differently: is there a point where some people might have been treated by the State as Ivorian nationals, without having acquired it by law, so that it could be said that they constructively acquired Ivorian nationality?211 Is there a legitimate expectation that treatment as a national will continue, given that the person’s circumstances have not changed in any way and no fraud has been committed? Concretely, would it be possible to accept that Houphouët-Boigny’s regime effectively conferred nationality on some historical migrants and their descendants by issuing Ivorian identification documents and granting them equal rights as nationals without any basis in law? This would beg a corollary question: if it is accepted that some people constructively acquired Ivorian nationality in practice but were then subjected to discriminatory practices of the late 1990s and 2000s in which State authorities tore up, destroyed, or failed to issue Ivorian personal identification documentation to those who had previously possessed it, could this qualify as arbitrary deprivation of nationality? These are complex issues without any clear answer in international or national law. A vexing problem with the universal right to nationality as enshrined in Article 15 of the Universal Declaration of Human Rights is that it is not enforceable on any particular State. How the international prohibition on arbitrary deprivation of nationality might come into play in the Ivorian context raises further questions about which other international human rights principles – such as due process, non-discrimination, the right to legal certainty, or Article 9 of the 1961 Statelessness Convention’s prohibition on deprivation of nationality on racial, ethnic, religious or political grounds – might be relevant, particularly where someone who perceives himself or herself to be Ivorian but is not considered by the State to be an Ivorian national results in statelessness. The more rigorous the Ivorian system becomes in determining Ivorian nationality pursuant to its laws, the likelier it will be that such questions will arise. This underscores the imperative for the Ivorian government to develop transparent guidelines on how Ivorian nationality is determined in a comprehensive manner and to collaborate with its neighbors to resolve cases where nationality is in doubt. 5.8. Challenges in obtaining statelessness statistics Proper identification of stateless persons, as well as groups at risk of statelessness, is the first and most fundamental step in devising a response to resolve statelessness in any country.212 This is a highly challenging task.213 Since 2012, UNHCR has published the Ivorian government’s projected estimation of 700,000 stateless persons or persons of undetermined nationality in Côte d’Ivoire. The government considers that this statistic represents a minimum estimate of those it considers “at risk of statelessness,” but UNHCR’s statistical reporting does not allow for the use of this term. A footnote explains how this number was reached as follows: This figure includes: i) 300,000 Children abandoned at birth: Government estimate of individuals of unknown parentage who were abandoned as children and who are not considered as nationals under Ivorian law. ii) 400,000 Descendants of Immigrants: 210 There is one allusion to a related scenario in paragraph 45 of the UNHCR Handbook on Protection of Stateless Persons: “For the purposes of the [1954 Statelessness Convention definition of stateless person,] conferrals of nationality under a non-automatic mechanism are to be considered valid even if there is no legal basis for such conferral.” The Handbook, however, distinguishes this scenario “from one where a non-national is merely treated to the privileges of nationality.” Id., para. 29, footnote 49. 211 This suggestion is inspired by the common-law legal notion of construction, whereby the law sanctions as fact something which is a legal fiction. 212 UNHCR’s increased emphasis on statelessness identification is in fulfillment of its mandate from its Executive Committee. UNHCR, Conclusion on Identification, Prevention and Reduction of Statelessness and Protection of Stateless Persons, 6 October 2006, No. 106 (LVII) - 2006, para. (b). 213 UNHCR, Guidance Document on Measuring Stateless Populations, May 2011. 57