58 SECTION I.A.3.2 and extended families.65 Some have even died in detention.66 If the processes of deprivation of nationality are allowed to conclude, these rights will be nullified for these individuals. Such a consequence will be disproportionate and completely fail to meet the requisite international law standards. It is useful to look at European Court of Human Rights (‘ECtHR’) decisions which illustrate the link between right to nationality and the right to private life, where the Court used the principle of proportionality to balance the interest of States against the infringement of the applicants’ rights. In Hoti, the ECtHR dealt with a case of refusal of the Croatian authorities to recognise the applicant as one of its citizens, acknowledging the fact that he was stateless.67 The Court reiterated its argument that ‘measures restricting the right to reside in a country may, in certain cases, entail a violation of Article 8 of the Convention if they create disproportionate repercussions on the private or family life, or both, of the individuals concerned’.68 It directed Croatia to ensure the applicant’s stability of residence through a legal status. Likewise, the ECtHR held in Kuric that the prolonged refusal of the Slovenian authorities to comprehensively regulate the applicants’ situation resulting from their erasure from administrative registers and data interfered with the exercise of 65 Ravik Bhattacharya, ‘In Kolkata, 85-year-old, his 6 children await “foreigner” son’s release from detention’ The Indian Express (20 February 2020) < https://indianexpress.com/article/cities/kolkata/ in-kolkata-85-year-old-his-6-children-await-foreigner-sons-release-from-detention-6267109/> accessed 19 July 2020; Tora Agarwala and Abhishek Saha, ‘Final NRC: “I don’t know what to do…will anyone give me a job?”’ The Indian Express (1 September 2019) <https://indianexpress.com/article/north-east-india/ assam/i-dont-know-what-to-do-will-anyone-give-me-a-job-assam-nrc-final-list-published-5955020/> accessed 19 July 2020; Arunabh Saikia, ‘A newborn died in a detention centre in Assam. His mother was later found not to be a foreigner’ (Scroll.in, 28 August 2019) <https://scroll.in/article/935337/detention-inassam-a-baby-and-old-man-died-despite-their-families-having-proof-of-citizenship> accessed 10 July 2020; National Human Rights Commission, ‘Report on NHRC Mission to Assam’s Detention Centres from 22 to 24 January, 2018’ (2018) 3 <https://cjp.org.in/wp-content/uploads/2018/11/NHRC-ReportAssam-Detention-Centres-26-3-2018-1.pdf> accessed 27 May 2020. 66 Abhishek Saha, ‘60-year-old woman lodged in Assam detention camp dies, toll rises to 30’ The Indian Express (7 April 2020) <https://indianexpress.com/article/north-east-india/assam/woman-lodged-inassam-detention-camp-dies-6351177/> accessed 19 July 2020; Arunabh Saikia, ‘In Assam, a sick man was not spared detention and a healthy man did not survive it’ (Scroll.in, 29 August 2019), <https:// scroll.in/article/935457/in-assam-a-sick-man-was-not-spared-detention-and-a-healthy-man-did-notsurvive-it> accessed 10 July 2020. 67  Case of Hoti v Croatia App no 63311/14 (ECtHR, 26 April 2018). 68 ibid. See also Maslov v Austria App no 1638/03 (ECtHR, 23 June 2008). SECURING CITIZENSHIP