Nationality and Cases of Statelessness in the Middle East and North Africa how the respective French and British perspectives on nationality impacted the initial post-independence nationality acts of MENA states – or indeed their influence throughout the world – remains, to the best of our knowledge, outstanding and goes beyond the scope of this study. However, it is clear that there was a strong “foreign” influence in the drafting of contemporary MENA states’ first nationality acts, the backbones of which are largely still in place today. Not with standing the impression made by the Ottoman, French and British approaches to nationality, the development of modern MENA states’ nationality law was also influenced from the very beginning by factors which are specific to the region. Arguably the strongest of these are the Arab culture or social structure and the predominance of Islam.53 There is therefore a fusion of legal models. For instance, in Oman, the legal system is based on English common law but the Constitution also identifies Sharia as the basis for the country’s legislation. Within Arab, Muslim society, there is a strong emphasis on familial or tribal ties, as well as a social and religious conception of these structures as patriarchal and patrilineal. This has influenced the adoption and retention of certain 53 - See for a detailed discussion of the notion of citizenship under Islam, N. Salam, “The emergence of citizenship in Islamdom” in Arab Law Quarterly, Vol. 12, No. 2, 1997. 48