The South African Constitutional Court ruled that the Births and Deaths Registration Act was unconstitutional because it discriminated against unmarried fathers by failing to permit them to register the birth of their child.155  The Bahamas Court of Appeal confirmed a High Court judgment that discrimination on the basis of sex of the parent in transmission of citizenship to children was unconstitutional, and that all children of a Bahamian mother and foreign father born since independence in 1973 should be deemed to be citizens.156 Material remedies International and regional human rights treaty bodies have on occasion ordered national authorities to assess damages in respect of violations connected with nationality and legal status in a country—or directly awarded financial compensation, although generally at a modest level. For example:  In the case of DZ v. The Netherlands, the UN Human Rights Committee required the Netherlands to provide the author with an effective remedy, including adequate compensation (as well as legal reforms).157  The Inter-American Court ordered payment of US$8,000 to each girl in the Yean and Bosico case as compensation for the harm done158; in the Expelled Dominicans and Haitians case, the court awarded US$10,000 compensation to each person.159  In the case of Hoti v. Croatia, concerning the situation of individuals erased from the register of those with residence in Croatia, the European Court of Human Rights awarded €7,500 to those affected.  In the case of Keita v. Hungary, concerning a stateless person unable to regularise his status, the European Court of Human Rights awarded €8,000 in respect of non-pecuniary damages.160  In the similar case of Kurić and Others v. Slovenia, the ECtHR awarded €20,000 to each of the six successful applicants in respect of non-pecuniary damage for discriminatory erasure from the national population register. Slovenia was also ordered to set up a domestic compensation scheme in respect of pecuniary damage.161  In Mennesson v. France the European Court of Human Rights awarded €5,000 to each of the two children affected by non-recognition of a their biological father in the civil registry in a case of surrogacy.162  In the case of Anudo v. Tanzania, the African Court on Human and Peoples’ Rights awarded the complainant and members of his family a total of TZS 229,200,000 (roughly US$90,000) for pecuniary and non-pecuniary damages, in addition to ordering Tanzania to allow him to return to the territory and restore his nationality.163  The case of Lakatosh and others v. Russia, brought to the European Court of Human Rights by stateless Roma in relation to their prolonged detention pending planned deportation, was settled on the basis of payment of €30,000 to each applicant.164 Injunctive remedies: individual relief, legal and procedural reform In seeking structural reforms that will benefit not only the plaintiff but also a wider group of people affected by similar problems, a court may be requested to issue an injunction requiring the competent authorities to reform the law or procedures. The first questions to ask in seeking such remedies will focus on the causes of non-recognition of nationality or nonissue of identity documents, and therefore what the solutions are. A detailed understanding of different laws and procedures may be required to explain the situation of plaintiffs with different personal histories or characteristics, in order to specify the remedies requested from the court (u focus box F). Centre for Child Law v. Director-General Dept of Home Affairs and Others, Case CCT101/20 ; [2021] ZACC 31, Constitutional Court of South Africa, Judgement of 22 September 2021, https://www.concourt.org.za/index.php/judgement/410-centre-for-child-law-v-director-general-dept-of-home-affairs-and-otherscct101-20. 155 The Attorney General v. Shannon Tyreck Rolle et al, Court of Appeal of the Commonwealth of the Bahamas, Case No. 62 of 2020, Judgement 21 June 2021, https://www.courtofappeal.org.bs/judgments.php?action=view&judgment=3629. 156 157 DZ v. The Netherlands, supra n 53. 158 Case of the Girls Yean and Bosico, supra n 52. 159 Expelled Dominicans and Haitians, supra n 64. Hoti v. Croatia, supra n 132; Sudita Keita v. Hungary, Application no. 42321/15, European Court of Human Rights, Judgment of 12 May 2020, https://hudoc. echr.coe.int/eng?i=001-202433. 160 Kurić and Others v. Slovenia, supra n 133; for more on the domestic compensation scheme see Kurić and Others v. Slovenia, Application no. 26828/06, European Court of Human Rights, Grand Chamber (Just satisfaction), 12 March 2014, https://hudoc.echr.coe.int/eng?i=001-141899. 161 162 Mennesson v. France, Application no. 65192/11, European Court of Human Rights, Judgment of 26 June 2014, https://hudoc.echr.coe.int/eng?i=001-145389. Anudo Ochieng Anudo v. United Republic of Tanzania, Communication No. 012/2015, African Court on Human and Peoples’ Rights, decision on reparations, 2 December 2021, https://www.african-court.org/cpmt/details-case/0122015. 163 Anna Lakatosh and Others v. Russia, European Court of Human Rights, Application no. 32002/10 Decision of the First Section, 7 June 2011, https://hudoc. echr.coe.int/#{%22itemid%22:[%22001-105325%22]}. UNHCR submitted a third party intervention in this case: UNHCR intervention before the European Court of Human Rights in the case of Lakatosh and Others v. Russia, March 2011, https://www.refworld.org/jurisprudence/amicus/unhcr/2011/en/77748. 164 U N H C R | L I T I G AT I N G T H E R I G H T T O A N AT I O N A L I T Y: A G U I D E F O R P R AC T I T I O N E R S 49