DPCE online, 2020/4 – Saggi ISSN: 2037-6677 Governing through uncertainty? Migration Law and governance in a comparative perspective de-naturalisation that may put a person at risk of loss of EU citizenship and statelessness ‘falls, by reason of its nature and its consequences, within the ambit of European Union law’28. In 2017, in the case Staatssecretaris van Veiligheid en Justitie29, the CJEU ruled on the application of the provision related to stateless minors, and opted for teleological interpretation. Two years later, with the Tjebbes case30, the CJEU had another opportunity to pronounce in nationality matters. The latter case has not resurrected the concept of independence of EU citizenship from the national citizenship, which was buried in the early stages of the EU Constitution project. However, the fact that yet another example contributed to the EU case law on nationality matters, may be relevant in statelessness matters with further juridical developments. Arguably, the case Staatssecretaris van Veiligheid en Justitie might become acknowledged as one of the landmark cases related to statelessness in the context of forced migration. Within the broader context of international law, the EU had several attempts to show its involvement in addressing statelessness. The pledge, made by the EU Delegation to the United Nations in 201231, included an entire paragraph (out of four in the section on ‘strengthening the rule of law at the international level’) dedicated to addressing the issue of statelessness. Interestingly enough, the formulation used in the document – ‘the European Union and its Member States’ - implies that the question concerned shared competences, otherwise it would have been formulated in a different manner (‘the European Union’ in the domain of EU exclusive competences and the ‘Member States of the European Union’ for the domains that do not fall under EU competences). Three years later, the pledge has been referred to in the Council conclusions32. The promise by the ‘EU Member States which have not yet done so’ to ratify the 1954 Convention and to consider the ratification of the 1961 Convention was recalled in the Council document. The note verbale and the Council conclusions – both non-legally binding documents, have not produced immediate results. As of mid-2020, among the EU Member States, there were only 20 ratifications of the 1961 Convention and 24 ratifications of the 1954 Convention (whereas Cyprus, Estonia and Poland have not acceded to it33). Nevertheless, several practical implications occurred, such as transforming the already existing 28 C-135/08, para 42 29 EJEU, 12-4-2018, C-550/16, A and S. 30 EJEU, 12-3-2019, C-221/17, Tjebbes and Others. 31 Delegation of the European Union to the United Nations, Pledge registration form of the European Union and its Member States, New York, 19 September, 2012, 3, available at www.un.org/ruleoflaw/files/Pledges%20by%20the%20European%20Union.pdf, accessed 77-2020. 32 Press release 893/15: Conclusions on statelessness adopted by the Council and the Representatives of the Governments of the member states, 2015, available at www.consilium.europa.eu/en/press/press-releases/2015/12/04-council-adoptsconclusions-on-statelessness/, accessed 7-7-2020. 33 Noteworthy is the fact that Malta accessed the treaty in 2019, while the United Kingdom has withdrawn from the European Union, thus leaving the number of EU Member States – parties to the 1954 Convention unchanged. 5264