certificates or ID documents faced the experience that local authorities or even low-level police officers at roadblocks would tear up their papers, denying their Ivorian nationality in practice.174 Can such persons who have been naturalized as a matter of law but denied proof of their Ivorian nationality in practice qualify as “stateless” as understood in Article 1 of the 1954 Statelessness Convention? Did the level of discrimination against “perceived foreigners” by Ivorian authorities reach the level where it indicated that the State no longer considered them nationals? Or is this a case where their nationality is not in question, but their rights as citizens were violated? 175 If the concerned individuals were consistently denied the right to obtain Ivorian nationality certificates or other Ivorian ID documents; denied the right to vote, take on a public service post or a liberal profession, or other rights attached to nationality, the conclusion might be reached that indeed, the Ivorian government had changed its position and did not consider these people as its nationals.176 This is an interesting case where the State’s position on these individuals’ nationality has changed over time. At the very least, those who benefited from the naturalization decree but cannot obtain documentation of their Ivorian nationality in practice can be said to be at risk of statelessness.177 In light of this, the Ivorian Ministry of Justice, with assistance from UNHCR, has undertaken a number of measures to ensure that those who acquired Ivorian nationality through the 1995 collective naturalization decree can obtain official proof of their nationality and benefit from the rights attached to that nationality in practice. Over several years, the Ministry of Justice compiled and reproduced copies of the 1995 decree and the 6 January 1996 edition of the Official Journal with the names of all naturalized individuals. It conducted a series of trainings with magistrates and other local officials and directly assisted individuals with obtaining nationality certificates. It is hoped that with the increased awareness of the rights of these individuals, all those concerned and their descendants will be able to obtain proper documentation of their Ivorian nationality. Their situation should certainly continue to be monitored. 5.2. Children of unknown parents Section 3.1.4 above explained how the 1972 amendments to the Nationality Code closed the only legal avenue for children found in Côte d’Ivoire of unknown parents to acquire nationality. Côte d’Ivoire acceded to the 1961 Statelessness Convention in 2013. It now has a legal obligation to grant Ivorian nationality to children born in its territory who would otherwise be stateless, as well as to grant its nationality to foundlings found in its territory. Although Article 3 of the Ivorian Nationality Code establishes that international treaties take precedence over Ivorian law in nationality matters, even where contradictory, this is impractical and cannot be relied upon to overcome various practices that either render children stateless or place them at heightened risk of statelessness. 174 Ousmane Diallo, Koupéla, Tenkodogo, Garango et Koudougou : La vérité sur les 8000 naturalisés, Nord-Sud, 18 March 2013. 175 The UNHCR Handbook on Protection of Stateless Persons provides several relevant passages to assist in this analysis, including in paragraph 43: “In cases where there is evidence that an individual has acquired nationality through a non-automatic mechanism dependent on an act of a State body, subsequent denial by other State bodies of rights generally accorded to nationals indicates that his or her rights are being breached. That being said, in certain circumstances the nature of the subsequent treatment may point to the State having changed its position on the nationality status of that individual, or that nationality has been withdrawn.” 176 Whether they would be stateless would depend on whether the individuals have otherwise obtained Burkinabè nationality. 177 These individuals fall within two of the classic categories of groups at risk of statelessness, namely: individuals with perceived or actual ties with foreign States, and migrant populations and their descendants. As always, an ultimate determination would need to be done on a case-by-case basis and would depend on whether a person does or does not clearly possess proof of another nationality. 48