It is possible to submit a combined section 15 AND exemption application. In such an application, you would motivate that the Minister grant the client a citizenship certificate in case of doubt, and that if the Minister refuses to register the client as a citizen, that the Minister then should consider the client for an exemption for permanent residence under section 31(2)(b) of the Immigration Act. The reason this is a good option is that once a person has exhausted the options for recognition of his or her South African citizenship, the Immigration Act is the only avenue towards legal status in the Republic (given that the person is not viewed as a national). However, one must be sure to explain all options to the client and to receive instructions. The client may wish to pursue judicial review of the citizenship application prior to pursuing an exemption under the Immigration Act. We recommend that section 15 applications be hand-delivered or sent via registered mail to Home Affairs' Head Office in Pretoria, attention to the Minister of Home Affairs but copying the DirectorGeneral, Director of Legal Services and the Deputy Director-General for Civic Services. Where a decision is not reached in a reasonable timeframe (3-6 months), a judicial review application can be brought under Promotion of Administrative Justice Act for failure to make a decision. An application to compel a decision can also be brought. A negative decision can be reviewed by a High Court under section 25 of the Citizenship Act, PAJA or uniform rule 53. 5.1.7 People born in South Africa and stateless Section 2(2) of the South African Citizenship Act119 provides as follows: Any person born in the Republic and who is not a South Africa citizen by virtue of the provisions of subsection (1), shall be a South African citizen by birth, if – (a) he or she does not have the citizenship or nationality of any other country, or has no right to such citizenship or nationality; and (b) his or her birth is registered in the Republic in accordance with the Births and Deaths Registration Act, 1992 (Act 51 of 1992). This provision, if enforced, should protect against statelessness by granting any child born on South African territory citizenship if they would otherwise be stateless. South Africa is one of few African countries that have this unique provision to prevent statelessness and to protect the right to a nationality. It is furthermore remarkable that South Africa grants this right from birth – there are no requirements such as a specific length of residence. The only administrative requirement is that the birth is registered. 119 Previously section 2(4)(b) prior to the South African Citizenship Amendment Act of 2010. 84 Promoting citizenship and preventing statelessness in South Africa: A practitioner’s guide