A Study of Statelessness in South Sudan - 2017 applicants to run the risk of statelessness”.64 This demonstrates lack of understanding of the concept, causes, and risks of statelessness. Oversight mechanisms are reportedly in place within the DNPI to ensure compliance with legislation. A DNPI staff member in Juba notes, “There are senior officers in each section who are responsible for making sure the issuing officers conform to the provisions of Nationality Act, and such senior officers will then advise or address any problems with the concerned junior officers”. 65 However, if the capacity of senior officers is also called into question, there is a need for additional training at all levels. Finally, rejected applicants have the possibility of initiating an administrative appeal and/or seeking judicial redress as per Sections 8592 and Sections 93-97 of the Regulations (Administrative Appeal and Judicial Redress respectively). The Director of the DNPI explains: “An aggrieved party can lodge his or her complaint with the Minister of Interior within six months from such rejection by issuing authority”.66 However, FGDs revealed very limited awareness of the possibility of appeal. One FGD participant in Aweil argued, “There is no administrative system in place where individuals could get fair hearing concerning their rejected applications”.67 Moreover, Sections 93 and 94 of the Regulations make it unclear whether administrative appeals are a necessary first step before judicial redress. Procedural Irregularities In addition to capacity limitations, there are some disturbing reports of procedural irregularities at the DNPI, as illustrated by the following two quotes: “We have applied for the nationality certificates, but until now we have not received it. What the officers told us is that we should go through the window (which 64 65 66 67 68 69 70 71 22 KII with DNPI Staff in Juba; KII with DNPI Staff in Aweil. KII with DNPI Staff in Juba. Conversation with the Director of the DNPI, Juba. FGD with female Falata in Aweil. FGD with male Madi and Acholi in Nimule. KII with CSO Staff in Nimule. Marko (2016), p.674. Ibid. means we should give bribe). Unfortunately, at that time we were broke”.68 “I see people who are advantaged economically or those who have money— they just give officers money and their process of getting nationality is fastened. And those who are disadvantaged have to follow the normal procedure”.69 As will be discussed further below, the cost of applying for nationality certificates already represents a significant barrier. If compounded by alleged additional financial requirements, access to the nationality application procedure is further undermined. Discriminatory Practices Discriminatory practices within the DNPI are problematic and contribute to furthering the risk of statelessness in South Sudan. The first notable trend is the importance accorded to ethnicity under Article 8(1)(b), which stipulates that an applicant will be considered for nationality by birth if “such a person belongs to one of the indigenous ethnic communities of South Sudan”. Despite the existence of alternative pathways to South Sudanese nationality, one researcher notes, “The overwhelming majority of citizenship applicants need to prove their ethnic affiliation […], which suggests a return to the colonial logic”.70 Ferenc David Marko suggests that an applicant is “never considered strictly as an individual” but rather as an extension of his or her ethnic group.71 This, in practice, means that the ethnic group to which an applicant subscribes will be the basis for whether he or she is successful in obtaining nationality documents. Unless nationality is acquired on the basis of Section 8(1)(b), the Nationality Act does not allow for this interpretation, which is a clear violation of both international law and article 14 of the Transitional Constitution of South Sudan, which prohibits