Clients rejected for late registration of birth If the reason for the rejection is that the application does not meet the requirements for LRB contained in regulation 4 and 5, it may be necessary to apply for a certificate of citizenship in cases of doubt in terms of section 15 of the Citizenship Act (see par. 5.1.6). If the reasons are not justified in term of the Act or Regulations, or if no reasons are received within 90 days, the decision may be taken on judicial review. Should the Department decline to approve a client’s application for late birth registration, the client is entitled to written reasons for the decision in terms of section 5 (1) of PAJA. The first step which you can take on behalf of your client is thus to request that such written reasons be provided. If you either receive written reasons and the reasons are unsatisfactory, or you do not receive any response to your request, your clients will have grounds for the judicial review of this decision or an internal appeal of the decision. According to section 5 (2) of the PAJA, the reasons given for the Department’s decision to refuse to approve your client’s application must be ‘adequate’. It is also stipulated in section 5 (3), that the decision will be regarded as being taken without good reason should the local office fail to provide adequate written reasons. You may decide to pursue judicial review of the decision at the outset. Your client is entitled to this procedure. It may be more effective, however, in practice, to refer the application and the reasons for its refusal to either the District Manager or the Deputy Director-General for Civic Services. If the client and his witness are at any stage called in for interviews, prepare the client and witnesses for this interview. Request to be present at the interview ahead of time (see section 3(3)(a) of PAJA; legal representation may be necessary to protect the client's right to just administrative action). The client and his/ her witness will be interviewed separately and their answers will be compared against each other to evaluate credibility and veracity. Advise your client's witness not to make any statements to which they do not have personal knowledge. Accompany the client and his witness to the interview and ask for minutes to be given to you following the interview. Birth to a single father or to an undocumented mother and South African father 76 Promoting citizenship and preventing statelessness in South Africa: A practitioner’s guide