38.2 (7) TEMPROSA.DOCX38.2 (7) TEMPROSA.DOCX (DO NOT DELETE) 244 BERKELEY JOURNAL OF INTERNATIONAL LAW 1/16/2021 12:59 PM [Vol. 38:2 August 2019, declared more than 1.9 million people, mainly from the state of Assam, on the verge of statelessness. 11 At the individual level, take the tales of two women from across the Atlantic as recent demonstrations of the pervasive, almost plenary, power of the State over inclusion and exclusion. In November 2014, Hoda Muthana from the United States, and in February 2015, Shamima Begum from the United Kingdom left their home countries. Muthana and Begum married Islamic State fighters and had children in Syria. When the Islamic State began to fall, both desired to return home. But both States denied their return because the women lacked citizenship. 12 According to the US Department of State, Muthana was not a US citizen, had no legal basis for return, did not hold a US passport, the right to a passport, or possess a visa to travel to the United States. 13 Meanwhile, the United Kingdom intended to strip Begum of citizenship based on an amendment to its nationality law. The amendment allowed the UK Secretary of State to deprive individuals of citizenship if "conducive to the public good because the person, while having that citizenship status, has conducted him or herself in a manner which is seriously prejudicial to the vital interests of the United Kingdom." 14 These stories are not unique. Our world, at least as far as citizenship is concerned, is largely statist. The State decides who a citizen is and who is stateless. 15 International law embraces this truth: the 1954 Convention Relating to the Status of Stateless Persons (1954 Statelessness Convention) defines a "stateless person" as a "person who is not considered as a national by any State under the operation of its law." 16 In embracing the power of the State to say who a stateless person is 11. See M. Mohsin Alam Bhat, Twilight Citizenship, https://privpapers.ssrn.com/sol3/papers.cfm?abstract_id=3603707&dgcid=ejournal_htmlemail_law:courts:ejournal_abstractlink (last visited Aug. 24, 2020). 12. See Jonathan Shaub, Hoda Muthana and Shamima Begum: Citizenship and Expatriation in the US and UK, LAWFARE (Feb. 25, 2019), https://www.lawfareblog.com/hoda-muthana-andshamima-begum-citizenship-and-expatriation-us-and-uk. Although both Muthana and Begum's situations also concern issues of revocation of citizenship and denial of return to countries of citizenship or habitual residence, they also engage with what statelessness is. See also Steve Vladeck, Unpacking (Some of) the Legal Issues Surrounding Hoda Marijuana, JUST SEC. (Feb. 20, 2019), https://www.justsecurity.org/62659/unpacking-some-of-issues-surrounding-hoda-muthana. 13. U.S. DEP'T OF STATE, Statement on Hoda Mutha, https://www.state.gov/statement-on-hodamuthana/ (last visited Apr. 15, 2019). 14. Immigration Act, 2014, c.22, § 17(3) (Eng.). The UK Secretary of State must have reasonable grounds to believe that the person being stripped of citizenship will be able to become a national of another country or territory, or in other words, that they will not become stateless. 15. See Annemarieke Vermeer-Künzli, Diplomatic Protection as a Source of Human Rights Law, in THE OXFORD HANDBOOK OF INTERNATIONAL HUMAN RIGHTS LAW 250, 253 (Dinah Shelton ed., 2013). 16. Convention Relating to the Status of Stateless Persons, art. 1(1), Sept. 28, 1954, 360 U.N.T.S. 117 [hereinafter, "1954 Statelessness Convention"]. This Article will not engage in a discussion of the categories of people to whom the Convention does not apply as stated in article 1(2) of the Convention since they do not modify the general definition of statelessness.