Report on Citizenship Law: Nigeria although the presumption in international law is that nationality would follow habitual residence, unless otherwise agreed.58 Nigeria initially rejected the judgement, but in 2006, a UN-brokered bilateral agreement was reached on its implementation. As regards the nationality of those resident in the areas awarded to Cameroon, who are largely Efik people of the old Calabar kingdom, the agreement was that Cameroon guaranteed fundamental rights and freedoms to Nigerian nationals, and promised not to force Nigerian nationals living in the transferred territories to leave their homes nor to change their nationality.59 The territory was formally handed over to Cameroon on 14 August 2008, though a Nigerian presence remained during a five-year transitional period. The understanding seems to have been that at the end of the transitional period, residents in the transferred territories could become Cameroonian with the right to Cameroonian identity documents; but could also remain Nigerian with resident alien status in Cameroon, or leave what was now Cameroon and resettle in Nigeria.60 But the legal authority to enable these outcomes on either side of the border was left unclear. On the Nigerian side, no constitutional amendments were proposed similar to those for the Northern Cameroons following the postindependence referendums, in order to provide for the nationality status of those who relocated to the Nigerian side of the new border from zones in the former Northern and Southern Cameroons that had now been decided were part of Cameroon. Nor was any action taken to provide ongoing access to recognition of Nigerian citizenship for those whose homes were now in Cameroon. The government of Cross Rivers State in Nigeria purported to carve out a new local government area for the Bakassi displaced—though it had no constitutional authority to do so—and granted or facilitated some humanitarian assistance.61 The former Bakassi residents were denied the right to vote in various elections, since the locations where they were registered no longer exist; there was litigation by the Independent National Electoral Commission on this point.62 In February 2014, the Nigerian Attorney General of the Federation and Minister of Justice, Mr. Mohammed Adoke, speaking at the opening of the 32nd Session of the Mixed Commission, was reported as stating that those affected by the judgment who wished to be Nigerian should ‘apply for Nigerian citizenship’ implying that they needed to naturalise, rather than obtain recognition of ongoing nationality from birth.63 Since then, there has been no http://www.icj-cij.org/en/case/94. For a detailed history of the dispute, the court case and its aftermath, see Hilary V Lukong, The Cameroon-Nigeria Border Dispute: Management and Resolution, 1981-2011 (Langaa Research & Publishing Common Initiative Group 2011). 58 ILC, Draft Articles on Nationality of Natural Persons in relation to the Succession of States, article 5. 59 Greentree Agreement, Article 3(2): ‘Cameroon shall : a) Not force Nigerian nationals living in the Bakassi Peninsula to leave the zone or to change their nationality …’. 60 ‘Bakassi - more than one place, more than one problem’, IRIN, 13 November 2007; Le temps des realisations: Bulletin mensuel bilingue d’informations N° 14, Special Edition on Bakassi, Government of Cameroon, August/September 2013. 61 The National Commission for Refugees, Migrants and Internally Displaced Persons was reported by the Cross River State government to have distributed relief supplies to more than 1,500 households in two local government areas in the state. ‘Bakassi, Akpabuyo Refugees Get Relief from Refugees Commission’ Cross Rivers State government, 29 July 2013. 62 Chidi Anselm Odinkalu, ‘Stateless in Bakassi: How a Changed Border Left Inhabitants Adrift’ Open Society Foundations, 2 April 2012, available at https://www.opensocietyfoundations.org/voices/stateless-bakassi-howchanged-border-left-inhabitants-adrift; Jude Okwe, ‘INEC - Bakassi May Not Participate in 2015 Elections’, This Day (Abuja), 4 April 2014. 63 Dele Ogbodo, ‘Greentree Agreement: FG Advises Bakassi Indigenes to Apply for Nigerian Citizenship’, This Day, 3 February 2014 18 RSCAS/GLOBALCIT-CR 2020/12- © 2020 Author(s)