CRITICAL ASIAN STUDIES 165 could deport foreigners without a court ruling. Nevertheless, Burmese judges repeatedly upheld the rights and status of non-taingyintha citizens by birth. The Supreme Court dubbed non-taingyinthacitizens “statutory citizens,” as they qualified for citizenship under statutory law rather than the 1947 Constitution.85 In a case of detained Pakistanis who immigration officials planned to deport because they “looked Pakistani” and could not speak Burmese or Rakhine, the Supreme Court stated: A person descended from ancestors who for two generations have made Burma their permanent home, and whose parents and himself were born in Burma, is a statutory citizen. Today in various parts of Burma there are people who, because of their origin and isolated way of life, are totally unlike the Burmese in appearance … . they are nevertheless statutory citizens under the Union Citizenship Act. The applicants claim they belong to that category. They might be right and therefore the opportunity of proving that they are, should be given to them. To deny them this opportunity would be a violation of their fundamental rights.86 Burmese case law from the 1950s and early 1960s provides a glimpse into attempts to regulate citizenship and residency claims and the individuals and families caught up in these processes. Questions of citizenship status often made it to the courts in cases related to property, deportation, and mandatory registration of foreigners.87 Yet, this recourse to the legal system would not last, and the lines between statutory citizens and taingyintha would become more pronounced under Burma’s authoritarian governments.88 After a military coup in 1962, the Burmese government intensified deportation initiatives to further disenfranchise and dispossess non-taingyintha, ignoring previous legal rulings.89 Potential foreigners under the Burmese way to socialism After General Ne Win took power in 1962, his Revolutionary Council government instituted a program of nationalization and isolation.90 In 1963, the Burmese Immigration Department documented 95,000 Indians with Foreign Registration Certificates (FRCs), 85,000 of whom lived in Rangoon.91 The same year, the Department reported that 8,344 foreigners had left Burma permanently, including 5,911 Indians and 1,499 Pakistanis.92 Foreigners were banned from certain occupations and trades, were restricted to their district of residence, and could not receive re-entry visas if they went abroad. In addition, any foreigners aged twelve and older were required to pay an annual fee for an FRC.93 Wholesale businesses and retail shops were nationalized in 1964, followed 85 Hasan Ali v. Secretary, Ministry of Immigration and National Registration 1959 B.L.R. (S.C.) 187; Meher Ali v. Secretary, Ministry of Immigration and National Registration 1959 B.L.R. (S.C.) 187. 86 Hasan Ali v. Secretary, Ministry of Immigration and National Registration 1959 B.L.R. (S.C.) 187; Meher Ali v. Secretary, Ministry of Immigration and National Registration 1959 B.L.R. (S.C.) 187, p. 194-195. 87 For example, see, among others: Peer Mohamed v. Union of Burma (1965) B.L.R. 51 (C.C.); Ko Aung v. Abdul Latiff (1958) B.L.R. 216 (H.C.); Hasan Ali v. Secretary, Ministry of Immigration and National Registration (1959) B.L.R. 187 (S.C.); Kali Mutu v. The Union of Burma (1962) B.L.R. 51 (C.C.). 88 Rhoads 2023a. 89 See, among others: Indu Bhai v. The Union of Burma (1963) B.L.R. 348 (C.C.); Tai Yu Han v. The President of the Union of Burma and one (1953) B.L.R. 47 (S.C.); Bishna Lal v. The Union of Burma (1959) B.L.R. 3 (H.C.); Hasan Ali v. Secretary, Ministry of Immigration and National Registration (1959) B.L.R. 187 (S.C.). 90 Holmes 1967. 91 Times of London 1964. 92 NAI 1964, 21. 93 NAI 1964, 21, 37; UKNA 1963.