CChapter 3: Comparative analysis of nationality laws Saudi Arabia, being of Muslim faith is reported to be an implicit requirement for naturalisation, given that good behaviour – an explicit condition in the nationality law – must in practice be proven by a certificate signed by the Imam in the person’s place of residence.177 While discussing the pervasion of religion into the sphere of nationality policy, it is also worth noting the influence of Islamic Shari’a law within the overall domestic legal systems of MENA countries. In much of the region, Shari’a dominates the areas of family law and personal status law, which can have a knockon effect for the enjoyment of nationality. A clear example of this is the absence, in many countries, of a legal framework for adoption. As such, most nationality laws make no provision for the acquisition of nationality through adoption – itself an unrecognised legal concept.178 This may create problems for the enjoyment of nationality by children who have been abandoned, if their parentage is unknown but they are also unable to benefit from the legal provisions guaranteeing a nationality for foundlings. In Lebanon, Decree, EUDO Citizenship paper, 2011, available at: http://eudo-citizenship.eu/ docs/LEB-1994NaturalizationDecree-GuitaHouraniNov2011.pdf. 177 - G. Parolin, Citizenship in the Arab World. Kin, Religion and Nation State, Amsterdam University Press, 2009, page 103. 178 - For instance article 7(3) of the Covenant on the Rights of the Child in Islam states that “the child of unknown descent […] shall have the right to guardianship and care but without adoption”. 135