the Constitutional Court’s judgment in the case of Mskhiladze, he wrote his own appeal against his extended confinement with no prospect of expulsion and filed it with the Supreme Court of Khakassia. The appeal was not granted, but journalists who learned of it notified ADC Memorial. As a result, Denis Lee received assistance from an attorney, was released, and even received a certificate establishing his identity. The Need for Positive Measures in Respect of the Roma Population The question of documentation is particularly acute for Romani people—a separate category of the population in both Ukraine and Russia. Structural discrimination against this ethnic group involves extreme poverty, violation of the rights to housing, access to education, and social and medical assistance, and lack of personal documents. This means undocumented status and, accordingly, statelessness is widespread in Roma communities and is handed down from generation to generation. To receive a Ukrainian passport, applicants must present the originals of documents confirming the citizenship and identity of one or both parents who were Ukrainian citizens at the time of the person’s birth (to confirm the applicant’s affiliation with Ukrainian citizenship).85 Thus, current laws make a child born in Ukraine completely dependent on the status of their parents, which contravenes recommendations made by the Committee on the Rights of the Child: paragraph 38 of the Concluding Observations of February 3, 2011 issued by this committee recommended that Ukraine amend laws so that both laws and practice guarantee the right of the child to nationality (citizenship) and the right not to be deprived of citizenship under any circumstances and regardless of the parents’ status.86 This provision of the citizenship law also contravenes the Convention on the Reduction of Statelessness, ratified by Ukraine, which stipulates that states parties must extend citizenship to a person born on their territory who would otherwise be stateless. Among the barriers Roma face on their path to documentation are a low level of education, poor knowledge of the Ukrainian and Russian languages, and lack of awareness of the need to register the births of their children and the importance of 85 Resolution of the Cabinet of Ministers of Ukraine No. 302 approving the “Procedure for Processing, Issuing, Exchanging, Forwarding, Confiscating, Returning to the State, Finding Invalid, and Destroying Passports of Citizens of Ukraine” of March 25, 2015, https://zakon. rada.gov.ua/laws/show/302-2015-%D0%BF 86 Concluding Observations of the UN Committee on the Rights of the Child: Ukraine, February 3, 2011, https://www.unicef.org/ukraine/ukr/UN_CRC_ ConcludingObservations_Ukr.pdf 47