Comparative Regional Report on Citizenship Law: Oceania provides that every person of i-Kiribati descent has the right to become a citizen.76 In Kiribati and Vanuatu a person with indigenous ancestry can apply for citizenship.77 In Palau, a person with at least one parent of recognised Palauan ancestry can apply for naturalisation.78 The Constitution of the Marshall Islands provides for naturalisation on the basis of descent in two ways: first on the basis that a person has land rights, defined to mean “any right in any land in the Republic under the customary law or any traditional practice”; and secondly on the basis that the person is “of Marshallese descent, and that in the interests of justice his application should be granted”. 79 Both grounds demonstrate the importance of ‘blood relationship’ to citizenship, as the entitlement to land rights under Marshallese custom is based on family relationships. Both categories are covered, because, as the High Court of the Marshall Islands has noted, it is possible for a person to be of Marshallese descent and not have land rights. In Marshallese custom, there are two categories of land ownership. Matrilineal clan members have permanent land rights and authority over land, while patrilineal clan members have interim rights that last a few generations. As such, a descendant from a male Marshallese ancestor who has been absent from the state for several generations might be of Marshallese descent but not have land rights.80 In contrast, three states – Papua New Guinea, Samoa and Solomon Islands – define ancestry by reference to the citizenship of a person’s ancestors. Citizenship by descent is available in Papua New Guinea to a person with one parent or grandparent who was, or is eligible to be, a citizen; in Samoa to a person born outside Samoa with at least one grandparent who is a citizen by birth; and in Solomon Islands to a person with at least one parent, grandparent or great grandparent who is or was a citizen by birth.81 Applicants might also be required to meet other criteria, such as residence or good character. Naturalisation by descent reflects to the desire in many Oceanic states to constitute a citizenry based on shared indigenous heritage and culture. In Samoa, however, the stated purpose for the introduction of laws providing for citizenship by descent in 2016 was to permit non-citizens of Samoan descent to represent Samoa in various sporting events.82 Naturalisation for former citizens Several states in Oceania give preferential access to naturalisation to former citizens. One, now outdated, category of former citizen specifically provided for was a woman who had lost her citizenship upon marriage to a foreign citizen, and whose marriage had subsequently broken down. The only state to retain naturalisation for this category is Kiribati.83 Tonga does not provide a special category, but its law does waive the residence requirement for naturalisation 76 Constitution of Kiribati 1979 s 19. Constitution of Kiribati 1979 s 23, Citizenship (Registration) Regulations 1983 (Kiribati); Constitution of Vanuatu 1980 s 10, Citizenship (Entitled Persons) Act c 110 (Vanuatu). 78 Constitution of Palau 1980 Art III s 4, Citizenship Act c 13.1 (Palau) ss 136-141. 79 Constitution of the Marshall Islands 1979 Art XI, s 2(1)(a) and (c). 80 In Re Citizenship of Kiritano [2012] MHHC 7. 81 Constitution of Papua New Guinea 1975 s 66(3); Citizenship Act 2004 (Samoa) s 7(4); Citizenship Act 2018 (Solomon Is) s 14(5). 82 Kelly Buchanan, ‘Citizenship Act Amended to Allow Second Generation Samoans Overseas to Claim Citizenship’ (Global Legal Monitor, 24 August 2016) <//www.loc.gov/law/foreign-news/article/samoacitizenship-act-amended-to-allow-second-generation-samoans-overseas-to-claim-citizenship/>. 83 Citizenship Act 1979 (Kiribati) s 10. 77 RSCAS/GLOBALCIT-Comp 2020/1 - © 2020 Author 15