Cassadee Orinthia YAN International Comparative Jurisprudence. 2024, 10(1):94-111. regardless of parental nationality. The divergent strategies employed by these nations underscore their differing approaches to citizenship. Kenya and South Africa have recognized the issue of statelessness and have initiated measures to address it. In Kenya, a government initiative was launched in 2016 to find stateless individuals and provide them with identity cards so that they can receive essential services. Challenges remain, however, including the need for precise methods for identifying statelessness. While statelessness is less prevalent in South Africa than in Kenya, administrative hurdles and a lack of documentation can pose difficulties for immigrants and refugees. Notably, gender plays a contrasting role in the legal frameworks of these nations. Kenya has taken steps to rectify gender discrimination, particularly concerning women’s rights. Children born outside Kenya to non-Kenyan fathers could not previously be granted nationality by their mothers. However, this prejudice has been corrected by various constitutional revisions. South Africa, on the other hand, ensures equal citizenship rights for both sexes, irrespective of birthplace and parental nationality. Despite their legislative frameworks, Kenya and South Africa encounter administrative and implementation-related challenges in enforcing their citizenship rules and addressing statelessness. Kenya would benefit from further support in translating legal requirements into effective practices, including enhancing understanding among authorities and prospective beneficiaries and establishing a clearly defined procedure for identifying statelessness. Similar administrative complexities might arise in South Africa, especially for immigrants and refugees who need help in order to obtain documents and navigate the system. References Abuya, E. O. (2021). Registering persons at risk of statelessness in Kenya: Solutions or further problems? In T. Bloom & L. N. Kingston (eds.), Statelessness, governance, the problem of citizenship (pp. 251–263). Manchester University Press. https://doi.org/10.7765/9781526156426.00032 African Commission on Human and Peoples’ Rights v. Kenya (merits). (2017). African Court Law Report, 2 (2017–2018), 9– 64. https://www.african-court.org/wpafc/wp-content/uploads/2020/04/African-Court-Law-Report-Volume2-2017-2018.pdf African Charter on Human and Peoples’ Rights (1981). https://au.int/sites/default/files/treaties/36390-treaty-0011__african_charter_on_human_and_peoples_rights_e.pdf African Charter on the Rights and Welfare of the Child. (1990). Adopted by the 26th Ordinary Session of the Assembly of Heads of State and Government of the OAU African Union, Addis Ababa. Ahsan Ullah, A. (2016). Rohingya crisis in Myanmar: Seeking justice for the “stateless”. Journal of Contemporary Criminal Justice, 32(3), 285–301. http://dx.doi.org/10.1177/1043986216660811 Akstinienė, A. (2017). Consequences of reservations to international human rights treaties, concluded in the aftermath of WWII. International Comparative Jurisprudence, 3(1), 104–114. https://doi.org/10.13165/j.icj.2017.03.009 Albarazi, Z. (2014). No legal bond, no family life. Tilburg Law Review, 19(1–2), 11–19. https://doi.org/10.1163/2211259601902002 Alfasi, N., & Fenster, T. (2014). Between socio-spatial and urban justice: Rawls’ principles of justice in the 2011 Israeli Protest Movement. Planning Theory, 13(4), 407–427. https://doi.org/10.1177/1473095214521105 Baird, N. (2020). Stateless person. In R. Grote, F. Lachenmann & R. Wolfrum (eds.), Max Planck Encyclopedia of Comparative Constitutional Law. Oxford University Press. Balaton-Chrimes, S. (2013). Indigeneity and Kenya’s Nubians: seeking equality in difference or sameness? The Journal of Modern African Studies, 51(2), 331–354. https://doi.org/10.1017/S0022278X13000049 Batchelor, C. A. (1998). Statelessness and the problem of resolving nationality status. International Journal of Refugee Law, 10(1–2), 156–182. https://doi.org/10.1093/ijrl/10.1-2.156 Birkvad, S. R. (2019). Immigrant meanings of citizenship: mobility, stability, and recognition. Citizenship Studies, 23(8), 798– 814. https://doi.org/10.1080/13621025.2019.1664402 108