The Extraordinary Statelessness of Deepan Budlakoti 19 of the Ontario state. Justice Phelan (quoting Justice Shore in Al-Ghamdi, 2007) states: “The objective of paragraphs 3(2) (a) and (c) of the Citizenship Act is to ensure that citizenship is not accorded to someone who is immune from almost every obligation of citizenship (e.g., paying taxes and respecting criminal law). This is manifestly an important objective” (Budlakoti v. Canada (Citizenship and Immigration), 2014 FC 855, para. 48). Yet Budlakoti was never immune from the obligations of Canadian citizenship. He has been subjected to the full force of Canadian criminal law in his convictions and sentences. More sympathetic readings of his brushes with Canadian law have pointed out how his pleas and sentencing have reflected his status as a young and low-income person, and the particular vulnerabilities associated with his racialized Otherness (Behrens, 2015). The approach taken by the government and courts is a “reverse onus” approach, which places responsibility on individuals, faced with Canadian citizenship revocation, to show that they do not have citizenship in some other country, rather than on the state to prove that the decision to deprive individuals of citizenship will not render them stateless. Since the first determination by Canadian authorities that his citizenship had been issued in “administrative error” given his parents’ presumed employment with the Indian High Commission at the time of his birth, only those objects (mainly documents) in legal-administrative networks that reinforce his noncitizenship in Canada have been enlisted to support the Canadian government’s case that Budlakoti is a non-citizen of Canada. The government’s actions were to his detriment in that Budlakoti had opportunity during this time to apply for Canadian citizenship. Yet he (and his parents) were implicitly discouraged from doing so by the reiterated assurances by the Canadian government, which issued Deepan passports (which involves vetting applicants to ensure that they are indeed Canadian), documents involved in his becoming a ward of the state, an OHIP card, etc., indicating he was indeed a Canadian citizen. A justice-based argument to restore Budlakoti’s citizenship would accept that his case is one of “detrimental reliance:” to his detriment, the Canadian state made him believe for about 20 years through its various document-issuing actions that he was a Canadian.25 The Canadian courts have thus far also refused to engage with a fuller socio-legal understanding of citizenship, following Nottebohm, based upon a “genuine link” to a state, and “a social fact of attachment.” The genuine link principle of citizenship may be limiting in an era of globalization whereby more people are living and working internationally, and individual’s social and affective ties to nation-states have attenuated. However, in cases such as Budlakoti’s involving extinguishment of citizenship, Nottebohm’s dicta remain appropriate and effective, “serving to protect precisely the kind of deep social bonds emphasized in Nottebohm against a formal nationality 25 I would like to thank Audrey Macklin (personal communication) for bringing this argument to my attention. Studies in Social Justice, Volume 11, Issue 1, 1-26, 2017