Interministerial Circular No. 31/MJ/CAB 3 of 25 April 1962 governed the issuance of certificates of nationality until recently. It established the courts’ territorial jurisdiction over the issuance of such certificates and the role of the Ministry of Justice of supervising and overseeing their issuance. Annex B to this circular provided approximately a dozen official model forms that were to be used for issuing certificates of nationality. For those attributed nationality pursuant to Article 6, nationality certificates were to be entitled: “Certificate of Nationality: Petitioner of Ivorian nationality by origin by his or her birth in Côte d’Ivoire,” and presented special instructions to judges: Fact to verify: Birth in Côte d’Ivoire. This birth constitutes a presumption. However, it is your responsibility to verify the birthplace of one or both parents of the petitioner, when it appears to you, for example, upon examining the names on the birth certificate of the petitioner, that they are foreigners. Whatever the outcome of your evaluation, you will request instructions from the Ministry of Justice. These instructions reinforced the understanding that although the 1961 Nationality Code did not define who constitutes a “foreigner,” it implicitly linked being a foreigner to place of birth outside of Côte d’Ivoire. They created, however, a dangerous practice, whereby it was permissible, even potentially necessary, for judges issuing nationality certificates to exercise subjective discretion in questioning a person’s origins on the basis of social stereotyping of a person’s family name. A new circular issued by the Ministry of Justice on 30 June 2014 supersedes the Interministerial Circular of 1962 governing nationality certificates in light of the Council of Minister’s decision in 2014 to issue “secure judicial certificates” going forward.97 The new secure nationality certificates issued by courts no longer distinguish in their titles the method by which an individual possesses Ivorian nationality (i.e. nationality by origin versus other means).98 This also means that the standard paragraph cited above regarding proof with respect to those who possess Ivorian nationality by origin is also no longer included. These are laudable measures. 3.2.11. Statelessness safeguards and compliance with the statelessness conventions At no time has the Ivorian Nationality Code included any explicit reference to statelessness. However, the deliberations regarding the 1961 Nationality Code indicate that care was taken to ensure that statelessness would be avoided, but only in the context of Articles 13 and 51 of the Nationality Code on marriage, which were reserved at the time for women. Article 13 allowed foreign women marrying Ivorian men to decline to acquire Ivorian nationality by submitting a declaration at the time of the civil marriage ceremony, whereas Article 51 allows Ivorian women marrying foreigners to retain their Ivorian nationality, unless they file a declaration renouncing their Ivorian nationality upon marriage. To safeguard against statelessness for Articles 13 and 51, the implementing decree99 and Interministerial Circular100 required women to bring proof, in the form of an official attestation, that either the laws of the country of her foreign spouse’s allow her to acquire nationality through marriage or that the laws of her country of origin allow women to retain nationality upon marriage 97 Ministère de la Justice, des Droits de l’Homme, et des Libertés Publiques, Note Circulaire No. 8 du 30 juin 2014 (on file with author). This point has been confirmed by the Ministry of Justice via correspondence in April 2016. 98 This practice diverges from the requirement established in Article 98 of the Nationality Code to include this information. It is this Article, however, which should be reformed in any future law reform effort in order to harmonize and neutralize nationality certificates. 99 Décret No. 61-425 du 29 décembre 1961 portant application du Code de la nationalité ivoirienne. 100 Circulaire Interministérielle No. 31/MJ/CAB 3 du 25 avril 1962 (1). 30