134 Kingston internal colonialism.21 This view is in stark contrast to the Western ideal of the ‘social contract’ (in which the individual surrenders absolute freedom in exchange for state protection of fundamental rights), as well as oft-accepted ‘solutions’ to statelessness that rely on the provision of citizenship for upholding human rights. Although most discussions of statelessness as a human rights issue contend that the granting of legal nationality is a positive step toward rights protection, it is noteworthy that several groups – including many members of Europe’s Roma community and some indigenous nations – reject state citizenship. These marginalized communities are often ignored by scholars and advocates who only consider one type of inclusion: formal citizenship. The international community’s reliance on state-sponsored identities and documentation, however, leaves little space for rights protection outside the confines of bounded, legal nationality. There are few (if any) developed theories of partial citizenship because it has always been regarded as the imposition of second-class status on vulnerable groups – and instances of statelessness generally support this view. However, Cohen’s concept of semi-citizenship may offer possibilities not only for the oppression of marginalized groups, but at the same time also opportunities for forms of formal inclusion that could provide some of the protections and benefits currently reserved for citizens.22 This requires us to move beyond the binary juxtaposition of ‘citizen versus non-citizen’ to consider the possibilities that exist along a spectrum of citizenship. This calls into question our understandings of political membership, while also prompting governments to respect so-called ‘universal’ human rights that are, in reality, limited by their close association with citizens’ rights. Notably, Matthew Gibney’s work on ‘precarious residents’ (including unlawful migrants and asylum seekers awaiting status determination) provides recommendations for ensuring rights protection and political membership outside the bounds of traditional citizenship. Firstly, one potential standard for defining membership is the principle of choice. Membership should be available to anyone who chooses to live in a state. A second approach is to emphasize individuals’ situations as subjects of state power; a state can only legitimately rule if the people consent to such rule. Third, the principle of societal membership states that membership of a state should be composed of those who have a significant stake in the development and direction of 21 22 James C. Scott, The Art of Not Being Governed: An Anarchist History of Upland Southeast Asia (Yale, 2009). Elizabeth F. Cohen, Semi-Citizenship in Democratic Politics (CUP 2009) 206. tilburg law review 19 (2014) 127-135