Iseult Honohan
not making their citizens stateless, in some cases they maintain the possibility of another citizenship that
is not necessarily recognised by the state in question, which risks rendering people effectively stateless.
Moreover, such revocations have been criticised as discriminatory (in not treating alike native born and
naturalised citizens, or dual citizens and holders of only one citizenship), as targeting particular groups,
or as an inappropriate substitute for punishing crimes. More generally it may be argued that wide state
powers to revoke citizenship erode the security of citizenship itself.2
What’s distinctive in these case studies
In the four case studies in this symposium we see a range of different types of citizenship withdrawal
beyond the Western context. These accounts, from Syria, by Mohamad Alh, from Nigeria, by MaryAnne
Iwara, from Myanmar, by Jasmine Burnley, and from India, by Aashish Yadav and Mohsin Alam Bhat,
along with the commentaries by that follow, by Laura van Waas, Milena Tripkovic, and Émilien
Fargues, throw new light on the practice of citizenship revocation. These cases share certain distinctive
features, and unlike in the more discussed Western cases mentioned above, they do not rely on the
exercise or expansion of formal powers in citizenship laws.
In these cases, citizenship has been revoked from those whose (albeit disputed) citizenship derives
from birth (either by descent or territory) rather than naturalisation. Many of those affected continue to
be resident in the state, as opposed to being deported. These are larger scale processes of revocation,
which appear to be applied to individuals on the basis of their group membership, rather than in response
to specific crimes or other actions. Statelessness has not in general provided a limit to the withdrawal of
citizenship.
The groups affected may be defined in ethnic (Kurds in Syria) or religious (Muslims in Assam/India)
terms, or in a combination of the two (Rohingya in Myanmar). In these cases the members of the group
have been characterised as outsiders, as immigrants, even as illegal immigrants or ‘alien infiltrators’.
While there has undoubtedly been movement across borders, these groups have had a substantial and
long-standing presence in their respective countries, in the case of the Rohingya and Kurds for centuries.
In Nigeria, it is in relation to the region rather than the nation-state that the Boko Haram victim returnees
are defined as outsiders; they cannot establish that they are eligible for the certificate of indigeneity in
that particular region, a prerequisite for citizenship.
Defining these groups as non-members has been central to this process. In two cases the mechanism
has been ostensibly a determination of those properly qualified to hold the status: the Syrian exceptional
Census of 1962 and the National Register of Citizens (NRC) of 2014-19 in Assam. In Myanmar the
basis for deprivation was laid by new citizenship legislation in 1982, which created three tiers of
citizenship that excluded those who were not members of specified ‘national races’ and granted a lesser
status selectively to certain others.
Why might we think of these processes as more like revocation than correction of citizenship? In
some cases it has been argued that what is involved is a correction: annulling the citizenship of those
who were never entitled to it. But, in the first place, even in the context of continuing immigration,
significant numbers of those whose citizenship was withdrawn (or their ancestors) seem to have met the
legislative criteria for citizenship relevant at the time. In India from 1949 to 1986, in Nigeria from 1960
to 1979, and in Myanmar (then Burma) from 1948 up to 1982, all born in the country were deemed to
be citizens from birth. Subsequently, and in Syria throughout this time, descent from a citizen was the
principal basis for the award of citizenship.3 These combinations of original ius soli with ius sanguinis
2
See further Honohan, I. (2020), ‘Just what’s wrong with losing citizenship? Examining revocation of citizenship from a
non-domination perspective’, Citizenship Studies, 24:3, 355-370, DOI: 10.1080/13621025.2019.1700045
3
In Syria this only through the father; in India since 2004, a citizen cannot pass citizenship to their child at birth if the other
parent is in the category of illegal immigrant or undocumented foreigner, while since 2019 exceptions have been provided
2
Robert Schuman Centre for Advanced Studies Working Papers