 allow children born in the Republic whose parents are not citizens and who are not admitted for permanent residence to qualify to apply for citizenship if they have lived in Republic until age of majority. We set out hereunder the specific regulations which we believe to be either unconstitutional (violating the rights in the Bill of Rights) or ultra vires (in that the regulation is wider than the Act provides for or amounts to an amendment of the provisions of the Act), or is otherwise in conflict with the government intentions stated above. We also point out where our courts have found sections of the regulations to be unconstitutional or have read in words to the regulations, which must be taken account in drafting the amendments. We trust our comments will contribute to the overall quality of the regulations and its ability to foster and ensure universal birth registration in South Africa. Sincerely, CENTRE FOR CHILD LAW RIGHTS Per: Anjuli Maistry LAWYERS FOR Per: Liesl Muller 4 HUMAN