70 SECTION I.B.2 stipulated date. It was found that his actions were not voluntary, as the secret mission included him renouncing his Portuguese nationality and obtaining an Indian one. Hence, it was held that the respondent was an Indian citizen and that to hold him not to be one at this stage would render him stateless, since he had already renounced his Portuguese nationality. In Jan Balaz, the Gujarat High Court was asked to decide whether children born in India to an Indian surrogate with German nationals as their surrogate parents would be eligible for Indian citizenship by birth.110 In this case too, the Court interpreted the Citizenship Act progressively to hold that the children had a right to Indian citizenship via their surrogate mother, who was an Indian national, and directed the Government to issue Indian passports to them. The Court was aware of existent German laws that do not recognise surrogacy, which would have then denied German citizenship by birth to the children, rendering them stateless. In Ramesh Chennamaneni, the petitioner was challenging the cancellation of his citizenship by an enquiry committee constituted under Section 15 of the Citizenship Act.111 The petitioner was an Indian citizen by birth who had migrated to Germany and acquired German nationality (thus giving up his Indian citizenship) before moving back to India after several years. He had subsequently applied for Indian citizenship by registration, a precondition for which was continuous residency in India for 12 months prior to the application. While his citizenship application was successful, one of the respondents contended that the petitioner had concealed material facts about the continuous residency requirement, as he had travelled to Germany and back several times in those 12 months. The Telangana High Court remarked that even though the petitioner’s travel to Germany would constitute a wrong declaration for the purposes of his application, this would not perforce result in the 110  Jan Balaz v Anand Municipality and 6 Ors AIR (2010) Guj 21 (Gujarat High Court). 111  Ramesh Chennamaneni v Union of India (2019) SCC OnLine TS 2100 (Telangana High Court). SECURING CITIZENSHIP