  applications for international protection in the form of refugee status or subsidiary protection. Section 6(3) of the Irish Nationality and Citizenship Act 1956 provides that “a person born in the island of Ireland is an Irish citizen from birth if he or she is not entitled to the citizenship of any other country”. Section 16(1)(g) of the Irish Nationality and Citizenship Act 1956 gives the Minister the power to dispense with certain conditions of naturalisation in certain cases, including cases involving a stateless person. 17. However, there is no ‘ex officio’ consideration of statelessness when a person makes an application for naturalisation as an Irish citizen and the determination of a person’s statelessness in the context of their application for refugee status or subsidiary protection does not constitute a formal recognition of statelessness. 18. In the case of Spila & Others v Minister for Justice, Equality and Law Reform,xiv a case concerning the challenge of the Minister’s decision not to grant certificates of naturalisation to a family of seven ‘non-citizens’ from Latvia, the High Court set out that: “(…) this Court is relieved of the responsibility for deciding whether these applicants are, as a matter of international law or otherwise, to be considered as ‘stateless’”. In his decision, Mr Justice Cooke set out that the reason why the Court was “relieved of this responsibility is twofold: In the first place, it is clear that when these applications were made, the Minister was not explicitly requested consider whether, as ethnic Russian Latvians they were ‘stateless’ in any sense. As pointed out above, in the application forms, they declared themselves to be of Latvian nationality with the qualification of ‘ethnic Russian’. It may be true that when the applications were presented, the applicants and their solicitor were unaware of the significance that might attach to the characterisation of ‘statelessness’ for these purposes. Nevertheless, it is clear from the letter of the 8th April, 2009, from the applicants' solicitor referred to in para. 6 above, that it was only after the decision was received that it occurred to the applicants to assert their classification as stateless persons”. The Court accordingly refused the application, setting out that “this application for judicial review is unnecessary and unfounded and (…) the complex issue as to the possible status of the applicants as ‘stateless’ individuals in international law or for the purpose of the policy maintained by the Minister must be decided definitively in the first instance by the respondent Minister before it need be judicially reviewed”. The Situation of Stateless Persons in Ireland 19. As set out in the UNHCR Handbook on Protection of Stateless Persons, “(G)overnment officials might encounter the question of whether a person is stateless in a range of contexts, reflecting the critical role that nationality plays in everyday life. For example, consideration of nationality status is relevant when individuals apply for passports or identity documents, seek legal residence or employment in the public sector, want to exercise their voting rights, perform military service, or attempt to access government services. The issue of nationality and statelessness may arise when an individual’s right to be in a country is challenged in removal procedures. In refugee status determination, nationality is often key to identifying the country 6