Statelessness & Citizenship Review 2021 3(1) have on a person’s social identity, thus ruling that such denial of citizenship could be in contravention of art 8. 55 Furthermore, two recent developments in international legal scholarship can support the argument in this article linking right to life and the obligation not to render persons stateless. Firstly, Michelle Foster and Hélène Lambert argue that denial and withdrawal of nationality on one of the grounds on which refugee status is granted should give rise to a legitimate claim for refugee status. 56 They also detail jurisprudence where violations of civil and political rights in connection with such denial or withdrawal amounts to persecution. 57 Furthermore, they identify that in few cases, even denial of socio-economic rights of stateless persons could amount to persecution. 58 Secondly, Cóman Kenny argues that statesanctioned statelessness caused by mass arbitrary deprivation of nationality could amount to crimes against humanity and genocide, depending on the circumstances. 59 These developments reveal that the right to have rights is so important that their deprivation or denial or the consequent denial of human rights can amount to persecution under international refugee law or to international crimes under international criminal law. Since human dignity and the right to life are values on which both refugee protection and international criminal justice are premised, these developments support drawing a link between the obligation not to render persons stateless which is premised on human dignity and the right to life. 60 IV THE MEANING OF ‘LIFE’ UNDER ART 21 OF THE CONSTITUTION AND THE INTERNATIONAL OBLIGATION NOT TO RENDER PERSONS STATELESS Having established in the previous section that under international law, an inference can be drawn between the right to life and the obligation not to render persons stateless, this section shows how life is affected in a situation of statelessness in India. Thereafter, it examines the meaning of ‘life’ under art 21 and analyses the obligation not to render persons stateless through the lens of ‘life’ under art 21. A ‘Life’ in a Situation of Statelessness in India India with China, Indonesia and Nigeria accounts for about 42% of the world’s stateless population. 61 However, due to issues with reporting, there is no concrete 55 56 57 58 59 60 61 Genovese (n 17) [33]. See also Hoti v Croatia (European Court of Human Rights, First Section, Application No 63311/14, 26 April 2018) [119]–[123]. See Foster and Lambert (n 19) 157. ibid 173. ibid 142. Cóman Kenny, ‘Legislated Out of Existence: Mass Arbitrary Deprivation of Nationality Resulting in Statelessness as an International Crime’ (2020) 20(6) International Criminal Law Review 1, 34. Clara Laverty, ‘What Lies Beneath? The Turn to Values in International Criminal Legal Discourse’, EJIL Talk! (Blog Post, 23 April 2018) available at <https://www.ejiltalk.org/what-lies-beneath-the-turn-to-values-in-international-criminallegal-discourse/>; Christian Walter, ‘Hospitality and Integration of Migrants and Refugees’ in Andrea Gattini, Rosana Garciandia and Philippa Webb (eds), Human Dignity and International Law (Brill 2020) 182. Lily Chen, Petra Nahmias and Sebastian Steinmueller, UNHCR Statistical Reporting on Statelessness (Statistics Technical Series Report 2019/1, UNHCR October 2019) 1. 194