Jasmine Burnley regard,38 and its exclusion of certain groups who had previously held citizenship, from full ‘ius soli’ citizenship amounts to a further step in the process of revocation and results in the creation of stateless persons. However, whilst the law constitutes a legal revocation of citizenship for Rohingya and other non-recognised groups unable to prove their existing citizenship, it is not the sole cause. As Nyi Nyi Kyaw argues, it is also through administrative practices, including an uneven implementation of the law and failure to support a process of citizenisation for those that do qualify for it, that the revocation of entitlements associated with citizenship has been conducted.39 An illustration of this is the Government’s 1989 policy to put in place an updated system of colour coded identity cards, which aligned with the classes of citizenship.40 When the Government took the step of replacing the existing documentation system under which most people held NRCs with colour coded Citizenship Scrutiny Cards,41 the Rohingya were left out42 and therefore did not receive proof of citizenship as recognised by the new documentation system. Instead, the Rohingya continued to hold their NRCs, which allowed them access to rights associated with citizenship entitlements until 1995, when under a further documentation project, the authorities began to replace NRCs with temporary identity cards, known as White Cards.43 Nyi Nyi Kyaw suggests that by 2014, only half of the Rohingya held White Cards, leaving the rest – including many young children –undocumented and in a ‘legal limbo’.44 This uncertainty was transformed into a more substantive revocation of rights associated with citizenship when in 2014, the Government enacted a Law that prevented White Card holders from establishing or joining political parties.45 In parallel, entitlements were further compromised in 2014 when the Government decided last-minute, to prohibit people from self-identifying as Rohingya as part of the national census enumeration.46 The additional decision that all White Cards would expire and must be returned to the Government,47 both left a large number of Rohingya in a completely undocumented state, and disenfranchised the majority of Rohingya ahead of the 2015 national election, both of which constituted further revocation of rights associated with citizenship. The Government of Myanmar did offer a potential route back to citizenship for those whose White Cards were being terminated through a process of national verification, the objective of which ‘was to scrutinize them as to whether they were entitled to become a citizen.’48 The verification process however, included a 38 ICJ (2019), Citizenship and Human Rights in Myanmar: Why Law Reform is Urgent and Possible. A Legal Briefing; Advisory Commission on Rakhine State (2017), Towards a peaceful, fair and prosperous future for the people of Rakhine. Final Report of the Advisory Commission on Rakhine State 39 Nyi Nyi Kyaw (2017), ‘Unpacking the Presumed Statelessness of Rohingyas’, Journal of Immigrant & Refugee Studies, 15(3): 269-286. 40 Ibid., 278. 41 Justice Base (2018), A Legal Guide to Citizenship and Identity Documents in Myanmar. 42 Nyi Nyi Kyaw (2017), ‘Unpacking the Presumed Statelessness of Rohingyas’, Journal of Immigrant & Refugee Studies, 15(3): 269-286. 43 Advisory Commission on Rakhine State (2017), Towards a peaceful, fair and prosperous future for the people of Rakhine. Final Report of the Advisory Commission on Rakhine State. 44 Nyi Nyi Kyaw (2017), ‘Unpacking the Presumed Statelessness of Rohingyas’, Journal of Immigrant & Refugee Studies, 15(3): 279. 45 Advisory Commission on Rakhine State (2017), Towards a peaceful, fair and prosperous future for the people of Rakhine. Final Report of the Advisory Commission on Rakhine State 46 Ferguson, J. (2015) ‘Who’s Counting? Ethnicity, Belonging, and the National Census in Burma/Myanmar’, Bijdragen tot de Taal Land en Volkenkunde, 171(1): 1–28. 47 Norwegian Refugee Council (2018), A Gender Analysis of the Right to Nationality in Myanmar. 48 Government of Myanmar (2015), Notification 19/2015 dated February 11. Issued by the President’s Office https://www.president-office.gov.mm/en/?q=issues/rakhine-state-affairs/id-7031 22 Robert Schuman Centre for Advanced Studies Working Papers