Peter Spiro
The allocation of Comoros citizenship to stateless bidoons has drawn similar fire. Although
nominally volitional, bidoons were reportedly pressured into accepting Comoros citizenship through
ruses. For example, authorities created the impression that only by accepting Comoros citizenship
would individuals be eligible for citizenship in the UAE. UAE authorities also reportedly made eligibility
for basic social services contingent on taking the Comoros passport (see Noora Lori’s book ‘Offshore
Citizens’ for a definitive account).190
Whether or not these actions violate international law implicates factual questions – empirical,
in Eleanor Knott’s formulation.191 To the extent that naturalization is nonconsensual, it is inconsistent
with international law. That norm is clear, one of the few hard constraints under international law
on state nationality practice. Whether the Russian and UAE actions violate this norm is a question
that is being hashed out through the standard machinations of international law – a kind of act-andresponse dynamic in which an array of international legal actors judge the legality of state conduct.
Consent remains the touchstone, a standard we’re now looking to refine through practice.
Through this lens, Russia’s passportisation in Crimea (at least following the occupation) and the
UAE’s Comoros action appear inconsistent with the volitional naturalisation norm and international
law. To the extent there is a problem here we already have the answer. That may not stop other
countries from putting citizenship to ill use of course. No law enjoys perfect compliance, international
law less than others, to be sure, given its horizontal structure. But these and other recent examples
of putatively weaponised citizenship will supply no validation for bad behaviour in the future.
190 Lori 2019.
191 Knott 2022.
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Robert Schuman Centre for Advanced Studies