Are participation rights a lingua franca? The complexities of translating and comparing the term ‘participation’ in educational contexts

Abstract

Children’s right to express their views under article 12 of the United Nations Convention on the Rights of the Child is commonly referred to as ‘participation’. How this term is used in scholarship, policy and practice, however, varies enormously across linguistic and national contexts. This article reports and discusses four complexities associated with translating and comparing the term participation that were identified from a series of international workshops on children’s rights in education. We conclude that further empirical, interdisciplinary research is required to examine these complexities in further depth.

Introduction

Article 12 of the United Nations Convention on the Rights of the Child (UNCRC, 1989) is one of the most commonly used within scholarship, policy discourses and practices regarding children. Some consider it the cornerstone of the innovation contained in this widely ratified treaty, which grants children the full range of human rights and fundamental freedoms (Lansdown, 2014). As the United Nations Committee on the Rights of the Child (2009) acknowledges, implementation practices of Article 12 have progressively been conceptualised under the broader label of participation, “although this term itself does not appear in the text of Article 12” (§3). Even so, the term ‘participation’ continues to prevail in research published in English language and in regional and national policy discourses.

This paper builds upon insights derived from an exploratory research endeavour based on a series of international workshops with scholars specialising in children’s rights in education. Over the years, it has become increasingly apparent that researchers from different nations and language contexts use and understand the term participation in various ways. This realisation prompted an aspiration to understand and compare the meaning of the term ‘participation’ in education across diverse linguistic contexts, across Europe, and beyond. Whilst the exploration of ‘participation’ began as a translation quest, it quickly became visible that simple translations from English to other languages could rarely be done because there were various meanings within each language, as well as within and across various cultural, legal, professional, and political contexts. This led the research team to realise that ‘uncovering’ what participation means in different languages was something akin to opening Pandora’s box: ‘participation’ consists of a range of concepts that make up its meaning. This insight partly changed the direction of our venture, which was now dedicated to digging deeper into the complexities surrounding the participation concept in English as well as in other languages.

In this paper, we describe and analyse complexities we found to be associated with translating and comparing the term ‘participation’ in education law, policies, and practices across various languages, nations, and cultures. Before these complexities are presented in detail, we begin by presenting the conceptual framework used to aid the disentangling of the complexities, drawing on semantic studies distinguishing between signification of a semantic term—encompassing relatively stable and shared semantic features within a linguistic community—and its various contextual meanings (see Darbellay, 2005; Jensen, 2006). Another subsection of the conceptual background focuses on ambiguities surrounding the use and definition of the term ‘participation’ in the UNCRC and related scholarship. The next section presents the methodological process, followed by a detailed analysis of four types of complexities we encountered during the research. First, we describe the challenges of identifying the relevant word(s) in each language due to varying and broad semantic fields. Second, we analyse variations in the contextual meanings of words identified as part of the concept of participation. Third, we consider what the first two complexities mean when the translation process is applied to participation as a human right. Finally, we discuss the challenge of developing a robust and conceptually coherent analysis tool. The last section of the paper comprises preliminary conclusions, which may constitute a basis for future research.

Conceptual background

The semantic challenges of ‘participation’: Theoretical insights

The starting point of the project was that the international understanding and meaning of the term “participation” − whether grounded in international, legal or academic discourse − often differed from its linguistic significations. As our discussions progressed, we recognized that comparing linguistic significations would be insufficient to understand “participation” in education due to its diverse contextual meanings. Therefore, we turned to conceptual tools developed in linguistics, discourse analysis, and comparative transnational cultural history to assist with our analysis. Languages are not neutral, simplified, and homogeneous supports for communication; they are, on the contrary, complex semantic systems woven with diversity, irregularities, and ambiguities inherent to their social, political, and cultural (un)markings. To properly understand and analyse this semantic plasticity, words must be considered not as fixed concepts but as dynamic spaces for semantic negotiation and co-construction.

In semantic research, linguists generally distinguish between the signification and the meaning of a word or concept. Whilst there is no space in this article to delve into detailed definitional debates specific to the field of linguistics, we advance here that signification (or ‘signified’) refers to the content of a word in its denotative characteristics, encompassing relatively stable and shared semantic features within a linguistic community (similar to a dictionary definition). In contrast, meaning includes broader semantic dimensions inherent to different language uses in discourse, influenced by connotations, contexts, and social situations, akin to an encyclopaedic definition (see Darbellay, 2005; Jensen, 2006). Words or concepts are not imposed by the world; they represent what we bring to the world to understand it. Therefore, the use of such concepts tends to proliferate with increasing variations in meaning. Beyond their signification, words are evaluated not only by what they refer to or say but by what they do in and through context-specific discourse: their meaning.

The distinction between signification and meaning corresponds to theories of critical discourse analysis (CDA) suggesting that words (the text) should be considered not only in their context but also in the oral or written text that surrounds them, known as the co-text, which guides the understanding of words situated within the complexity of textuality (Darbellay, 2005). In the context of this study, the distinction between signification and meaning is noteworthy. While the notion of participation may have a relatively stable definition regarding its signification, it remains subject to numerous variations depending on academic and disciplinary contexts, cultures, discourses, texts, and countries. For instance, the word ‘participation’ may carry a specific signification in UNCRC discourse or academic research, differing from its meanings in various languages and cultural contexts.

Another relevant theoretical framework is Espagne’s (2013) work on cultural transfers, which supports an examination of how ideas and objects – such as the notion of ‘participation’ – circulate internationally. Moving beyond the comparison between two nations, this approach shows that any object migrating from one cultural situation to another takes on a new meaning. Cultural exchanges should thus not be reduced to the mere circulation of ideas as they already are but should be recognised as a relentless assimilation, reinterpretation, and re-signification process. Cultural transfer theory also highlights that exchanges do not occur between two languages, nations or cultures as homogenous entities (Espagne, 2013). Contributing to coining ‘transnational approaches’, Espagne suggests that transfers may be studied as complex and dynamic interactions between various poles or linguistic areas in which particular attention can be paid to interconnections and intermingling (métissage) throughout. In this study, a transnational perspective is adopted, whereby the nation-state – as socio-historically defined – is the not main entity considered. It is acknowledged that a nation may comprise several official languages and related cultures and that the same language is sometimes common to several countries, pointing to levels of variation in the alignment of legal texts and the language used.

Participation in the UNCRC and beyond

Another starting point for our efforts to compare and translate the term ‘participation’ was understanding and unpacking ambiguities surrounding the use and definition of this term in the UNCRC and related scholarship. First, there was a debate between the authors regarding whether ‘participation’ is the appropriate term to explore. If the focus is on the word ‘participation,’ the UNCRC should not be the original text since Article 12 recognises ‘the right to be heard’ and does not use the term ‘participation rights.’ However, in its General Comment, the Committee on the Rights of the Child (2009) acknowledges that “the concept of participation is omnipresent” (§86), reflecting “considerable progress” in implementing Article 12 since the Convention’s adoption (§3). Therefore, the notion of participation is frequently used in texts that supplement and elaborate on the Convention’s content. In line with CDA theories, considering the co-text legitimises the study of participation as a pervasive word within the co-text and context of Article 12 (see Darbellay, 2005). This perspective is supported by studies indicating that human rights documents are not static and that the re-contextualisation of rights within social contexts and practices is part of the broader rights apparatus (see Moody, 2016).

Second, the lack of common ground for defining participation rights in the UNCRC complicates the comparison of the meaning of participation in education in different languages and contexts. Various studies offer theoretical models conceptualising participation rights. These models address different questions relating to the meaning of participation rights in the UNCRC. Lundy’s (2007) influential model conceptualises interrelated elements that should constitute children’s participation. Lundy’s model offers a normative definition of participation rights, addressing the question, “What should the meaning of participation rights be according to the UNCRC?”. The model addresses four elements: space (children must be given opportunities to express a view); voice (all children must be facilitated to express their views); audience (the view must be listened to); and influence (the view must be acted upon, as appropriate). Lundy notes that Article 12 can only be understood fully when considered in the light of other relevant UNCRC provisions, especially Article 2 (non-discrimination), Article 3 (best interests), Article 5 (the right to guidance), Article 13 (the right to seek, receive, and impart information), and Article 19 (protection from abuse and violence).

Two additional studies offer multidimensional empirical models of children’s participation rights that could facilitate evaluating their fulfilment and impact in different contexts (Herbots and Put, 2015; Perry-Hazan and Somech, 2023). Herbots and Put (2015) propose a model comprising four main components: purpose (why?), context (where?), stakeholders (who?) and mode (how?). Purpose of participation refers to the ideological presuppositions of why participation is invoked. Context looks to where and in what activities and situations participation occurs. In this regard, the model differentiates between social levels of a child’s life based on Bronfenbrenner’s (1986) ecological approach to child development: the microsystem (the relationship between the child and their immediate environment), the macrosystem (the institutional patterns of a particular culture), and the mesosystem situated between them. The context also refers to the topic that involves participation. Stakeholders typically include the child (ren), their parent(s), and other adults. Mode of participation refers to different typologies defining participation by classifying the level of power-sharing between children and adults. It also distinguishes between individual and collective decision-making.

Perry-Hazan and Somech’s (2023) empirical model focuses on one particular aspect of children’s participation: student participation in collective decision-making (i.e., decisions having collective implications made by a group of students or a group comprising students and adults). The model suggests that student collective participation is a multidimensional structure that emerges within a context. It offers four dimensions that comprise participation: decision domain, level, structure, and target. Additionally, the model suggests that the rationales behind promoting student participation (pragmatic, moral, or developmental/pedagogical) will determine its dimensions, which, in turn, will affect the students (e.g., their rights consciousness and democratic skills), the teacher (e.g., their job satisfaction and professional competence), and the school (e.g., school climate and organisational functioning). It posits that the school’s organisational culture will shape these relationship patterns.

A further model (Gal, 2017) proposes a framework for analysing participation rights to delineate the factors influencing children’s participation. Like Herbots and Put (2015), Gal draws on Bronfenbrenner’s (1986) ecological approach. Gal’s model differentiates between predetermined conditions, the context, and the outcomes. Predetermined conditions refer to the nature of the decision on the agenda, the people affected by it, and the characteristics of the participating child. The contexts influencing children’s participation are depicted in expanding concentric circles, reflecting various spheres, from the individual’s most intimate circle to the broadest national, cultural, and international spheres. Gal’s view of outcomes relates to individual children’s sense of fairness, satisfaction, and well-being as well as to interrelated structural parameters affecting these individual outcomes—the participation level, its continuity, and its systemic use.

Other theoretical models conceptualise children’s participation by classifying participatory practices by the level of power sharing. Indeed, levels of participation are one of the dimensions in empirical models (Herbots and Put, 2015; Perry-Hazan and Somech, 2023). Hart’s “ladder of participation” (1992) delineates eight participation levels. The ladder’s five upper levels fulfil the UNCRC’s rationales. These levels, from the highest to the lowest, comprise (1) child-initiated practices that share decisions with adults, (2) child-initiated and directed practices, (3) adult-initiated practices that share decisions with children, (4) consultation with children, and (5) assigning specific roles to children. The model’s three lower levels allude to practices that do not reflect participation: tokenism, decoration, and manipulation. Shier (2001) similarly classified levels of children’s participation. His model differentiated between (1) children sharing power and responsibility for decision-making, (2) involving children in decision-making processes, (3) taking children’s views into account, (4) supporting children in expressing their views, and (5) listening to children. The model also conceptualised three stages of commitment at each level: ‘openings’, ‘opportunities’, and ‘obligations’.

Some models conceptualising participation rights encompass cultural context in their analysis (Gal, 2017; Herbots and Put, 2015; Perry-Hazan and Somech 2023), acknowledging that children’s participation rights are understood and enacted differently in different societies and cultures. These insights address prevalent criticism regarding the dominance of Western neoliberal values in the literature on children’s participation rights (e.g., Duramy and Gal, 2020; McMellon and Tisdall, 2020). Incorporating the cultural context in models conceptualising participation rights contributes to their empirical rigour. However, acknowledging the inherent disparity of context-based meanings and practices of participation adds challenging complexities to determining the common ground for cross-cultural comparison.

In summary, various models define children’s participation rights from different angles. Some models are broad (Gal, 2017; Herbots and Put, 2015; Lundy, 2007), whereas others focus on education (Perry-Hazan and Somech, 2023) or specific dimensions of participation (Hart, 1992; Shier, 2001). They are embedded in different disciplinary approaches, including the normative/legal perspective (Lundy, 2007), organisational studies (Perry-Hazan and Somech, 2023), or developmental psychology (Gal, 2017; Herbots and Put, 2015). Moreover, the models address different questions including: What should participation rights be? (Lundy, 2007); How should we evaluate or measure the various dimensions of participation rights and which factors influence them? (Gal, 2017; Herbots and Put, 2015; Perry-Hazan and Somech, 2023). Additionally, the models differ in their approach to the cultural context.

In light of the above, it seems that the term “participation” in the field of children’s rights is what Skinner (1988) calls a performative concept, meaning a concept that not only describes something but also evaluates the phenomenon in question, adding a positive or negative value to it. The disparity between the models exemplifies the absence of a settled definition of children’s participation rights that could be adopted as a basis for linguistic comparisons and should be taken into account in the attempt to unpack the meaning of ‘participation’.

Research design

The rationale for this investigation arose in an online discussion of European Conference on Educational Research (ECER) Network 25 (Children’s Rights in Education) (‘N25’) members in September 2021. Membership of N25 is comprised of academics who work in the children’s rights in education field, many of whom were formerly teaching practitioners. Conversations about children’s right to participation in education at ECER 2021 turned to how the word ‘participation’ is understood and used in different languages.

The research began in early 2022 by collecting the authors’ reflections on the research questions in their own language and context. By email, the following six questions were distributed to members of N25 who had expressed an interest in exploring the subject further, requesting brief written responses:

(1) Is the word ‘participation’ used in education in your context?

(a) If ‘Yes’: In what ways is it used? What is the meaning of the word for ‘participation’ in your language/context?

(b) If ‘No’: What word(s) or term(s) are used instead? Do these word(s)/term(s) differ in meaning in the contexts of (a) civil society; and (b) and children’s right to be heard?

(2) In your language and context, what shapes understanding of this word in education?

(3) What consequences does that word have for practice? What are the consequences for implementation?

(4) Is there a legal obligation regarding participation in the context of education? If there is a legal obligation for children to be heard, what is the language used in legislation and statutes for implementation?

(5) Do we know how children understand this word/right?

(6) What questions would you add to this list?

The call received 11 written responses from experts in the field. These responses were used to select speakers who could present diverse perspectives that could prompt further reflection on the research themes at a closed online N25 workshop in March 2022. The meeting also included a presentation by a linguistic expert who introduced relevant semantic theories, including those that distinguish between signification and meaning. The workshop concluded with a strategising session in which it was decided that it was critical to seek the perspectives of those outside the core working group at an in-person event. Drawing on this dialogue, we defined four research questions:

(1) What is the meaning of the word for ‘participation’ in different languages and contexts?

(2) Which word(s) or term(s) may be used instead?

(3) What does not count as participation? and

(4) What consequences do these understandings of the terms used have for practice and implementation?

To investigate these research questions, data collection took place during one open N25 ECER discussion forum in August 2023. Ethical approval was secured from the [university] ethics committee. The forum began with short presentations by Hanna, Moody and Perry-Hazan on how the term ‘participation’ is understood in three languages and contexts: English in the four UK devolved nations; Swiss French in the Swiss federal context; and Hebrew in the Israeli context. Following the presentations, data was collected using an interactive, structured dialogue facilitated by Gillett-Swan. Participants were given time to reflect on the meaning and use of the term ‘participation’ – or equivalents – in their context and language(s). Subsequently, participants distributed themselves amongst four groups to promote wider representation of languages and contexts, which resulted in four different languages or contexts being present in each group. During these conversations, the four groups explored dictionary definitions, the colloquial use, and implementation in education law, policy and practice (if at all) of the term “participation”. These discussions were summarised and recorded as data on posters by Hanna, Moody, Perry-Hazan, and Heard. The posters were subsequently transcribed and digitised by Hanna. Both in the workshop and throughout the later stages, we used a process of “analysis through discussion” (Lahelma et al., 2014). Originally developed in ethnographic research, it proved productive in our project carried out by a diverse, international team, as it allowed us to draw on our distinct national, cultural, disciplinary and linguistic perspectives in order to question each other’s assumptions and offer alternative interpretations, thus arriving at more thorough and nuanced observations.

The complexities to which this paper attends began to arise when the researchers individually reviewed the data to identify codes and came together as a group to share their analyses and construct a coding tool. At this stage, we recognized the need to untangle the complexities we identified and dedicating our subsequent meetings to their discussion.

Complexities of translating and comparing the significations and meanings of ‘participation’

Identifying the relevant word(s) within multiple semantic fields

The first complexity we encountered in our research was identifying the relevant word(s) in each language as they were embedded in multiple semantic fields. The semantic field is a group of words, linked by meaning, that centre around a common term or concept. For example, a commentator for the Giro d’Italia may use cycling terms such as time trial, sprint, peloton, break away and drafting. In our project, the common term was ‘participation’ and its translation into different languages. We discovered that the translated term for ‘participation’ was often not the most commonly used. In other languages, the semantic fields of the terms in use did not correspond to the semantic field for participation in English (e.g., participation, take part, voice). Furthermore, in some languages, several different words captured the nuances of the term participation. Most scholars in the project confirmed that Article 12 of the UNCRC is regularly considered a foundation for the broader notion of child ‘participation’ within their own linguistic and cultural contexts. Nonetheless, they noted the tension between translating the word ‘participation’ across different languages and the alternative, sometimes multiple, terms used in different linguistic and/or legal contexts.

Clarification about which word was being studied and its signification was necessary in any attempt to analyse its meaning. For instance, in Polish, ‘participation’ can be translated into three different words (i.e., udział, uczestnictwo and partycypacja), all of which are used in the field of education. The term udział, whilst referring to “participating in something, is really just about being present.” Uczestniczyć, on the other hand, “can also mean to take part in a more meaningful, purposeful way to have some influence”. The Polish partycypacja, however, is a newer term that refers to “shared responsibility for the course of whatever you’re involved in”. According to a Polish participant in our structured dialogue, this word is “more political, so in the sense that… having influence would be clear”. In Swedish, up to seven different words can be found in dictionaries to translate the term; however, only four are used in education. A Swedish participant in the structured dialogue observed that two words used for participation in Swedish “do not exist in English”. The Swedish delaktighet, means ‘being part of’ and ‘included in’; inflytande means ‘influence’.

Reference to the signification of participation was further problematised considering other terms used in place of participation, such as voice and engagement, which could “delete the… meaning”. Another participant summarised this aptly:

I think that the most important thing that… we learned [is that] there are languages where participation doesn’t have influence in it. Then maybe you need student voice and other terms which are actually… damaging because they don’t reflect what we mean when we talk about participation, rights and other languages where the influence is… in the word.

This captured the complexity and difficulty of our task; one participant observed that “it’s hard, isn’t it? Trying to define an English word using concepts. It’s not just vocabulary. It’s defining it using concepts. So, you live that word. However, I don’t have experience with that word. So, it’s hard to translate”. Methodologically, the semantic field of these translations made the term ‘participation’ so fluid that conceptual clarity was impossible.

Unpacking the various meanings of participation in contexts

In addition to the complexities of identifying the relevant semantic field and defining the signification of the relevant terms, we understood that the signification of these terms is not always aligned with their meaning; one participant laughed when asked if teachers spoke about participation in educational discourse, responding “if they do at all”, before clarifying that the term was “very common because you go to class, so you take part in education, but it doesn’t have the sense of the right to be heard”.

This required a closer look at the Who and the What (e.g. type of discourse) of our endeavour. Was the focus on the meaning of ‘participation’ for a layperson, for an education professional (e.g., a teacher, a principal, etc.), for children themselves, or a child rights scholar? Did our project examine how national policy discourses define or use the term or how practices allow its implementation? The unpacking of these two complementary dimensions raised further questions about whether we were focusing on the international legal meaning of the term – whether it is based on the UN language or one of the above-mentioned scholarly models – and its implementation or on the different words prevalent in diverse languages and contexts.

Acknowledging variation of meanings should not prevent researchers from looking for constant relevant features or identifying the core signification of the term ‘participation’, beyond the contexts in which it is used. Data from the workshops suggest that ideas of ‘being present’ or ‘taking part’ will likely cover a part of the meaning in most of the languages included in this exploratory study. Swedish and German languages have two words to cover these deltagande, teilnahmen (take part/being present) and delaktighet, teilhaben (being part of/included in). In Hebrew, hishtatfut means one of two things: taking part in non-mandatory activities (e.g., extracurricular) and taking an active role in classroom activities. In Latin languages and education contexts, participation (French), participazione (Italian), participaciò (Catalan) refer to taking an active role in activities. Highlighting these variations of meanings is crucial to improve the general understanding of the terms studied by taking into account subtleties or nuances hitherto unknown or obscured.

Considering translation operations of participation as a right

Identifying the signification of the word ‘participation’ and unpacking its meanings in various contexts led to another level of complexity related to the notion of translation itself. Indeed, several translation operations may occur simultaneously, particularly considering that languages are interdependent, and exchanges across various cultural and linguistic contexts have continuously influenced evolution in the matter. Cultural transfer theory (Espagne, 2013) assists in understanding these processes by proposing that these exchanges are mediated by individuals or groups functioning as intermediaries or facilitators in the process of selective adaptation of foreign elements to fit new cultural paradigms. A Russian participant in one of the workshops clarified this process when asked whether the term participation, translated as Uchastiye, was used with the idea of “driving change” for children: “It gained this meaning as well nowadays. So, this is still a very broad term, but these days, it has gained these [political] connotations”. In the structured dialogue, a German participant highlighted that the direct translation of participation is Partizipation, which “is often used in the sense of having a part in decision making and a democratic sense”, but teilnehmen, meaning ‘attending’ is used “when you want to talk about how many children attend school”. Teilhaben is used to mean ‘involvement’ and ‘engagement’. These three terms, however, “are used interchangeably… when you talk about participation and education in German, you have to describe what you mean with this term, so it is not confused”, highlighting the fluidity of signification and meaning and how they fold into one another.

When it comes to human rights, a more vertical translation process co-occurs. Research has shown that human rights terms or norms are translated within and throughout the implementation process (I’Anson et al., 2017; Hanson and Nieuwenhuys, 2012; Robinson et al., 2020). I’Anson and colleagues (2017) identify up to five successive stages of translating the UNCRC into policy design and professional practice in what they named an International Economy of Children’s Rights. By so doing, they highlight that the principles of the UNCRC progressively grow distant from the original wording through the incorporation and reshaping of national jurisdictions.

An example is how, in Northern Ireland, a 2014 Department of Education circular frames participation as “the opportunity [for children] to voice their opinions and have a real say in decisions that affect their lives in schools and within their local community” (Department of Education, 2014: p. 4). This highlights the incorporation of some of the exact wording of Article 12 of the UNCRC in national jurisdictions (see our italics). Also, it suggests how such incorporation is context-dependent; here, it may be due to some influential actors, ¹ given that other nations in the UK do not share this translation of ‘participation’. Indeed, when analysing the incorporation of Article 12 in all UK education legislations, Robinson et al. (2020, p. 533) found that:

principles relating to children being informed about matters and being supported to understand that they have a right to express their views, as well as given opportunities to do so in verbal and non-verbal ways, undergo reshaping and narrowing during their translation into education legislation.

Beyond formal policymaking and implementation, anthropologists also highlight that international norms are not merely translated into ‘local’ linguistic or cultural categories. Merry’s ethnographic work led to theorising ‘vernacularization’ as a process through which “human rights language is […] extracted from the universal and adapted to national and local communities” (2006, p. 39). Like Espagne (2013), she underscores a key dimension of the process: the people in the middle, translators or intermediaries who “refashion global rights agendas for local contexts and reframe local grievances in terms of global human rights principles and activities” (Merry, 2006: p. 39; see also Goodale, 2024).

Translation processes are, therefore, multiple and dynamic, and our project highlights that this is notably the case in the fields of children and human rights law. Research carried out to uncover the various meanings of ‘participation’ should, therefore, pay due attention to reinterpretations, refashioning, and reshaping transnational perspectives as well as to the translators themselves.

Negotiating ambiguities in development of the coding tool

The practical implications of the above complexities resulted in two main difficulties relating to constructing a robust and conceptually coherent coding tool. The first difficulty relates to the complexity of identifying the relevant words in multiple semantic fields (subsection 4.1). In seeking to understand the significations and meanings of ‘participation’, we tried to break it down into discrete terms for coding, which, we discovered, had no consensus or shared meaning. For example, in an initial coding framework, we utilised the term ‘inclusion’, which we later abandoned because the term is extremely broad; it could be understood as the right to non-discrimination in decision-making, but others understood this as restricting the meaning to ‘access’ instead of a feeling of belonging and being listened to in a decision-making space.

This challenge led us to consider other terms that may better reflect the meaning of participation rights, for example, voice. However, this is also a vague concept that is not used in all languages, and one that does not carry an explicit reference to decision-making. Indeed, as one participant pointed out, student voice as a term was “problematic” because “in many places [it had] become just about [children] using the voice but not necessarily anything happening with that”. Implicitly, the term voice was suggested as a more benign term than ‘participation’ by one discussant who suggested that if using the term ‘participation’ in England, “you won’t get in the door” because it carried connotations of adults “losing control”. Participation was, therefore, an inherently ambiguous term, frequently understood as an exercise or activity that was exhibited by young people “turning up” and “raising hands” but which fell under teachers’ remit of pedagogy. This was echoed by another participant who recalled her professional practice in teaching: “To me, participation was about children raising their hands and participating in the classroom. So, when I hear about this voice… it’s hard for me to understand that and to shift what I have been taught and how I saw participation as a teacher”.

The second difficulty with the coding tool relates to a mixture of the significations and meanings of participation in participant discussions. This is directly connected to the second complexity of unpacking the various meanings of participation in contexts (subsection 4.2). During the analysis, there was no consensus on the component terms of participation for a coding tool, eventually identifying that one cause of incertitude in discussions about participation was that some discussed the signification of participation, whereas others focused on its contextual meaning in education.

This posed a major challenge when constructing the coding tool because comparison became futile between languages and translations. One example is the code of ‘autonomy’, which arose from references in the data to participation as ‘political’. Under Article 12 of the UNCRC, children have the right to express their views and for those views to be given ‘due weight’ in accordance with their age and maturity, which in the participation literature has become synonymous with ‘influence’ (Lundy, 2007). This right was agreed upon in recognition of the traditional denial of legal autonomy in decision-making to children and established an obligation to build children’s capacity in decision-making instead of the traditional focus on their lack of competence (Daly, 2018). The text, therefore, makes explicit reference to children having their views weighted and implicit reference to the role of autonomy in ensuring this influence (Daly, 2018). The context in which this is understood, however, adds further complexity. As the Russian participant underlined above, participation can be politically charged due to “wider political events”, suggesting that children’s participation can reveal and test broader political contexts, particularly where any participation tends to be “adult-led and organised”. This prompted a debate in the structured dialogue about Greta Thunberg’s child-led climate change campaign and the “opposition to children participating in this manner”.

This challenge was compounded when we considered that even within the English language, there is a difference between signification and meanings depending on jurisdictions, which directly relates to the third complexity above, suggesting the various translation operations should be considered (subsection 4.3). For example, participation in education in England is understood as attendance or presence, “bums on seats”, but in Scotland, where the Scottish government had incorporated the UNCRC, participation is understood in policy as “all of the ways in which children and young people engage in action, practices and dialogue with adults… to create positive outcomes” (Scottish Government, n.d.) with one of the benefits listed as ‘autonomy’.

The realisation in the structured dialogue that ‘signification’ and ‘meaning’ are not dichotomous or mutually exclusive demonstrated that our task was not “just a translation, but rather trying to unpack the policy, the discourse, the practice and all the assumptions underneath”. Attending merely to translating terms as words, in instances where “you don’t have the vocabulary… to explain it or the experiences of that… makes it harder to understand”. One person suggested that the purpose of participation may be more helpful in examining its meaning: “to start from the purpose before the vocabulary”.

Cautious conclusions and directions for future research

The complexities analysed in this paper highlight that understanding and comparing the meanings of the term ‘participation’ in education across different linguistic contexts requires empirical interdisciplinary research with diverse participants. Yet, our exploratory research led to some preliminary conclusions, which may constitute a basis for such research. One of these conclusions concerns the gap between the signification of participation in the UNCRC and children’s rights scholarship and the meanings of the term ‘participation’ in education in most countries and languages. The signification of participation in the UNCRC and related scholarship includes influence, in accordance with the “due weight” requirement in Article 12 of the UNCRC. However, discussing the meanings of the term participation and its uses in context revealed that the ideas of ‘influence’, ‘civic involvement/engagement’ or ‘activism’ are marginal. Interestingly, a range of words across languages exist to describe such ideas: meoravut to describe civic involvement in Hebrew, and the Latin-derived partycypacja, the novel Polish term referring to engagement and influence, and partizipation, in German, to describe the process through which individuals are actively and significantly involved in all decisions that affect their lives. The only exception is Sweden, where the word inflytande (influence) is part of the lexicon connected to the idea of ‘taking part’ in educational contexts, as well as in other contexts.

Another preliminary conclusion is that the meaning of the term participation in education is often associated with compulsory activities. It became clear to the authors that instead of building young people’s capacity to participate as a human right, their ability to consent to it is removed and participation, understood as ‘being present’ or ‘taking part’, becomes compulsory; such contextual ‘meaning’ of participation in many school spaces is thus as an exercise or activity. By framing participation as an individual responsibility or unquestionable benefit for young people – a performative concept – their choice to consent (or not) is removed. This understanding of participation contradicts the common interpretation of participation rights in the UNCRC, as including the right not to participate (Hanna, 2024; Perry-Hazan, 2021).

What our work to date reveals is that understanding participation is far more complicated than it might initially appear. While there is some level of common general understanding about the term, nuance is important to ensure that practitioners and scholars working in this space have the same foundational understanding of the concept in what it means and looks like, but also with what it is not. A next step for inquiry could include seeking the perspectives and experiences of children and analysing how children in different linguistic, national and international contexts understand and experience the concept of ‘participation’ both in school and in out-of-school contexts. Such work with could build on the important work of Graham et al. (2018), who explored how participation is perceived and practised in Australian schools and concluded that participation was, or could be, experienced in four key ways: as having voice, as having influence, as making a choice, and as a process of working together. It is particularly important to examine the terms children would use to explain and portray the different presentations of participation identified across various national and international contexts, and how this might inform a shared understanding of what participation is and what it is not. Future research might also involve educators, education leaders, or policymakers to determine whether the practical unravelling of the term for different potential users and implementers changes its meaning.

Bringing these ideas together with what we have already started doing could also provide the opportunity for comparative nested case studies (Chong and Graham, 2016) that compare perspectives and experiences of different stakeholders (e.g. children of different ages, educators, education leaders, policymakers, academics) within and across different national contexts (e.g. primary, secondary, public, private, religious schools, independent) and jurisdictions (e.g. metropolitan, regional, remote, different states/provinces). The case studies could draw on different national and linguistic contexts, representing different significations and meanings of participation. We learned that we should have a large sample in each country because of the inherent heterogeneity within each national context. We also learned that both quantitative and qualitative methods would be required to fully unpack how participation is understood and to compare the findings across case studies. There is also an opportunity to explore the term from different disciplinary perspectives. For example, how (if at all) does the meaning change when viewed from a legal, philosophical, linguistic, or economic perspective compared to an educational one? The field of children’s rights in general, and participation rights in particular, is unique in that it is both inter- and trans-disciplinary. Indeed, participation rights are embedded in many social fields – both public and private - and institutional spaces such as the family, courts, schools, health services, social services and decision-making fora at several political levels. Through this study, and through the interdisciplinarity of our research group, we learned that all of these domains may constitute different meanings of participation. These directions provide just a few of the many other potential entry points for further inquiry based on the unravelling that we have started to do in the exploratory work detailed in this paper.

Ultimately, the gaps we identified between the signification of participation in the UNCRC and its contextual meanings may explain why participation rights in education are poorly implemented. These gaps also prompt the question of whether participation is the most appropriate term to describe Article 12 or its current legal translations (e.g., United Nations Committee on the Rights of the Child, 2016). As a provocation, we can question if the whole participation idea is part of the ‘pedagogisation’ of childhood process (see Schreuder and Dekker, 2013) or if it can support better and fuller realisation of children’s rights.