Institutional Erasure: Legal Pluralism in Colonial Egypt
Samy A. Ayoub
Legal pluralism, as practiced in Egypt in the 19th – 20th centuries, was made possible within institutional structures, procedural norms, and Islamic legal practice under Khedival rule. Islamic legal practice during Ottoman rule not only made other legal traditions accepted within a pluralist legal order, but also, it made them germane to how the system was to operate. This coexistence among different legal regimes was unsettled due to the expansion of secular national courts inaugurated in 1883. These courts gradually claimed universal jurisdiction and later consumed the entire legal sphere. British colonial officials in the late 19th century and nationalist secular elite in the early 20th century saw Khedival legal pluralism as an obstacle to national sovereignty in the postcolonial Egyptian state. The Egyptian constitution of 1923 was intentionally designed to not only facilitate an official rupture from the Ottoman order but also to enshrine new conceptions of sovereignty which radically reoriented the Egyptian state’s political and legal traditions. By the 1920s, the British colonial policy of unifying the judiciary in Egypt was adopted by Egyptian nationalists who argued that Islamic courts and religious tribunals for Jews and Christians must be subsumed under nationalized secular state courts. Among the key motivating factors for adopting this position was the Egyptian insistence and struggle to end capitulations, and their belief that a unified national court system for all Egyptians, regardless of their religious tradition, would enhance the rise of a cohesive national identity.
Law occupied a central role in imperial governance in British colonial Egypt, where a sophisticated set of institutions, rules, and procedures were promulgated to govern judicial practice. This short essay focuses on judicial practice in the early 20th century through an intertwined set of institutional, political, and legal apparatuses such as the Ministry of Justice and the courts. Islamic courts, judges, and lawyers –– as a manifestation of the system of governance –– were subject to regulation, reorganization, and contestation in colonial Egypt. The Ministry of Justice, for example, managed the Islamic courts and their operations through the consistent issuance of guidance memos (manshūrāt) and decrees (awāmir) that instructed the courts and judges on the correct interpretations of regulations and procedures; provided updates about policy changes in the ministry; and solicited proposals from judges and lawyers for potential improvements to the courts’ operations.
I locate modern Egyptian legal history within emerging practices, notions, and institutions created by the Egyptian political and legal elite in the late 19th and early 20th centuries CE. While much of historians’ attention has been directed toward either the study of the social history of the law or to a focus on the rulings issued by some Islamic courts, considerably less attention has been paid to the regulatory requirements, structural reforms, and procedural changes within Islamic courts during the Khedival and colonial periods.
Egypt’s political history informs our understanding of how the Egyptian state operated among Islamic law, Ottoman and Khedival imperial codes, and European laws. From 1517 – 1867, Egypt was one of the Arab provinces of the Ottoman Empire. Egypt became an autonomous tributary state of the Ottoman Empire and was given the new title Khedivate of Egypt from 1867-1881. In 1875, Egypt came under the legal and political authority of European powers. From 1882 to the early 1950s, Egypt was a British colony. Before the British mandate over Egypt, France had occupied it briefly from 1798 to 1801. The tension among these different legalities –– in particular, the emerging hegemony of European laws –– shaped a variety of Egyptian responses that sought to preserve Islamic law, its practitioners, and its institutions.
I propose that the history of procedural law within Islamic courts casts doubt on the undifferentiated histories of modern legal thought and practice in Egypt. For example, the targeted reforms within Islamic courts, in the late 19th century specifically, can be narrowed down to issues of jurisdictional authority and procedural rules, with an entrenched view among British colonial officials and secular elite of the inherent arbitrariness of Islamic courts.1“Mā Hādha,” in Majallat al-Aḥkam al-Sharʿiyya (1) 8-9, 209-213 The strategies and structural changes that effectively (re)shaped legal practice in Islamic courts and religious tribunals evolved around three anchors: jurisdiction, procedure, and institutional reconfiguration. A key consideration in this regard is how the technical and mundane nature of procedural rules might make them uninteresting sites for historical and legal research. Unfortunately, this means that the transformative power of procedural law to shape Islamic substantive rules and alter Islamic court operations is absent from current treatments of the subject in this time period.
Studying the development of procedural rules commits us to asking historicized questions about Islamic law. These rules defined how Islamic courts registered cases, conducted trials, evaluated evidence, and passed judgment. Any history of Islamic courts in modern Egypt faces two central challenges: (1) the colonial and nationalist narratives of “reform” painted a negative picture of Islamic courts’ “old” and “ad-hoc” operations; and (2) secular Egyptian legal elite dismissed Islamic legal institutions and religious tribunals for Jews and Christians as irrelevant to the postcolonial Egyptian state project. Official histories, for instance, point to the inevitable abolition of these institutions as a precondition for a nationalized modern (civilized) legal order. I argue that the history of procedural changes within Islamic courts reveals both the reductive nature of the discourse of “reform” (iṣlāḥ) and the limitations of the discourse of “revival” (nahḍa) to provide an enduring alternative or conceive of a convincing explanation to this institutional erasure. These discourses painted the measures taken in relation to Islamic courts in Egypt as necessary remedies meant to preserve and improve their operations. The structural changes in the institutional landscape of law and justice in Egypt were not simply motivated by concerns of reform. These realignments were justified in relation to an emerging political project of nation-building under colonial European administration and supervision.
A driving force behind these procedural transformations (which included a drastic reduction of the number of Islamic courts) was the British colonial demands to “reform” these courts and to limit their jurisdiction. To put the magnitude of these structural changes into perspective, in 1880 Egypt had 3,833 Islamic courts distributed among its villages, towns, cities, and provincial capitals. In 1955, on the eve of the abolition of these courts, Egypt had just 137 Islamic courts. The narrative we observe from the British judicial advisors’ reports makes clear that the goal of introducing procedural changes and reforms was not only to restructure Islamic courts for the sake of improvement but also to achieve substantive realignment of their operations with visions of civil law adopted in secular courts.
The history of Islamic courts is usually subsumed under discussions of the place of religion in Egyptian society and the diminishing of the Islamic courts’ role and jurisdiction as evidence of legal modernity. One of my central claims is that the gradual adoption of systems of procedure –– heavily influenced by the Continental legal tradition in which lawmaking is primarily the domain of the state and not of the courts –– must be considered in the evaluation of the legal history of modern Egypt. The availability of a plural legal order was undermined by the hegemony of the logic of civil law among legal elites. The result was that legal pluralism was reframed into a discourse of “chaos.” This discourse of chaos was a key justificatory tool to the institutional erasure of Islamic courts under Khedival governance in Egypt.
Shifting Jurisdictions: Navigating Legal Pluralism2This case was litigated before the Islamic and Jewish Courts in Cairo. Then, it was reviewed before the Appellate National Court. The details of this case were published by the plaintiff’s lawyer among other cases that he argued before courts in early 20th century Egypt. See, Azīz Khānjī, Majmūʿat Mudhakirāt (Cairo: Maṭbaʿat al-Akhbār, 1912), 121-155.
The case study below is a window into judicial practice in early 20th century Egypt. It offers glimpses into the realities of legal pluralism in modern Egyptian history. It demonstrates how courts played key roles in shaping the social and religious scenes by considering the institutions of justice that shaped the legal practice and thought of Egyptian jurists, judges, and lawyers. The parties to this case, anticipating the shifting jurisdictional legal authorities, litigated a set of questions before Islamic, Jewish, and National courts.
The case below is narrated through the eyes of Laṭīfah, the plaintiff in this case, and the arguments of her lawyer, ʿAzīz Bik (Bey) Khānjī (d. 1956). Khānjī was a lawyer and a historian, and one of the key figures who wrote and practiced law in Egypt in both its Islamic and National courts. His family came from Aleppo with an Armenian catholic background. He was trained in law at the Khedival School of Law (Madrasat al-Ḥuqūq al-Khidīwiyya).3This school used to be part of Madrasat al-Idāra wa al-Alsun (School of Administration and Languages), which was revitalized under Ismāʿīl Pasha in 1886. The school of administration was dubbed as Madrasat al-Ḥuqūq (School of Law), yet its goal was the training of government officials. This school later became the Egyptian University School of Law (Cairo University), when the university was founded in 1925. See Farhat J. Ziadeh, Lawyers, the Rule of Law, and Liberalism in Modern Egypt (Stanford Cal.: Hoover, 1968), 21. Khānjī attended Islamic law classes at al-Azhar and joined the famous Muslim reformist Muḥammad Abduh’s circle in the late 19th century CE. He started his career as a lawyer in 1899 and was immediately recognized as one of its rising stars. He was also key to the foundation of the National Lawyers’ Bar Association (Niqābat al-Muḥāmīn) in Egypt. He published more than 40 titles on legal, political, and historical issues in early 20th century Egypt.4Khayr al-Dīn al-Ziriklī, Al-ʿAlām: qāmūs trājim lī ashhar al-rijāl wa al-nisāʾ min al-ʿarab wa al-mustaʿribīn wa al-mustashriqīn, 8 vols. (Beirut: Dār al-ʿIlm lil-Malayīn, 2005), 4:230. In the 1920s, Khānjī worked as a propagandist for the secularist Kemalist regime in the emerging Turkish republic (168-74). Khānjī’s historical works and legal analysis belonged to a trend of teleological nationalist histories of the 19th– 20th century.
The Life of a Player in 1905 Cairo: A How-To Guide
Alī Bik (Bey) Fahmy and Laṭīfah met for the first time in 1905 in Cairo, Egypt. Alī introduced himself as an aristocratic Egyptian. Laṭifah’s first impression of him was that he was a sincere person and probably possessed serious wealth. Later we learn that the name “Alī Bik (Bey) Fahmy” was only a pseudonym for Maḥmūd Efendī who introduced himself as “Alī Bey Fahmy” to Laṭīfah. I will use the real name, Maḥmūd, the defendant in this case, to avoid confusion.
Maḥmūd was a Muslim and Laṭīfah was Jewish (isrāʿiliyya). According to Jewish Law, we are told by Laṭīfah’s lawyer, it is prohibited for a Jewish woman to marry a Muslim man. In the face of these obstacles, Maḥmūd, as a sign of his love, offered to convert to Judaism to marry Laṭīfah. He went to the Jewish religious authorities (Ḥākhāmākhāna) and asked to convert to Judaism. The Ḥākhām (Rabbi) tentatively agreed and promised to start the legal process and all relevant religious rituals, once Maḥmūd submitted his written application.
Despite Maḥmūd’s efforts to win over Laṭīfah, some members of her family had opposed their marriage. We are told that her uncle did not like Maḥmūd. Laṭīfah’s sister, however, was in favor of the marriage. Maḥmūd used to send a constant flow of love letters that swayed Laṭīfah’s heart. In one letter, Maḥmūd wrote: “Oh beloved, if only you would know how much I adore you!…I cried so much [due to my longing for you] after you saw me off from our last date.” Laṭīfah went through a period of mixed feelings about this marriage proposal but decided to marry Maḥmūd after his conversion to Judaism.
One day, Maḥmūd jubilantly reported to Laṭīfah that the Jewish religious authorities offered initial acceptance of his application and asked if she would accept him in marriage as a Jewish convert. Laṭīfah promised to accept his marriage proposal, and they both went to the Jewish court and were issued an initial marriage contract. In December 1905, Maḥmūd applied to the Jewish court stating his intentions to convert to Judaism out of love for this religion. He also made statements about his marital status, debts, place of birth, and relevant details. In his written application to convert to Judaism, Maḥmūd declared: “I am ‘ʿAlī Fahmy,’ present at the Ḥākhāmākhāna, seeking to convert to Judaism out of love for this religion. I am not married. I have no debts. I am not in need of financial support. I am financially solvent. I was born in Bilbīs (a town in the Delta’s Sharqiyya governorate). I currently live in Cairo, I studied at the English School, and I speak English. I am 23 years old. I have no father or mother. I am an orphan. I request a date to come to the Ḥākhāmākhāna to perform the rituals to convert to Judaism.” In addition to this statement, Maḥmūd submitted an affidavit, signed on 29 December 1905, by three witnesses to confirm his name, age, and residence.
After submitting this application, the Jewish court sent a letter to the local governor’s office informing them that Maḥmud (Alī Bey Fahmy) had applied to become a Jew. The head of the Jewish religious authority asked the governor to send officials to give Maḥmūd some advice and share with the Jewish courts the necessary legal procedures to follow in these circumstances of conversion. The Ḥākhām proposed that the government deputy should arrive at 10:00AM on Sunday, 31 December 1905.
After these steps, the Jewish court approved Maḥmūd’s conversion. On Tuesday, 5 Tevet 5666 (2 January 1906) the main Ḥākhām supervised Maḥmūd’s immersion into a mikveh (a pool of natural water in which one bathes for the restoration of ritual purity) before a public audience. Maḥmūd had also gone through a Jewish circumcision ritual, probably a day earlier. Although Maḥmūd was already circumcised as a Muslim, he had to go through a modified procedure to follow Jewish law. Before an assembly of Jewish authorities and local elite members, the Ḥākhām warned Maḥmūd that following Jewish law might be challenging and would require discipline. Maḥmūd insisted on his conversion and confirmed his commitment to follow Jewish law. Maḥmūd adopted the Hebrew name of Jubrāʿil b. Ibrāhīm (Gavriel ben Avraham).
In January 1906, Maḥmūd married Laṭīfah in a Jewish marriage ceremony and signed a Jewish marriage contract. The contract stated:
(1) Maḥmūd married Laṭīfah according to Jewish Law.
(2) If Maḥmūd desired to divorce Laṭīfah and marry someone else, without a justifiable legal reason in Jewish law, he would be liable for 4000 L.E. along with the 2000 L.E. of the delayed dowry.
(3) Maḥmūd is committed to following Jewish family legal norms as explained in Minhājī Maṣarīm. The book enumerates the marital responsibility upon Maḥmūd: namely, to support his wife by providing food, clothing, and housing. He should not [make her] travel with him without her permission. He may not marry another woman unless they spend 10 consecutive years together, without giving birth to a child. He does not sell or use as collateral anything of her belongings. The inheritance is based on the customary practice of the country. He should not ask her to surrender any of her financial rights.
Within a week of signing the contract, Laṭīfah learned that her husband, Alī Bey Fahmy was in fact Maḥmūd Efendī. When she confronted Maḥmūd with his real name, he confessed and explained that the reason he used an alias was to avoid media attention and the wrath of his family. He reaffirmed his love for Laṭīfah and promised to honor his commitments towards her. Soon after, he submitted a written statement with the Jewish religious authorities explaining his resort to a pseudonym. Thereafter, he was issued an updated Jewish marriage contract with his real name.
After three weeks of marriage, Maḥmūd’s family learned about his conversion to Judaism and marriage to Laṭīfah. Maḥmūd panicked and told Laṭīfah that his family learned about his marriage and conversion, which might legally allow his family to refuse him any inheritance or endowment revenue. If he were to be excluded from receiving inheritance or endowment, he would be poor and unable to sustain his livelihood. To avoid such a catastrophic scenario, Maḥmūd appealed to Laṭīfah that he must, as a matter of formality, marry a Muslim woman (on paper) and sign an Islamic marriage contract (suggesting that he is contracting marriage as a Muslim, presumably negating his apostasy). On February 20, 1906, he signed an Islamic marriage contract (24 days after the signing of the Jewish marriage contract).
On several occasions, it appears that Maḥmūd violated his commitments toward Laṭīfah. For instance, before signing his Jewish marriage contract, Maḥmūd committed to gift Laṭīfah 1,000 L.E. over three years to help her and her family. He wrote a signed declaration granting her authority to seek these three annual installments from the tenant who leased his agricultural lands. After consummation of marriage, Laṭīfah wrote to the tenant seeking the first installment. The tenant sent her a legal notice with a lawyer affirming that he had already paid Maḥmūd all his money in advance and owes no money to Maḥmūd.
Furthermore, Laṭīfah claimed that Maḥmūd attempted to force her to surrender her financial claims and accused him of being abusive and physically assaulting her. Laṭīfah narrated that Maḥmūd invited her to a date night at a local nightclub and theater, Teatro, on one day in April 1906. Laṭīfah was excited, and she donned a nice dress and all her jewelry. Maḥmūd and Laṭīfah got into the car, but shortly after, it stopped before the house of a local shaykh (a relative of Maḥmūd). Abruptly, Maḥmūd asked Laṭīfah to join him briefly inside the house. Laṭīfah sensed something was wrong and refused to leave the car. As a result, several men approached her and forcefully carried her into the house. Then, they stripped all of her jewelry from her. They beat her and attempted to force her to sign a paper to forsake financial obligations committed to her by Maḥmūd. Luckily, because she was screaming loudly, the house owner, along with some neighbors, were able to hear her cries for help, and they rescued her. Laṭīfah went to the police who investigated the incident and decided to refer the case to the public prosecutor office.
Maḥmūd realized the failure of his attempts to escape his financial obligations or responsibility towards Laṭīfah. He approached her for forgiveness and offered to have the Jewish court intervene to settle things between them. He assured her that he would accept the Jewish court’s decision. As a sign of good faith, he returned all of her jewelry and went with her to the Ḥākhāmākhāna. On 21 May 1906, both Maḥmūd and Laṭīfah appeared before the Jewish religious authorities in Cairo and agreed, in writing, to accept the appointment of two judges to review their case and to issue a binding decision.
Before the Jewish court, Laṭīfah relayed her complaints against her husband, including his abusive behavior and his repeated attempts to force her to surrender her financial rights. Maḥmūd testified before the court that he denied any abusive behavior towards Laṭīfah. He explained that he converted to Judaism for his love for her. He asserted that he was living comfortably and providing for Laṭīfah. He asked the court to see Laṭīfah’s clothes and check their household furniture as a sign of his wealth. Maḥmūd claimed that he gave her money to buy food for Passover and that he strictly eats Kosher meat from the Jewish butcher. He claimed that he was committed to his adopted Jewish faith. He asserted that the incident at the house, on 25 April 1906, which involved physical altercations, was started by her. He reiterated that he was seeking peaceful settlement with Laṭīfah, and he would accept the decision of the Jewish court.
The Jewish court reaffirmed Maḥmūd’s financial obligations towards his wife, Laṭīfah, totaling 6,000 L.E. He affirmed before the court that he was committed to paying this amount of money in case of divorce, or if he married someone other than Laṭīfah. The court ruled that (1) if Maḥmūd divorced Laṭīfah, disturbed her life, or violated this court’s decision, he would be immediately responsible to pay his agreed upon financial obligations, and (2) Maḥmūd should never harm Laṭīfah physically or emotionally. The court’s decision was read out before the two parties. They both accepted it and recorded their acceptance in writing. As a result, Laṭīfah dropped her legal suit against Maḥmūd in the secular court, which fined him 100 piasters and payment of the legal fees.
Maḥmūd and Laṭīfah’s relationship deteriorated rapidly in 1907. Maḥmūd violated the agreement from the Jewish court. First, Laṭīfah claimed that he physically assaulted her on two separate occasions. In each incident, Laṭīfah filed a lawsuit in the court and Maḥmūd was hit with heavy fines. Second, it was revealed that Maḥmūd was married to two other women while he was married to Laṭīfah. The second wife, Adilāt, was in an unregistered marital relationship with Maḥmūd, and the third wife, Zakiyya, known as Munīra B. Ḥasan, had been in a registered marital relationship with Maḥmūd for some time. After Laṭīfah learned about these revelations, she left Maḥmūd’s marital house. Maḥmūd sued Laṭīfah in the Cairo Islamic court seeking a judgment to compel her to return to his marital house. At this point, Maḥmūd was engaged in legal battles simultaneously with Laṭīfah, Adilāt, and Zakiyya.
At the Cairo Islamic court, Laṭīfah argued that the court had no jurisdiction in her case. She explained that she and her husband are a Jewish couple, and they are subject to Jewish law. Maḥmūd countered that he was in fact a Muslim, reminding her of the Islamic marriage contract he signed shortly after his marriage to her. She explained to the court that Maḥmūd claimed that his signature was only a formality to allow him to inherit from his family and keep his stipend from his family’s endowments. Laṭīfah also presented documentary evidence that Maḥmūd affirmed his Jewish faith on many occasions after signing this marriage contract.
Foreseeing his weaker position in the case (and probably fearing investigation of his apostasy), Maḥmūd declared before the Cairo Islamic court that he divorced Laṭīfah. This legal tactic allowed Maḥmūd breathing room by achieving a key goal: dropping his case against Laṭīfah. The judge at the Cairo Islamic court acknowledged that Laṭīfah presented sufficient documentary evidence about her husband’s conversion to Judaism. However, the case before the judge was concerned with a marital dispute, and since Maḥmūd announced his divorce from Laṭīfah, the case against her to return to Maḥmūd’s marital house was dismissed.
Laṭīfah filed a new lawsuit against Maḥmūd before the first-degree national court in Cairo seeking to compel Maḥmūd to pay her the 6,000 L.E. ordered by the Jewish court’s decision. The court dismissed the case, arguing that the agreement between Maḥmūd and Laṭīfah made before the Jewish court was signed after Maḥmūd signed an Islamic marriage contract, which allows him, as a Muslim, to marry more than one wife and divorce a wife without financial sanction. In other words, the Jewish court decision is not binding in this case because Maḥmūd was apparently a Muslim, and Jewish law would not apply to him.
Laṭīfah took the case to the Appellate National Court. The court ruled that Maḥmūd was obliged to pay Laṭīfah 6,000 L.E because he violated the agreed upon conditions in the written agreement before the Ḥākhāmākhāna. The court did not explore the issue of conversion. Instead, the court considered the signed agreement between Maḥmūd and Laṭīfah as a binding arbitration and a civil contractual matter. For the court, the signed agreement gained its authority as a contractual commitment in the civil law, not as a decision from the Jewish court. The Appellate court reversed the previous judgment for the lower court and compelled Maḥmūd to pay his financial obligations towards Laṭīfah.
Some of the questions that could be elicited from this case are: Why did the Islamic court consider Maḥmūd a Muslim by simply signing an Islamic marriage contract, despite his stated Jewish faith in his official documents and before the Jewish court (and even after signing this Islamic marriage contract)? Also, if the court recognized that Maḥmūd was at some point an apostate who converted to Judaism, how should this fact have affected his other two Muslim wives and their marriages? Aren’t Maḥmūd’s marriages to these two Muslim women automatically dissolved in the case of his confirmed apostasy? At the same time, if Maḥmūd was a Muslim, as the court considered him, wouldn’t this scenario dissolve the marriage contract with Laṭīfah because it is prohibited in Jewish law to marry a Muslim man?
The key lesson here is that the coexistence among different legal regimes was unsettled due to the expansion of secular courts. These secular courts claimed universal jurisdiction and later consumed the entire legal sphere. The challenge of the secular national courts in Egypt should not be reduced to their mere presence as an alternative. The adopted substantive procedures that accompanied these courts were key in the mounting criticism of Islamic courts and their bureaucratic operations. We must reject both the revisionist interpretations of these transformations and the historical inevitability of canceling “religious” legal institutions. These attitudes overlook the history of Islamic legal institutions that survived colonialism in the Muslim world. I propose that we need to move beyond debating the “loss of the Sharīʿa” to focus specifically on the institutional history of justice. This might allow us further insights into the process of how civil and Islamic law were reified and opposed to one another.
The case study provides us with important background to some of the complicated issues of conversion, such as its motivations and the official processes to authorize it. It reveals how Islamic and Jewish courts played key roles in shaping social life in Egypt. It demonstrates how the institutional apparatus of courts maintained Islamic and Jewish legal norms and their social relevance. I find the interpretations of the lower national court odd considering the published jurisprudence of Islamic courts. I contend that the signed arbitration by the two parties facilitated by the Jewish court would have been maintained in an Islamic court because it was contractually binding. The lower secular national court’s decision suggests that marital disputes in Islamic and Jewish courts translate to only “religious” obligations which are binding only upon those who belong to these traditions. Thus, this case underlines a key transformation in the late 19th century: as part of the secular ideology of the legal elite and British colonial officials, Islamic courts became “religious” courts concerned primarily with matters of family law. In 1897, for the first time in the history of Islamic judicial practice, the Egyptian government officially adapted the function of Islamic courts to follow that of the Jewish and Christian courts, restricting the former’s scope to the domain of personal status law.♦
Samy A. Ayoub earned his PhD from the School of Middle Eastern and North African Studies and the James E. Rogers College of Law at the University of Arizona. He specializes in Islamic law, modern Middle East law, and law and religion in contemporary Muslim societies. Dr. Ayoub was selected as a Fellow at the Program on Law and Society in the Muslim World at Harvard Law School. Before joining the University of Texas at Austin, Dr. Ayoub was a postdoctoral faculty fellow at the University of California, Santa Barbara.
Ayoub, Samy A. “Institutional Erasure: Legal Pluralism in Colonial Egypt.” Canopy Forum, February 23, 2022. https://canopyforum.org/2022/02/23/institutional-erasure-legal-pluralism-in-colonial-egypt/.