21 | PROTECTING STATELESS PERSONS FROM ARBITRARY DETENTION IN MALTA 4. CONCLUSION AND RECOMMENDATIONS In the Maltese context, it appears that the issue of statelessness is not yet visible enough to push the state to introduce a system of identification and protection specific to the needs of stateless people and persons at risk of being stateless. On the other hand, there is fear that accession to the Convention would lead to “a strain of the system”, in itself a paradox as the numbers appear so negligible. The specific situation of detained persons is in fact problematic due to the broader human rights concerns related to Malta’s detention regime, with detention for purposes of removal presenting itself as particularly problematic in the case of stateless persons, or persons at risk thereof. stateless, present themselves as such. In this regard, the positive efforts of the Office of the Refugee Commissioner are noted. Also noted are the comments by the Ministry regarding possible accession to the 1954 Convention, and its openness at discussing details with civil society organisations. On the basis of the above, the following recommendations are made. Both aditus and ENS stand ready to constructively engage in a technical discussion with the relevant stakeholders, and provide all relevant information and input: 1. It is nonetheless positive to note ad hoc attempts at granting, as a minimum, national protection, to persons who although not formally identified and processed as State authorities should collect accurate data regarding stateless persons, including those in detention. Data on statelessness is necessary to ascertain the extent of the problem and to design

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