by law-makers or the courts, it is unclear if the guarantee encompasses equality before the law as per the standards laid out in international human rights treaties. Attendees at the Focus Group in the North did not refer to any restrictions in access to legal aid, though the unavailability of quality legal assistance in rural areas was noted by representatives of local NGOs. In the South, participants pointed out that the cost of legal services is unaffordable to them. Legal NGO clinics operating in the field, including UNHCR’s implementing partners, remain the most effective means of delivering free legal aid to stateless populations. 4.7 Expulsion The Code on Administrative Violations of the Kyrgyz Republic provides for the administrative expulsion of foreigners and stateless persons for the breach of residence and sojourn rules in the Kyrgyz Republic (Article 39). The 2000 External Migration Law also includes an administrative expulsion for a person who does not comply with an order from internal affairs or national security agencies to leave the Kyrgyz Republic after the expiration of their visa or an annulment of their residence permit (Article 19). It further lists the following additional grounds for which an administrative expulsion can be issued: if the person concerned acted against the interests of national security or the protection of public order; or if it is necessary for the protection of public healthcare and public morals, rights and legitimate interests of Kyrgyz citizens and other persons. An administrative expulsion could likewise be ordered in cases of repeated and severe violation of Kyrgyz law but it does not invoke a criminal liability and is used as an administrative penalty. A decision is made by the courts and executed by either internal affairs or national security agencies (Article 19). Statistics on the number of violations of residence rules drawn from the survey in the South indicate an infrequent number of administrative expulsions. During 2008, for instance 7 cases of administrative expulsion out of 218 violations of residence rules by aliens were reported by internal affairs bodies in Osh province. However, as recognized by the NGO groups who prepared the Southern survey, the law does not take into account the specific rights which must be regarded in cases of administrative expulsion of stateless persons such as, the principle of family unity. 5. BASIC NEEDS AND ESSENTIAL SERVICES 5.1 Food security and nutrition and water and sanitation The legislation of the Kyrgyz Republic does not contain any provisions that specifically focus on access of stateless persons to food, water and sanitation. During the Focus Groups in the North and South of the country stateless individuals did not report any restrictions in availability to food, water and sanitation; accessibility therefore seems to be on par with the national population. 5.2 Housing Although the right to housing is not stipulated among the rights stateless persons specifically enjoy under the 1993 Aliens Law, the rate of access to housing is quite high. Thus, the survey in the South showed that some 77 percent of individuals surveyed have accommodation in either their own property or that of family members, while the remainder rent. The survey indicated the difficulties faced by stateless persons in the South in owning property due to lack of status. 80 percent of home-owners among the population concerned in the North responded that they did not face difficulties in enjoying their right to property however only 40 percent of them actually owned property. Small Changes ‫ ـ‬Big Gains: An Action Plan to Prevent and Reduce Statelessness in the Kyrgyz Republic 78