a citizen.42 b) Deprivation / denial of citizenship: An elderly man has been recognised as a South African citizen since his birth in 1952. Throughout his life he has been issued with several identity documents, driver’s licences and he voted in every election. At the age of 70, the DHA decided to investigate his citizenship. His ID number is blocked on the system. He can no longer renew his driver's licence or use his identity document to receive his old age grant. He can no longer access free health services like other South Africans of his age to treat his chronic health conditions. At no point did the Department issue him with a formal written decision, with written reasons for the blocking, nor did they give him an opportunity to appeal the decision. The law allows him to be a citizen, but the haphazard and unlawful implementation of the laws deprive him of his citizenship. 22. Section 33 of the South African Constitution specifically protects the right to administrative justice. That is administrative action that is lawful, reasonable, and procedurally fair. Everyone whose rights have been adversely affected by administrative action has the right to be given written reasons. The Promotion of Administrative Justice Act (3 of 2000) (PAJA) provides additional directions on how to ensure an efficient administration and fair administrative practices in government decision making, especially where it seriously affects the rights of the individual. In terms of PAJA, and the Constitution, whenever a decision is made (or fails to be made) which affects an individual’s citizenship, prescribed processes must be followed which will allow the individual to challenge the state’s conduct. 23. As a last resort, an individual ought to have access to courts to seek a judicial review of administrative actions (decisions relating to citizenship) of the state. Section 25 of the South African Citizenship Act gives special statutory review powers to the High Court of South Africa to review the citizenship decisions made by the state. But these special processes are hampered by the fact that hardly any citizen can afford such legal intervention, and, even then, are hamstrung in the proceedings because of a lack of written decisions and reasons. Even where pro bono human rights lawyers intervene on behalf of indigent clients, these processes take years because of the extreme lack of due process on the part of the state. The applicant may have their citizenship restored, but they would have lost a significant number of years to statelessness unnecessarily, and potentially suffered significant prejudice in the intervening period. 24. The High Court of South Africa, in Nzama v the Minister of Home Affairs43 held that the Minister’s failure to take formal decisions on citizenship applications is a violation of the South African Constitution. In this case the applicant’s identity number was blocked for more than ten years, during which he was not able to register his children and add them to his medical aid, and to be admitted as an attorney after completing his Bachelor of Law. He was threatened with deportation, only staying in South Africa because there was no country to deport him to. During this process, he was not formally informed about the decisions regarding his citizenship, nor was he provided with written reasons by the DHA in respect of 42 Note that In South Africa, citizenship is determined at the point of birth registration. If a child is South African, a computerised birth certificate with and identity number is issued. If the child is not a citizen, or the department does not recognise them as a South Africa citizen, they are issued with a handwritten birth certificate with no identity number. Therefore the denial of a birth certificate amounts to denial of one’s South African citizenship. 43 Nzama v the Minister of Home Affairs (North Gauteng division, Pretoria) 7 March 2018. 9