LGBTIQ+ Human Rights and Illiberal Challenges to the Liberal International Order

Scholarship interrogating contemporary contestations over LGBTIQ+ human rights shows that “anti-gender” or “anti-feminist” politics have been central to the national and multilateral policy agendas of illiberal populist regimes in diverse regional contexts. As Grzebalska et al. (Reference Grzebalska, Kováts and Pető2017) write, illiberal populist “anti-gender” actors use the terms “gender” and “gender ideology” to describe and denigrate LGBTIQ+ identities and rights, sexuality education, reproductive rights, and gender and sexuality studies, and as so-called failures of liberal democracy (6).

Scholars have made strikingly consistent observations across diverse regional contexts that anti-gender politics express opposition against sexuality and gender equality, and more broadly, dissatisfaction with liberal democracy and the global dominance of the West (Ayoub and Stoeckl Reference Ayoub and Stoeckl2024a; Edenborg Reference Edenborg2023; Korolczuk and Graff Reference Korolczuk and Graff2018). Within what many consider to be a new era of illiberal populism, “gender” has come to function as a “symbolic glue” that connects a range of counter-hegemonic narratives against liberal democracy (Pető Reference Pető, Sajó, Uitz and Holmes2022, 318). For these reasons, as Korolczuk and Graff (Reference Korolczuk and Graff2018) argue, contemporary conservative opposition against reproductive and sexual rights transcends categorization as an anti-feminist and anti-queer “backlash” and can be more accurately understood as a new transnational “ideological and political configuration” altogether (815).

As scholars writing on anti-gender politics uncover the illiberal motivations behind contemporary movements against sexual and reproductive rights, IR scholars increasingly attend to the normative challenges that rising autocratic and illiberal powers are posing to the LIO as “a distinctive type of order, organized around open markets, multilateral institutions, cooperative security, alliance partnership, democratic solidarity, and United States hegemonic leadership” (Ikenberry Reference Ikenberry2010, 512). While scholars disagree about what is “liberal,” “international,” or “ordered” about the LIO (see Lake et al. Reference Lake, Martin and Risse2021), there is a prevailing sense that institutions, norms, and rules based on multilateralism, free trade, and individual rights are facing unprecedented challenges, and may even be in a state of “crisis” (Deitelhoff and Zimmerman Reference Deitelhoff and Zimmermann2019; Ikenberry Reference Ikenberry2018). The nature and trajectory of this crisis are also contested, but scholars widely cite the Eurocentric foundations of the LIO and the systemic inequalities it has inscribed within the international order as the primary causes of growing discontent (Acharya Reference Acharya2017; Deitelhoff and Zimmermann Reference Deitelhoff and Zimmermann2019; Epstein Reference Epstein2012).

The sense that the LIO is in a full state of crisis has been tempered, in some instances, by doubts that the diverse array of illiberal powers can develop and offer a coherent alternative to the existing order. However, Michelsen et al. (Reference Michelsen, de Orellana and Buranelli2025) show that alliances between new right politicians in democratic and authoritarian states are, in fact, “solidifying into an international compact that advocates radical normative change in international relations” (1). According to the authors, this “radical normative change” is centered on the constitutive principle of “birth-cultural sovereignty,” which predicates sovereignty on national identity conditioned by birth (1–2). Imagining gender as “governed by biology and innate birth-religion,” the authors show that new right actors are emphasizing traditional roles for women, and denouncing homosexuality and gender non-conformity as attacks on traditional values, traditional families, and national sovereignty. According to Michelsen et al. (Reference Michelsen, de Orellana and Buranelli2025), this “birth-culture” theory of nationhood has provided a common ontological frame and shared discourse that is coherent enough to provide an alternative to the LIO but flexible enough to accommodate diverse cultural, historical, and societal conditions (9–10).

Bettiza and Lewis (Reference Bettiza and Lewis2020) make a similar observation in their study of conservative soft power, arguing that narratives about “traditional values” and “family protection” are being used by illiberal actors to create “alternative non-liberal particularistic identities and moral orders” that undermine the global validity of democracy, human rights, and the liberal order (569). These findings echo those made by researchers studying anti-gender politics that contemporary opposition against sexual and reproductive rights is more than “backlash,” but a critique of liberal democracy that is advancing ethnonationalist narratives of “traditional values” to unite diverse and geographically disparate actors and constitute a coherent illiberal vision of international order.

Existing literature therefore indicates that LGBTIQ+ human rights, along with reproductive rights and gender equality, have become a key battleground upon which competing visions of international order are being waged. While existing scholarship has examined anti-Western and anti-colonial rhetoric in African anti-LGBTIQ+ politics (e.g., Currier Reference Currier2010; Awondo et al Reference Awondo, Geschiere and Reid2012; Ndjio Reference Ndjio2012; Nyanzi Reference Nyanzi2013; van Klinken and Chitando Reference Van Klinken and Chitando2016; and others), this article differs by situating such rhetoric within critical constructivist debates on norm violation, hierarchy, and international order, treating these discursive practices as strategic interventions in global status politics.

LGBTIQ+ Human Rights Norm Contestation in Multilateral and Bilateral Diplomacy

Prior scholarship has noted that the recognition of LGBTIQ+ rights has become increasingly accepted as an international norm over the past two decades (e.g., Thoreson Reference Thoreson2009; Langlois Reference Langlois, Bosia, McEvoy and Rahman2019). Yet, rather than transcending its status as a “candidate” norm to reach a tipping point as Finnemore and Sikkink’s (Reference Finnemore and Sikkink1998) model of the norm life cycle would anticipate, LGBTIQ+ human rights have become a fault line of international polarization “in which two groups of states have adopted conflicting norms, and have clashed repeatedly over them” (Symons and Altman Reference Symons and Altman2015, 62). As Clifford Bob (Reference Bob2012) has shown, these polarizing dynamics have been brought about by a “baptist-burqa” network that has formed between US Christian Right actors and conservative Islamic states who are aligned in their opposition to gender equality, LGBTIQ+ rights, and sex education. As Sanders and Jenkins (Reference Sanders and Jenkins2022) show, the Africa Group at the United Nations (UN) has become increasingly influential in this coalition of oppositional member states.

Scholars have used the notion of “norm spoiling” to describe the coordinated efforts underway to undermine women’s rights and LGBTIQ+ rights at the UN (Goetz Reference Goetz2020; Sanders Reference Sanders2018). This involves changing and removing language in UN documents to delegitimize gender equality, sexual and reproductive health rights, and LGBTIQ+ rights, often by advocating cultural relativism and “traditional values” and appropriating anti-colonial critiques of women’s rights (Goetz Reference Goetz2020, 171; Sanders Reference Sanders2018, 273; Sanders and Jenkins Reference Sanders and Jenkins2022, 406). However, as Sanders and Jenkins (Reference Sanders and Jenkins2025) argue, norm spoiling alone cannot achieve durable normative transformation. Rather, anti-feminist and anti-LGBTIQ+ actors have increasingly shifted from breaking or spoiling norms to engaging in what they conceptualize as “reactionary international norm building”: efforts to replace established rights with rival norms grounded in retrotopian imaginaries of tradition, family, and civilization, and to institutionalize these alternatives within international governance (609–611) As Symons and Altman (Reference Symons and Altman2015) observed nearly a decade ago, opposing networks of actors “for” or “against” LGBTIQ+ rights have taken shape in multilateral governance, creating a process of “norm polarization” between “states seeking to make sexual orientation a subject of human rights protection, and those which resist this move in the name of tradition, culture, and religion” (65).

In addition to contesting the norm of LGBTIQ+ human rights within multilateral institutions, bilateral diplomacy is also a site where contestations over LGBTIQ+ human rights are underway. Bilateral diplomacy, which manages relationships between individual states, is widely regarded as the core of international relations in that it involves the promotion of national interests and structures international negotiations (Pannier Reference Pannier, Balzacq, Charillon and Ramel2020, 20). Literature engaging with bilateral norm contestations over LGBTIQ+ human rights has largely focused on questions of how, if at all, international actors should respond to LGBTIQ+ human rights abuses in foreign states. These questions have become increasingly pertinent and challenging for diplomats, academics, activists, philanthropic organizations, politicians, international organizations, and financial institutions (Brown Reference Brown2023; Dasandi Reference Dasandi2022; Janoff Reference Janoff2022). Existing studies primarily focus on the global power dynamics that have transpired as Western governments and international financial institutions publicly condemn and negatively sanction states in the Global South for passing anti-homosexuality legislation (Brown Reference Brown2023; Cheeseman et al. Reference Cheeseman, Swedlund and O’Brien-Udry2024; Encarnación Reference Encarnación2016; Rao Reference Rao2015, Reference Rao2020). Scholars have also revealed the forms of anticipatory counter-mobilization (Wahab Reference Wahab2016) and norm immunization (Nuñez-Mietz and Iommi Reference Nuñez-Mietz and Iommi2017) that some states have exercised in their rejection of LGBTIQ+ human rights.

This literature reveals that contestations over LGBTIQ+ rights are shaping relations between states, showing that highly visible interventions by Global North governments in the form of public condemnations, aid conditionalities, and economic sanctions have not achieved their desired outcomes. Scholars have shown that these foreign policy measures have been counterproductive in their contribution to strengthening the ability of anti-democratic governments to claim that LGBTIQ+ identities and rights are neo-imperialist, fueling illiberal claims about the incompatibility of human rights with local traditions and beliefs (see Wahab Reference Wahab2016; Ayoub and Stoeckl Reference Ayoub and Stoeckl2024a; Brown Reference Brown2023; Encarnación Reference Encarnación2016), and performative in what these measures do to construct new civilizational narratives that are hypocritical, given the abuses that LGBTIQ+ people have faced in the Western democracies both historically and currently (Puar Reference Puar2018; Rao Reference Rao2020; Weber Reference Weber2016). At the same time, scholars acknowledge that ignoring the legislation and continuing to provide aid to governments that threaten the human rights of sexual and gender minorities is not necessarily a more legitimate, or “decolonial” option. As Brown (Reference Brown2023) argues, “remaining silent on LGBTQI+ rights and by extension other human rights, while continuing to provide financial assistance (and perhaps political and military as well) is also a form of external intervention – in support of an abusive government” (510).

Although these findings have advanced knowledge about how contestations over LGBTIQ+ rights are occurring between states, they do not typically engage with these as cases of norm contestation per se. Except for Nuñez-Mietz and Iommi (Reference Nuñez-Mietz and Iommi2017), who set out the theory of “norm immunization” to describe efforts by some states to create legal barriers to norm diffusion and internalization (196), most analyses have studied and problematized the ways in which Western governments and international financial institutions have incorporated LGBTIQ+ human rights into their foreign and institutional policies. Yet, for many years, constructivist IR scholars have demonstrated the centrality of norm dynamics and contestations within international order and hierarchy (Finnemore and Sikkink Reference Finnemore and Sikkink1998; Towns Reference Towns2010; Wiener Reference Wiener2018; Wunderlich Reference Wunderlich2013), signaling the need to further interrogate the norm dynamics at work within international contestations over LGBTIQ+ human rights within and beyond multilateral arenas. Specifically, this field of literature has created possibilities for recognizing how less powerful states leverage normative power in international politics and assert themselves as influential global actors (Bettiza and Lewis Reference Bettiza and Lewis2020; Fung Reference Fung2023; Hurrell Reference Hurrell2006; Kenkel and Cunliffe Reference Kenkel, Cunliffe, Kenkel and Cunliffe2016; Kurowska Reference Kurowska2014; Larson and Shevchenko Reference Larson and Shevchenko2010; Towns Reference Towns2010; Towns Reference Towns2012; Xiaoyu Reference Xiaoyu2012).

Challenging the notion that norms are exclusively diffused by major powers, critical constructivist IR theory shows that low-status states may engage in competitive norm entrepreneurship and contestation as a strategy to rise in the international hierarchy (Towns Reference Towns2010). Ann Towns (Reference Towns2012) shows, for instance, that the diffusion of legal gender quotas aiming to change the gender composition of national legislatures developed primarily out of Latin America in the 1990s (181). In adopting and advocating for the use of quotas in political representation, and subsequently producing more women legislators, peripheral states in Latin America and beyond (including Uganda), signaled that they were modern, transparent, and democratic, increasing their status in turn (199). In addition to showing that norm diffusion “from below” occurs within international politics, these findings show that to study norms is also to study status, hierarchy, and international order (2010, 8).

Critical norms literature has continued to demonstrate that norm contestation, especially in the areas of gender and sexuality, has become a crucial means through which lower-ranking states critique the West and, in doing so, challenge international hierarchy and its constitutive norms and structures. For instance, in their study of the effects of emerging autocratic powers on global gender equality norms, Jacob et al. (Reference Jacob, Scherpereel and Adams2017) conclude that the rise of countries like China, Russia, and India may undermine progressive global norms (i.e. gender equality, human rights, minority rights, and LGBTIQ rights) “that established powers tend to recognize and emerging powers tend to flout” (803). As powers seen as “hostile to Western visions of Order,” Russia and China have become recognized by numerous IR scholars as leaders of a twenty-first-century “autocratic revival” (Ikenberry Reference Ikenberry2010, 510). Unlike twentieth-century authoritarian states, they have adapted to global capitalism, while remaining anti-liberal and hostile to Western democracy, effectively finding “a pathway to modernity and development that bypasses liberal democratic practices and institutions” (510). Despite the emergence of new anti-homosexuality legislation in some African countries and anti-Western political sentiment in many countries in the region, little has been said about how, if at all, African states may be contributing to the perceived “autocratic revival” and the significance of emerging legislation therein. This article therefore treats the highly visible international contestations that surrounded the Ugandan Anti-Homosexuality Act as an entry point for interrogating how one African state is engaging in LGBTIQ+ norm contestation and challenging international order and hierarchy.

LGBTIQ+ human rights, reproductive rights, and gender equality have been flagged as norms facing significant challenges “from below,” creating the pathways discussed by Ikenberry as the means through which illiberal states are challenging international order and hierarchy. Existing research reveals that opposition to LGBTIQ+ rights has become a key mechanism through which states that rank lower in the international hierarchy are attempting to assert a rival set of norms and ordering logic that will ultimately enable them to rise in status. As Ayoub and Stoeckl (Reference Ayoub and Stoeckl2024a) argue, while there has been a prevailing assumption within norms literature that small and medium-sized states and declining powers are likely to aim for status “by being conspicuously good or moral actors,” opposition to LGBTIQ rights and adherence to the traditional values agenda is also becoming a basis for asserting geopolitical status, enabling “some states to gain new purpose and to play a role on the global political stage” through the advancement of ‘traditional values’ in domestic and foreign policy (68).

Norm-Violation

Amidst the rise of these, and other, challenges to the normative underpinnings of the LIO, IR norms scholars have become increasingly attuned to the wide range of practices that can be broadly categorized as “norm-violation.” The flip side of norm compliance, norm violation, refers to instances in which state and non-state actors do not adhere to international norms and may contest the efficacy and/or legitimacy of prevailing norms and institutions (Smetana and Onderco Reference Smetana and Onderco2018, 517). As Smetana and Onderco argue, attention to behaviors considered “wrong” in international society and a focus on the “outsiders” of international politics open avenues for IR research that have remained largely unexplored.

Within literature examining norm violation, scholars have pointed to the shortcomings of approaches that view norm compliance as an inherent good and as an inevitable outcome of the norm lifecycle. Critical IR scholars have problematized the tendency to infantilize and silence the community of states that actively reject certain norms (Epstein Reference Epstein2012; Evers Reference Evers2017; Steele Reference Steele2017; Towns Reference Towns2010; Xiaoyu Reference Xiaoyu2012), showing that unidirectional conceptualizations of norm socialization are unable to explain why states would intentionally and publicly violate international norms, despite anticipated social or material costs for doing so. These projects further reveal and theorize stigma and shaming as central, rather than peripheral, dynamics within processes of establishing norms. As Adler-Nissen (Reference Adler-Nissen2014) argues, if “norms hold international society together,” then shame and stigmatization will also exist, given that stigmatization clarifies the boundaries of acceptable behavior and aims to achieve conformity by distinguishing an “us” (the normal states) from a “them” (the transgressive ones) (149).

Critical constructivist theorization of how, why, and under what conditions states may violate international norms, and the choices they have in terms of how they manage external shaming and stigmatization, provides conceptual tools for understanding the contestations that unfolded in relation to the Ugandan Act. While this literature includes cases in which states violate norms covertly, attempting to hide their noncompliance or contesting the meaning of compliant behavior (see Evers Reference Evers2017, 786), literature addressing public and intentional norm violation is most suited to the case at hand. Within this body of work, researchers have argued that dynamics of norm deviance (Smetana and Onderco Reference Smetana and Onderco2018), transgression (Evers Reference Evers2017), and defiance (Terman Reference Terman2019) should not be viewed as cases of failed socialization, but as relational and performative interactions within international politics.

Constituting Deviance and Spoiling Identities

In their statements condemning the Ugandan government for adopting the Act, state actors demonstrate the two key functions of shaming described by interactionist IR scholars: spoiling the identity of a norm violator to promote compliance and socialization, and reinforcing the norm and the community of norm-adhering states (Adler-Nissen Reference Adler-Nissen2014; Smetana and Onderco Reference Smetana and Onderco2018). As Smetana and Onderco (Reference Smetana and Onderco2018) argue, the act of labeling certain acts as deviant serves two equally significant functions: to reinforce and clarify notions of normality, and to persuade “transgressive” states into compliance and socialization (518). This approach directs attention away from an effort to understand why some states violate norms while others do not, and towards the question of how deviant categories come into being through the community’s reaction (518).

The individual and collective statements issued by state actors invoked a range of operative terms to position Uganda as a deviant state for adopting legislation that criminalizes and denies the human rights of LGBTIQ+ people. Heads of State and MFAs variously described the Act as “heinous” (Canadian MFA), “appalling and abhorrent” (Canadian Prime Minister Justin Trudeau), “shocking” and “grave” (Australian MFA), “draconian” (German MFA), “tragic,” “shameful,” “wrong” (The White House), and as a “failure” that “damages the country’s reputation” (US Department of State). Some statements also referred to the wider national response to the Act in their countries. For instance, the Austrian MFA stated that the country is “appalled” by the Act, while the French MFA stated that the people of France are “deeply troubled” by the legislation. Thus, in their public condemnations, state actors placed the weight of their governments and wider societies behind LGBTIQ+ rights and against the Ugandan government’s decision to enact the law. As interactionist approaches to shaming reveal, such descriptors spoil Uganda’s identity as a deviant and inferior state while, at the same time, asserting the normal and superior status of shamers (Smetana and Onderco Reference Smetana and Onderco2018, 520).

Reinforcing the Community of Normals

Beyond the use of operative shaming terms, external actors reaffirmed their own identity as members of a community of norm-abiding and rights-respecting states. Within their statements of condemnation, several external state actors positioned LGBTIQ+ human rights as a boundary that distinguishes “normal” states from transgressive “deviant” states. For example, in the same statements in which the White House condemned Uganda for adopting the Act, President Joe Biden positioned the US within the community of “normals” who recognize LGBTIQ+ human rights, saying:

Stating that as the President of the US, he joins “people around the world,” Biden invokes a sense of moral cosmopolitanism (see Held and Maffettone Reference Held and Maffettone2017), asserting a larger global community of actors, including people in Uganda, who agree that the Act is “wrong.” This statement asserts the existence of a global community of moral actors who are united by their commitment to LGBTIQ+ human rights and their opposition to Uganda’s Act.

This normalizing dynamic is also evident in the statement issued by the Canadian MFA, which asserted that “Canada stands with the LGBTQ+ community in Uganda and around the world and calls on the Government of Uganda to revoke this law.” The UK MFA similarly remarked that the government is “appalled” by the legislation and that it “will continue to stand up for these rights and freedoms in Uganda and around the world.” The two main functions of shaming — constituting norm-violating outsiders and constituting the community of norm-adhering insiders, were perhaps nowhere more concisely phrased than in a two-sentence statement written by the Dutch MFA, which took the form of a post on X:

While the Dutch MFA statement may have been the most succinct, it was the Equal Rights Coalition (ERC) statement that most reflected the normalizing imperative of shaming. As an intergovernmental organization comprised of member states that cooperate with civil society, multilateral agencies, and other stakeholders to advance LGBTIQ+ human rights, the existence of the ERC serves as a formal organization that represents the community of “normal” states that adhere to LGBTIQ+ human rights. In the ERC statement, thirty-two co-signing member states expressed “grave concerns” about the “draconian” Act, calling “for the Ugandan government to protect its citizens, no matter their sexual orientation or gender identity.”

As state actors invoked strong operative terms to shame the Ugandan state for adopting the Act, they also ignored the well-documented role of far-right Western actors in promoting anti-LGBTIQ+ legislation in Uganda (see Kaoma Reference Kaoma2009; McEwen Reference McEwen2023; Oliver Reference Oliver2013; Sharlet Reference Sharlet2010; Titeca Reference Titeca2024) and its colonial origins. Such omissions are particularly striking in the case of the US statements, given the widely recognized leadership role of US Christian Right activists and organizations in financing and coordinating anti-LGBTIQ+ agendas in Uganda and other African countries. Notably, acknowledging these foreign influences would have implicated Western liberal states (and the US in particular) in the legislation they sought to shame, complicating their claims about Uganda as a deviant “other” and themselves as norm-abiding. This selective invocation of norm-violation reveals that shamers were less concerned with universal accountability and more with fortifying the legitimacy of the existing order and the norm-adhering community that upholds it. The omission of colonial history and erasure of US Christian Right influence in Uganda further reveal the normalization and boundary-drawing functions of shaming, which are necessary for shamers to maintain the appearance of coherence and adherence to the liberal democratic norms and order they aim to reinforce.

Positioning LGBTIQ+ Rights in the LIO

In addition to shaming Uganda and affirming their positions as “normal states,” several state actors also invoked a set of established norms, showing that the norm of LGBTIQ+ human rights is connected to a network of established norms. This finding reveals the strategy of using adjacency claims, or path dependence (Finnemore and Sikkink Reference Finnemore and Sikkink1998, 908), showing that LGBTIQ+ human rights are related to the established norms of democracy, public health promotion, and international law. The UK, Australia, and the White House cited the consequences of the Act for the securitization of the HIV/AIDS pandemic, a norm that emerged in the 1990s (see Vieira Reference Vieira2007); the UK and France pointed to the Act’s violation of Uganda’s international agreements and its own constitution; and, the statements issued by Canada, France, Norway, and the UK condemned the law’s inclusion of capital punishment. In these statements, state actors pointed to the network of liberal norms that Uganda is violating through legislation that criminalizes LGBTIQ+ people, advocacy, and representation. In doing so, they strengthen and reinforce the norm of LGBTIQ+ human rights as an important component of the LIO and its normative foundations, embedding LGBTIQ+ rights into the normative architecture of the LIO.

Although economic sanctions and aid conditionalities have been commonly used as “hard power” strategies to persuade governments to recognize LGBTIQ+ human rights, most state actors did not explicitly refer to the economic costs of the Anti-Homosexuality Act in their individual statements. The prevailing reticence to make direct references to economic penalties could be an indication that state actors have learned that such statements have been counterproductive in the past (see Dasandi Reference Dasandi2022). The US was an outlier in this regard, referring to the consequences of the law for Uganda’s participation in the global economy, existing trade agreements, and for its citizens to enter the US. President Biden warned:

Indicating the repercussions of the Act for bilateral trade cooperation between the US and Uganda, Biden warned that the US is in a position to impose economic sanctions that will be consequential for Uganda’s participation and standing in the global economy. The statement continues, elaborating on the consequences of the legislation for trade between the US and Uganda and alluding to the cost of the legislation in dollar amounts: “Our programs have boosted economic growth and agricultural productivity, increased investments in Ugandan businesses, and strengthened our trade cooperation. In total, the U.S. Government invests nearly $1 billion annually in Uganda’s people, business, institutions, and military.” Biden’s statements make clear that economic foreign policy tools were not abandoned altogether, but were selectively deployed to reinforce the norm’s symbolic importance within the LIO. As Terman (Reference Terman2019) suggests and as further discussed in what follows, such punitive strategies threaten to further entrench a state’s commitment to norm violation (9).

Transgressing and Counter-Stigmatizing the West

Uganda was first shamed for LGBTIQ+ human rights norm violation in 2009 when its MPs initially proposed the Anti-Homosexuality Bill (see Dasandi Reference Dasandi2022). This first attempt at passing legislation that would criminalize LGBTIQ+ people and advocacy, and in some instances sentence “offenders” to capital punishment, was met with widespread condemnation by Western state and non-state actors, multilateral bodies, and international financial institutions. Some donor states, including Denmark, the Netherlands, Norway, and the US, reportedly withheld millions of dollars in aid scheduled for Uganda, while the World Bank froze plans to loan Uganda $90m. These experiences would have alerted Ugandan state actors that the revival of anti-homosexuality legislation would result in financial penalties and diplomatic consequences. Yet, despite the high probability that the reintroduction of anti-homosexuality legislation would spark international condemnation and financial penalties, the legislature proceeded to pass the Act in 2023 and Museveni had little choice but to sign it for domestic political reasons, knowing that it was violating a norm and publicly acknowledging its non-compliance in multiple instances. According to Evers (Reference Evers2017), such instances of intentional norm violation, in which an actor publicly recognizes the existence of the norm it is violating, alters its behavior to violate the norm, and publicly acknowledges its noncompliance, constitute norm transgression (788).

Pre-empting Western recrimination for the Ugandan Parliament’s consideration of the 2023 Anti-Homosexuality Act, Museveni warned of the government’s motivation to intentionally breach the norm, saying, “It is the mistake of Western countries. They are the ones who are provoking, because they are really, the English word is insufferable…that’s how you get now a backlash. They are the ones who are provoking all this” (March 1, 2023). Notably, in responding to external condemnation, Ugandan state actors refrained from mentioning specific states or other actors (except for the World Bank), opting to refer to the West and Western countries as a community of interfering foreign actors. In such references, Museveni deploys a different set of operative shaming terms to counter-stigmatize Uganda’s detractors as “insufferable,” “lecturers,” and “imperialists.” In doing so, he simultaneously recognizes and delegitimizes their status in the international order, recasting Western shamers as the deviant actors who violate norms of sovereignty and culture and positioning Uganda as the defender of tradition and order.

Furthermore, in invoking Western states as “insufferable” actors who provoked the decision to pass the legislation, Museveni also calls into view the international audiences who make Uganda’s norm transgression possible. As Evers writes, unlike instances in which actors violate norms in secret, actors who openly transgress norms “require others to enforce the norms and label them as non-compliant” to achieve the desired self-identity (788). Drawing on Becker’s (Reference Becker1963) sociological theory of norm transgression, Evers argues that questions of how and why a state will violate a norm stem from its self-identity within international society and the norms that constrain and define its behavior (786). Thus, while condemning states shamed Uganda as a “deviant” actor to promote compliance with the norm of LGBTIQ+ human rights, Ugandan state actors’ responses made their norm transgression explicit. From this perspective, Museveni’s communicative acts in the face of international condemnation should be understood not merely as expressions of non-compliance, but as part of a performance of intentional norm violation, or transgression.

Defying LGBTIQ+ Human Rights, Compliance Demands, and Order

Further interrogation of Ugandan state actor responses to international shaming reveals an intentional and public refusal to comply not only with the norm itself but with compliance demands by norm-enforcers whose authority is disputed — a phenomenon that Terman (Reference Terman2019) defines as norm defiance. Terman’s (Reference Terman2019) framework suggests that shaming stimulates norm defiance when the shamed perceive acts of shaming as “a deliberate and hostile attempt by the shamer to denigrate the target in a social hierarchy” (7). When shaming is viewed as an effort to denigrate the target’s moral standing and thereby devalue its status within international hierarchy, the target may reject not just the norm but the authority of the norm-enforcer.

Uganda’s strategy reflects this logic, with Museveni’s remarks characterizing the West as a provoker of conflict rather than an enforcer of values and norms. In such a framing, norm defiance becomes an act of dignity, or a positive expression of in-group identity, enabling norm violators to reclaim status in international hierarchy and accumulate political capital, rather than descend in rank and status. Through this lens, Museveni is not a passive recipient of stigma, but an active participant in reshaping the meaning of Uganda’s norm violation, attempting to recast it as a badge of sovereign pride in the face of illegitimate Western pressure.

Norm defiance also contributes to explanations of how external pressures can alter domestic political environments. Within the “two-level game” that plays out between recipient governments and domestic political actors in response to international shaming (Dasandi Reference Dasandi2022), public condemnation may have the effect of constraining leaders from complying with international pressure, while those who demonstrate opposition to norms may be rewarded for claims that they are defending the state’s interests (661). From this perspective, shaming can be seen to create “political opportunities for new actors to demonstrate opposition to norms in ways that would have been less attractive without foreign condemnation” (Terman Reference Terman2019, 10).

Museveni displayed his defiant stance in a televised statement in which he addressed the ruling National Resistance Movement after Parliament had signed the Anti-Homosexuality Bill. In doing so, he expressed a refusal to comply with pressures to recognize international human rights norms, advancing a counter-narrative of deviance, normality, and authority in international politics:

Subverting the deviance-making process against the West by repeatedly asserting anti-homosexuality as a norm and support for LGBTIQ+ rights as deviance, Museveni challenges the legitimacy and status of Western “lecturers” who have attempted to persuade Uganda to recognize LGBTIQ+ rights. In this statement, Museveni reiterates prior remarks in which he asserted that “the Western countries should stop wasting the time of humanity by trying to impose their practices on other people” (March 16, 2023).

First Lady, Janet Museveni (who also serves as the Minister of Education) reiterated similar sentiments, issuing her praise to the Ugandan Parliament “for passing the Anti-homosexuality bill, which empowers Ugandans to resist such evils imposed on our children” (April 4, 2023). In a separate statement, she commented on “the significance of safeguarding African culture & family values against emerging threats” and “concern about the imposition of harmful practices like homosexuality,” telling her followers on X, “these negative influences need to be countered with strategic action” (April 4, 2023).

In another instance, President Museveni drew upon the metaphor of “prostitution” to shame and stigmatize international financial institutions and Western governments, arguing, “They want Africans to be prostitutes. Do what we don’t believe in because we want money” (Museveni, April 20, 2023). Drawing on the familiar anti-gender characterization of Western democracies and multilateral institutions as morally depraved global actors who seek to impose their sexual immorality upon others, Museveni counter-stigmatizes Western actors as the actual norm transgressors, equating them with “pimps” or “johns” who are using financial coercion to tempt an economically less powerful Uganda into accepting behaviors that they “don’t believe in.”

In the Ugandan government’s first detailed comments after Museveni signed the Act into law, its Minister of Information echoed the message that it is the resource-rich “Western world” that is transgressive and deviant:

Constructing the West, and its attempts to convince Uganda to remove the legislation as corrupt, Ugandan state actors counter-stigmatize their Western detractors, undermining their authority to make compliance demands on Uganda. Museveni reiterated these counter-warnings, posting on X, “I want to inform everybody, starting with Ugandans, that Uganda will develop with or without loans… It is, therefore, unfortunate that the World Bank and other actors dare to want to coerce us into abandoning our faith, culture, principles, and sovereignty, using money.” (Museveni, August 9, 2023). This post reinforces Museveni’s prior statements that defy Western compliance demands, positioning Uganda as a superior moral actor willing to pay a financial price to remain committed to its values.

While scholars have noted that counter-stigmatization tends to be a strategy of stigma management primarily used by powerful states “who feel they can ignore international shaming” (Adler-Nissen Reference Adler-Nissen2014, 154), Ugandan state actors used this strategy to assert their status and adherence to the anti-gender norms of compulsory heterosexuality, envisioned as central to the maintenence of state sovereignty, by positioning the Western stigmatizers as the deviant actors.

International Support for the Anti-Homosexuality Act, 2023

These responses to the normative pressure applied by Western actors reveal that the Act extends beyond a case of norm violation, revealing that the ongoing Western shaming of Uganda as a deviant state has transformed into transgression and defiance. Furthermore, as the Ugandan President and Information Minister issued statements of defiance against Western norms and pressures, they illustrate how counter-stigmatization involves the wearing of stigma as an “emblem of pride” (Adler-Nissen Reference Adler-Nissen2014, 153). This “emblem,” as Adler-Nissen (Reference Adler-Nissen2014) writes, not only works to counter-stigmatize the stigmatizer but to identify the stigmatized with the community of “deviant” others (153).

Research reveals that the strategic identification with other stigmatized actors can also involve similarly shamed states to perform as a community of defiant norm transgressors. Although Ugandan state actors did not specifically mention who these allied others may be in their statements, the few messages of support issued by external state actors provide some indication of the directions from which Museveni finds political allegiance. A public statement of support for the law was issued by the late Iranian President, Ebrahim Raisi, who gave a joint press briefing alongside Museveni amidst the influx of international reprisals, stating:

For the Iranian president, the legislation serves as an opportunity to bring the two nations closer together in their shared objective of opposing a joint “enemy.” Describing Western “pressure” on Uganda to accept LGBTIQ+ rights, Raisi accused the West of using this norm as a vehicle for spreading “extremism and terrorism,” returning a frequent accusation that has been directed at Iran by Western states. Furthermore, referring to cooperation between their two countries, Raisi warned that they will work together to “confront” their shared enemies.

The Russian Embassy in Kenya issued a short statement of support on X, resharing a post that stated “President Museveni, who has called gay people ‘deviants’ is widely expected to approve it,” further remarking “African countries stand firm to protect traditional values!”. Praising Uganda for protecting its “traditional values,” this post by the Russian embassy expresses a succinct, yet forceful, statement of solidarity with Uganda in its decision to reject LGBTIQ+ human rights.

These statements of defiance against LGBTIQ+ human rights and the West reveal that public bilateral condemnation of the Act created an opportunity for anti-LGBTIQ+ states to assert their solidarity with Uganda and advance the rival norm of LGBTIQ+ criminalization and traditional values. While these expressions of support do not constitute a consolidated alternative bloc, they signal symbolic alignment within broader processes of illiberal norm-building. Ugandan actors did not manage their stigma alone but had the assistance of anti-Western external allies who joined the cause of asserting the rival norm of traditional values to challenge the normative dimensions and multilateral systems that, in part, constitute the LIO. The defense of the Act therefore created an opportunity for an emerging discursive convergence around an illiberal interpretation of sovereignty and LGBTIQ+ human rights, to display their agreement, and alert the international community to their shared position against the norm and the compliance demands by highly ranking states in the LIO. These findings indicate that when considering the interactions that occur in the deviance-making process, it is important to consider the existence of a community of norm-violators who have various interests in performing their alliances for international audiences. The responses of the Ugandan officials and their external supporters show that this strategy may have the desired effect of weakening LGBTIQ+ human rights norms and constituting the conditions for rival anti-gender norms to gain legitimacy and strength amongst actors seeking to challenge the LIO and its normative foundations.

Beyond Norm Defiance? Constituting an Alternative Vision of International Order

The text of the Act itself articulates the law’s assertion of an alternative normative framework that challenges the multilateral human rights system. The original Bill set the objectives of the law, positioning it as an initiative to “establish a comprehensive and enhanced legislation to protect the traditional family.” Protection of the so-called “traditional family” is said to require “strengthening the nation’s capacity to deal with emerging internal and external threats to the traditional, heterosexual family,” and “protecting…legal, religious, and traditional family values of Ugandans against the acts of sexual rights activists seeking to impose their values of sexual promiscuity on the people of Uganda” (the Ugandan Gazette 2023).

This articulation of the law’s purpose exemplifies its entrepreneurial efforts to entrench an illiberal norm (Bloomfield and Scott Reference Bloomfield, Scott, Bloomfield and Scott2017) in opposition to LGBTIQ+ human rights. Uganda’s emphasis on defending the “traditional family” introduces a rival set of norms anchored in heteronormativity and nationalist sovereignty that seeks to reorder the hierarchy of international legitimacy and attendant notions of “normality” and “deviance.” As Smetana and Onderco (2018) argue, instances in which actors challenge the legitimacy of a norm (what they call “justificatory contestation”), can sometimes take the form of “revolutionary norm entrepreneurship,” which aims to overthrow the prevailing system and establish a new order that defines clear boundaries from the overthrown one (Wunderlich Reference Wunderlich, Wagner, Werner and Onderco2014, 89 in Smetana and Onderco Reference Smetana and Onderco2018, 527). From this perspective, it becomes possible to see that the legislation is not outside of the normative field, but is attempting to shift the rules of international hierarchy and order.

The objectives of the Bill further assert a traditional Westphalian notion of ‘sovereignty’ that denounces any type of foreign intervention within the state’s affairs. This notion of traditional sovereignty is not new or unique to Uganda or other African state and non-state actors who claim that homosexuality is “un-African” but has been central to Russian narratives that reject the subordination of national sovereignty to the protection of human rights (Ayoub and Stoeckl Reference Ayoub and Stoeckl2024a; Bettiza and Lewis Reference Bettiza and Lewis2020; Edenborg Reference Edenborg2023; Goetz Reference Goetz2020; Keating and Kaczmarska Reference Keating and Kaczmarska2019). Positioning Ugandan national sovereignty as dependent upon the “tradition” of compulsory heterosexuality and heteropatriarchal family-making, the legislation constructs homosexuality as a foreign and existential threat that must be rejected as a matter of national security and sovereignty. Thus, while the law has severe implications for the lives of LGBTIQ+ Ugandans, it also serves as a message of non-compliance against the international community of states and multilateral bodies that support LGBTIQ+ human rights. In the weeks prior to Parliament’s passing of the Bill, Museveni announced that the country would terminate the mandate of the UN Office of the High Commissioner and close the UN human rights office in Kampala (UN News, August 4, 2023). Museveni said, “We have a Ugandan Human Rights Commission, which is mandated by the constitution, so having others which are not part of our constitution is first of all unnecessary, but also diversionary…what can the UN do in Uganda? They don’t have the powers of enforcement, the ones who have the powers of enforcement are the Ugandan National Human Rights Commission” (March 1, 2023).

From the perspective of Evers (Reference Evers2017), Museveni’s statements illustrate the significance of identity signaling through norm transgression. The closure of the UN office, couched in the language of enforcement and sovereignty, performs a reassertion of domestic control in the face of international human rights monitoring. This is not simply an administrative decision, but a rejection of the global scripts of compliance within the LIO. Serving as a means of strategic status assertion, Museveni announces Uganda’s rejection of multilateral human rights mechanisms to not only resist them, but to assert a new kind of agency in world politics. In doing so, the Ugandan state rejects the stigma ascribed to it by norm-adherent states, positioning itself as an entrepreneur of an alternative world order.