370           Fisher This interpretation also makes good policy sense. Only the state can extend the benefits of nationality to an individual, and it is the state’s determination that should carry the day.23 The United Nations High Commissioner for Refugees (“UNHCR”) estimates that there are ten million stateless people globally who become stateless for a variety of reasons.24 For example, a child may be born stateless if their parents are stateless and the child is born in a country that does not grant nationality by birth in territory.25 Examples of groups that are largely stateless include Palestinians, the Bidoon in Kuwait, and Rohingya in Burma.26 A child whose birth is not registered may technically receive nationality at birth but become unable to prove their nationality through birth in territory or parentage later in life.27 States may revoke nationality for political dissidents or members of minority groups. As an example, Ethiopia stripped nationality from individuals of Eritrean origin after Eritrean independence.28 A territory may change hands, and individuals may not be recognized as nationals by the new state. For instance, many individuals in Soviet republics found themselves stateless after the dissolution of the Soviet Union.29 Stateless individuals globally experience many human rights violations; many stateless people lack legal status in their country 23 24 25 26 27 28 29 2022); see also Fisher, Operation of Law, supra note 14, at 267–68, 288–89 (“When an applicant can present evidence that the state in question has disclaimed her as its citizen, the applicant need not point to a principle of law­—whether in the nationality law or otherwise—in order to establish her statelessness.”). As a British appellate court stated: “The ultimate decision about grant or refusal of citizenship to any person is entirely within the remit of the administrative and judicial authorities of the Republic of Ukraine. For me to make any determination of citizenship would be an unauthori[z]ed trespass upon the . . . sovereignty of the Republic of Ukraine.” Fedorovski, Re Judicial Review [2007] NIQB 119 [16] (UK). UNHCR, Special Report: Ending Statelessness within 10 Years, UNHCR 16 (Nov. 2010), https://www.unhcr.org/ibelong/special-report-ending-statelessness-within-10years/. van Waas, supra note 14, at 52 (noting that states that do not convey nationality through birth in territory may result in the children of stateless parents inheriting their parents’ statelessness). Rosa Luxemburg Stiftung, Atlas of the Stateless 20–21, 26–27, 30–31 (2020). Fisher, Gender Discrimination, supra note 14, at 285 (noting a birth registration is essential to demonstrating nationality, whether proving parentage in a state with nationality law following jus sanguinis or proving birth in territory in a state with nationality law following jus soli principles). See, e.g., Haile v. Holder (Haile II), 591 F.3d 572 (7th Cir. 2010) (describing an asylum applicant who was stripped of Ethiopian nationality due to his Eritrean origin). Stserba v. Holder, 646 F.3d 964 (6th Cir. 2011) (describing an asylum claim for an individual of Russian descent in Estonia who was not recognized as Estonian after Estonia’s independence from the Soviet Union).