a liberal order imposed largely from the outside,”88 the cabinet instructed the Ministry of Justice to draft the new law in universal and liberal terms of nondiscrimination while sustaining discrimination based on race. Not surprisingly, it proved to be an impossible task. The cabinet rejected all the ministry’s drafts, for it considered the idea of putting Jewish citizenship on par with that of Palestinians outrageous. It went against the raison d’être of the state. The United Religious Front’s Zerach Warhaftig, a lawyer who later served as a Knesset member and as a cabinet minister, offered a solution to this conundrum. In a report prepared for the Ministry of Justice, Warhaftig suggested the legislation of two laws instead of one.89 The first, the Law of Return, which was enacted in 1950, provides every Jew the right to immigrate to Israel (aliyah) and to be granted automatic citizenship rights. The second, the Citizenship Law of 1952, was designed to govern the citizenship of Palestinians and other non-Jews. In making the case for his suggested model, Warhaftig referred to the experience of other countries, naming Australia, Canada, the United States, and South Africa. The reference to other settler colonial states was not arbitrary. In these countries, the relationship between race, citizenship, and migration laws is an intimate one. When presenting Warhaftig’s report to the cabinet, Minister of Justice Pinchas Rosen described the citizenship regimes of those countries as “discriminating racially in their immigration laws between different races, but not in their citizenship laws.”90 He therefore recommended, based on Warhaftig’s report, that “the principle of Jewish preferability ought to be enshrined in the politics of aliyah, but not citizenship.”91 Australia, in particular, served as a source of inspiration for Warhaftig. His model was a mimetic of the White Australia policy, which was Australia’s immigration policy until 1973. It guaranteed the immediate naturalization of white British migrants and restricted the naturalization of nonwhites.92 The Law of Return, alongside restrictions on the naturalization of non-Jews, particularly Palestinians, was Israel’s own version of the White Australia policy. Despite Israel’s claim to exceptionalism, a position that Ben Gurion held, Warhaftig was well aware that Israel was not inventing the wheel. At the first meeting of the legislative committee mandated to work on the bill, Attorney General Chaim Cohen commented that Israel's citizenship regime was globally unique in extending citizenship to persons immediately upon their entry to the country. Warhaftig immediately corrected him: “There is such an example—the British in Australia.”93 26 Electronic copy available at: https://ssrn.com/abstract=3533490