of that permanent residence permit the good faith spousal relationship no longer subsists, save for the case of death.’77 • Naturalisation through habitual residence Many countries will grant nationality upon application to persons who have been habitually resident on the territory for a certain period of time. The challenge for most stateless persons is that generally, such laws require lawful entry and lawful residence, which is not possible if a person cannot obtain a travel document. • Other possibilities Other possibilities for access to permanent residence exist on grounds such as the purchase of property in the territory. Mauritius, for example, grants the right of permanent residence to any person who purchases property of more than a stated value within the territory.78 While most stateless people are impoverished and would not be able to access such a provision, this example shows that no stone should be left unturned when researching nationality law options for clients. Has the client lost or been deprived of citizenship? It is possible that a client who believes herself to be a citizen of a particular country actually lost or was deprived of citizenship unbeknownst to her. Generally, loss of citizenship is automatic (by operation of law), while deprivation of citizenship tends to be by order of a government official (for example, the Minister of Home Affairs). Persons who have naturalised are more vulnerable to withdrawal of citizenship than citizens by birth. It is important to review not only the laws which grant nationality by naturalisation to determine whether or not they apply to your client, but also those which deal with loss or deprivation of citizenship. However, even citizens by birth can lose their citizenship. For example, if South Africans obtain citizenship in another country ‘by some voluntary and formal act other than marriage’ without applying to retain to the Minister of Home Affairs to his or her citizenship, they ‘shall cease to be’ South African citizens.79 77 78 79 46 Section 26 of the Act, as amended by the South African Immigration Amendment Act No. 13 of 2011. Elma Global, ‘Immigration and Permanent Residency in Mauritius’ available at http://www.second-citizenship.org/permanent-residence/immigration-and-per manent-residency-in-mauritius/ (accessed 3 October 2013). Section 6(1)(a) of the South African Citizenship. Promoting citizenship and preventing statelessness in South Africa: A practitioner’s guide