SAHNI ARTICLE 3.3.21 (WORD) (DO NOT DELETE) 142 Gonzaga Journal of International Law 5/6/2021 7:21 PM Vol. 24:2 becoming stateless since they had other nationalities. They were resident citizens of countries where there were no domestic or foreign travel restrictions. The principal place of residence was Canada, Switzerland, or Iran.274 Under the laws of these States, the Applicants had the liberty to approach the local Netherlands embassy or enter the Netherlands unhindered. Yet they deliberately or negligently did not adhere to Article 15(c). They omitted to renew their Dutch passports before the expiry dates.275 Therefore, their Dutch nationality was revoked by operation of law.276 The ECJ confirmed that the associated loss of EU citizenship was a proportional statutory effect since EU citizenship is subordinate to nationality of a Member State.277 Community citizenship is a benefit but does not oust domestic nationality.278 While three of the Applicants possessed Netherlands nationality under the jus soli principle,279 the fourth Applicant had pursued the naturalization route. “Ms Saleh Abady was born on 25 March 1960 in Teheran (Iran). She is an Iranian national by birth. By Royal Decree of 3 September 1999 she also acquired Netherlands nationality. On 6 October 1999, a Netherlands passport, which was valid until 6 October 2004, was issued to her for the last time. On 3 December 2002 her registration with the Personal Records Database was suspended because of her emigration. Since that date Ms Saleh Abady has clearly had her principal residence in Iran without interruption. On 29 October 2014 she submitted a passport application to the Embassy of the Kingdom of the Netherlands in Teheran (Iran).”280 However, based on the above facts, she was not eligible to apply for Netherlands citizenship nor retain [it] thereafter. The judgment states that Abady is an Iranian national by birth.281 It does not state that Abady was an Iranian national. In other words, Abady is still an Iranian national. This status conflicts with Iranian nationality law which forbids dual citizenship. 282 274. Case C-221/17, Tjebbes & Ors v. Minister van Buitenlandse Zaken, 2019 EU:C:2019:189, ¶¶ 13-16. 275. Id. 276. Id. ¶ 17. 277. Id. ¶ 39. 278. Treaty on the Functioning of the European Union (TFEU) [2016] O.J. C202/1, art. 20(1) (“Citizenship of the Union is hereby established. Every person holding the nationality of a Member State shall be a citizen of the Union. Citizenship of the Union shall be additional to and not replace national citizenship.) 279. Case C-221/17, Tjebbes & Ors v. Minister van Buitenlandse Zaken, 2019 EU:C:2019:189, ¶¶ 13, 14, & 16. 280. Id. ¶ 15. 281. Id. 282. QANUNI ASSASSI JUMHURII ISLAMAI IRAN [THE CONSTITUTION OF THE ISLAMIC REPUBLIC OF IRAN] 1368 [1989], art. 41.