2016] The Protection of Stateless Persons in Australian Law 429 connection, then the burden should shift to Australia to prove that the individual is a national of a particular country.141 Second, PAM3 appropriately states that: decision-makers must consider all available information, including written claims, documentary evidence and oral evidence provided by the applicant, as well as country of origin information … or any paper on CISNET [a departmental database] relating to the country where the applicant resided or cohort to which they belong, and they must not rely solely on a person’s claims of being stateless.142 However, PAM3 suggests that a decision-maker ‘should try to attain a level of satisfaction as to the identity of an applicant making claims of statelessness’,143 and, in particular, ‘must assess an applicant’s claims of statelessness against the laws of the country/countries of former habitual residence to determine whether the applicant could be entitled to citizenship’.144 Even more concerning is the idea that a person ‘might have an unexercised entitlement to residence or citizenship in another country [other than the country of former habitual residence]’,145 which could include a country to which the applicant has never been. This notion that a person ‘could be entitled to citizenship’146 is at odds with the clear view of the UNHCR that nationality ‘is to be assessed as at the time of determination’ and is not ‘a predictive exercise.’147 Hence, whether or not a person could be entitled to citizenship is arguably irrelevant to assessing his or her protection needs.148 Furthermore, a mere ‘entitlement 141 This contention draws on UNHCR, Geneva Conclusions, above n 136, 4 [13]. 142 Department of Immigration and Border Protection (Cth), PAM3, above n 93, 127 [81]. 143 Ibid 129 [86.1]. 144 Ibid 129 [86.3] (emphasis added). 145 Ibid 130 [87.1] (emphasis added). 146 Ibid 129 [86.3]. 147 UNHCR, Handbook on Protection of Stateless Persons, above n 20, 20 [50]. 148 The only exception in the context of the Refugee Convention is inchoate nationality, but this needs to be understood in a very narrow sense: see Hathaway and Foster, above n 7, 57–64. The PAM3 is a bit confused on this point. It attempts to distinguish between an enforceable versus discretionary right to citizenship, but then notes that ‘it may be possible to encourage the applicant to apply for that citizenship if they are found not to engage Australia’s protection obligations and are on a removal pathway’: Department of Immigration and Border Protection (Cth), PAM3, above n 93, 130 [87.1].