stateless through an denationalization: affirmative they are now act of marginalized, outcast, excluded and they have no right to engage in basic rights. 4 , 5 In addition, the BIA ignores its own test to determine whether persecution. revocation The ‘denaturalization BIA of has plus’ test citizenship articulated that requires is a an additional examination of the circumstances flowing from the stripping of citizenship to determine whether they rise to the level of persecution on a protected ground. Haile, 591 F.3d at 573 (quoting an unpublished BIA decision). The BIA did not do so here. By ignoring Petitioners’ citizenship and central is refusing argument persecution, 4 to that the reach revocation BIA refuses the of to M. Lynch, Lives on Hold: the Human Cost of Statelessness, Refugees International (February, 2005) http://www.refintl.org/sites/default/files/LivesonHold.pdf 5 Open Society Justice Initiative Makes Statement to the African Commission on Human and Peoples' Rights, (May 2, 2005), http://www.soros.org/initiatives/justice/focus/equality_cit izenship/news/africa_20050502. 26

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