi străini: these were foreign subjects residing permanently in the Principalities, but falling under the jurisdiction of consular representatives and incorporated within privileged collective units. This shift, triggered by the jurisdictional interference of the Christian powers into the affairs of the Principalities, compelled the Ottoman Porte to reassert its right of jurisdiction over Wallachia and Moldavia and clarify the legal status of their inhabitants in relation to the sultan. They were assimilated to the Ottoman re‘aya, in the sense they were simultaneously subjects of the local ruling princes and of the sultan. Concurrently, this shift also caused the Wallachian and Moldavian ruling princes to revise the ways in which they defined their subjects and codify their access to the possession of lands, their rights to exercise retail trade, as well as their political capacities and privileges. It is worth reiterating that it was the opening of foreign consulates in the Principalities, rather than the “Greek” presence in both lands and the hostile response to it among the local political elites,68 which brought changes to the legal definition of subjects and foreigners in Wallachia and Moldavia. Henceforth, not all permanent residents on the country’s soil were subjects of the local sovereigns, enjoying the same civil and political capacities: to access such capacities, they first had to submit an application to the authorities in order to obtain permission for împământenire / pământenie. This was the beginning of a lengthy bureaucratization of the concept of împământenire, which gradually evolved towards naturalization, as a result of the adoption of the French Code civil and the foundation of the Romanian nation-state. This process led to the emergence of a state monopoly over the procedures for the political-legal integration of foreigners and ensuing rights to own landed property and be elected to public office. 67 The essential study on this topic remains the book by Stela Mărieş, Supuşii străini din Moldova între anii 1781–1862 (Iaşi: Editura Universității „Alexandru Ioan Cuza”, 1985). See also Dimitris Kontogiorgis, “From Tolerance to Exclusion? The Romanian Elites’ Stance towards Immigration to the Danubian Principalities (1829–1880)”, in Olga Katsiardi-Hering, and Maria A. Stassinopoulou, eds., Across the Danube, 275–302. 68 Contrary to Iordachi’s interpretation, Liberalism, 31–84. 87

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