2020 Statelessness & Citizenship Review 2(1) Court considered that the Tanzanian government had not sufficiently established its case that the applicant was not a citizen. Despite this failure to assess the proceedings in Tanzania against the African Charter, the principle of a reversed burden of proof underlined by the African Court is of critical importance in the context of Tanzania, as well as other African states, where very few hold identity documents. Birth registration in Tanzania has improved in recent years, but still stands at only a quarter of children under five years old. It is much lower for older generations. 55 A national identity card has only recently been introduced, 56 and only a small minority of Tanzanians have been issued a passport for international travel. 57 In this context it can be virtually impossible for an ordinary resident to prove citizenship if the state chooses to question it and the burden of proof rests on the applicant. The African Court’s judgments in both Penessis and Anudo establish the important principle that the key issue is the question of entitlement to citizenship rather than the possession of the correct supporting documents. 55 56 57 Tanzania: Demographic and Health Survey and Malaria Indicator Survey (Final Report, December 2016) 21, 26 <https://www.dhsprogram.com/pubs/pdf/FR321/FR321.pdf>. The National Identification Authority was established in 2008, under the Registration and Identification of Persons Act No 11 1986 (Tanzania) amended 2014, and conducted a mass registration exercise from 2013–15: World Bank, ‘The State of Identification Systems in Africa: Country Briefs’ (Working Paper No 119065, January 2017) 53. Halili Letea, ‘Clock Ticks for 950,000 Holders of Old Generation Passports in Tanzania’, The Citizen (Online, 29 July 2019) <https://www.thecitizen.co.tz/news/1840340-521496298txon/index.html>. 178