Kelly Kapianga (LCK Chambers) as proof that the Board must register an eligible applicant not captured under any grounds on which an application can be denied. The 2016 Constitution also creates the new entitlement to apply to register as a citizen for a person who has been ordinarily resident in Zambia for a period of at least five years and was born in Zambia, or was born outside Zambia of an ancestor who was a citizen.119 Exactly who an ancestor is has yet to be defined by statute or case law. As in the case of marriage, it is unclear whether the Citizenship Board has an obligation to register a person who applies and fulfils these conditions. Finally, the 2016 Constitution provides for an application for registration based on ten years residence, subject to other conditions to be established by law or regulation. The conditions include residence by virtue of a permit as already stated and following the procedures laid out in the 2017 Regulations. These are, publishing of the application in the Gazette and in two consecutive issues of a daily newspaper circulating in the person’s area of residence, a notice in the prescribed form of the person’s intention to apply for registration as a citizen120 and, thereafter, filing the application in the prescribed manner. 3.6 Toleration for dual citizenship Finally, the 2016 Constitution introduced an entitlement to dual citizenship for those who voluntarily acquire another.121 As a consequence, the acquisition of alternative citizenship is no longer a ground for loss of citizenship.122 The principal motivation for permission of dual citizenship appears to be the desire to allow Zambians residing in other countries and who had lost their citizenship to participate in the political processes in Zambia.123 However, between 2016 and 2019, only 156 applications for dual citizenship have reportedly been granted.124 A closer look at the law suggests that dual citizenship, the requirements for a person who had previously lost Zambian citizenship on acquiring alternative citizenship and a Zambian acquiring a second citizenship are different. In respect of the former, the person is required to apply to the Citizenship for Bestowal of citizenship.125 It is unclear whether the Board has discretion to deny the application and neither the Constitution of Zambia, 2016 nor the Citizenship of Zambia Act, 2016 are clear on this. The necessity for the application, can be seen as necessary to provide the Board an opportunity to scrutinise claims by people that they had at one time been Zambian citizens. The details required when completing the form filed in the application appear to bear this out. They require that the applicant provide 119 Constitution of Zambia 2016, Art. 37(1)(a) and (b). Regulation 3 of the Regulations, 2017. 121 Article 39 Constitution of Zambia 2016 122 Article 39(1) 123 Lusaka Times Newspaper, “You can apply for Dual Citizenship now-Home Affairs”, 7 January 2016. Available from https://www.lusakatimes.com/2016/01/07/110255/ 124 Pezzy Kudakwashe, Lusaka Times Newspaper, ‘Government approves 156 dual citizenship applications,’ 17 September 2019 Available from: https://www.lusakatimes.com/2019/09/17/government-approves-156-dualcitizenship-applications/ 125 Regulations 10(1) and (2) of the Citizenship of Zambia Regulations, 2017 120 18 RSCAS/GLOBALCIT-CR 2020/14- © 2020 Author(s)