Convention is complemented by developments in international human rights law .78 Indeed, as set out in the Tunis Conclusions, Article 9 of the 1961 Convention “was designed to give effect to Article 15 of the UDHR and is complemented by provisions of conventions such as the CERD, CEDAW and CRPD”. 79 It is instructive that the outcome of this UNHCR facilitated expert meeting was to connect Article 9, not only with CERD (racial discrimination), but also with CEDAW (gender) and the CRPD (disability) which protect against discrimination on the basis of characteristics not explicitly mentioned in Article 9. 49. The prohibition on racial discrimination is a peremptory norm of international law80 and is an obligation erga omnes.81 Therefore, states cannot derogate from these obligations including during times of emergency without violating international law.82 50. It is important to contextualise this customary law prohibition of racial discrimination within the historical use of deprivation of nationality by states. As articulated by the UN Special Rapporteur on contemporary forms of racism, racial discrimination, xenophobia and related intolerance: “historically, citizenship stripping has been a favoured political tool of ethnonationalist governments wishing to isolate, marginalize or exclude certain racial, ethnic, religious, and national groups.”83 51. UN treaty bodies have frequently held that the rights enshrined in treaties are guaranteed to those belonging to national, religious, racial, and ethnic minorities, without discrimination.84 Commenting on the centrality of the principle of non-discrimination and the obligations of States in this regard, the UN Human Rights Council has affirmed that: 78 UNHCR Guidelines No. 5 (2020), para, 79. UNHCR, ’Tunis Conclusions‘ , paras. -71. 80 Human Rights Committee General Comment No. 29, CCPR/C/21/Rev.1/Add.11, paras. 8, 13(c). See also, UN General Assembly, ‘Fourth report on peremptory norms of general international law (jus cogens by Dire Tladi, Special Rapporteur’, A CN. January , available at https://undocs.org/en/A/CN.4/727. 81 Barcelona Traction, Light & Power Co. (Belg. v. Spain), 1970 I.C.J. 3 (5 February), p. 32, para. 34. 82 Human Rights Committee General Comment No. 29, CCPR/C/21/Rev.1/Add.1, paras. 8-9, 13, 1516. It has also been held that the prohibition of any form of discriminatory treatment, such as based on gender, nationality or birth status, is a peremptory norm, see IACtHR, Advisory Opinion OC-18/03 of 17 September 2003, Juridical Condition and Rights of Undocumented Migrants, para. 101. 83 UN Special Rapporteur on contemporary forms of racism, racial discrimination, xenophobia and related intolerance, ’Amicus Brief before the Dutch Immigration and Naturalisation Service’ October , para . The Special Rapporteur cites numerous sources in support of this claim: A/HRC/ 7/23, paras. 20-27 (in which the then-UN Independent Expert on Minority Issues explains the discriminatory history of citizenship-stripping and denial of citizenship); Lawrence Preuss, International Law and Deprivation of Nationality, 23 GEO. LJ. 250, 274-75 (1934) (concluding that "[l]egislation imposing the loss of nationality as a penalty is primarily dictated by political motives, and is designed to rid the state of citizens whose conduct is deemed inconsistent with their obligations of loyalty to the state, or, more accurately, to the government in power."). For specific examples, see A/HRC /RES/34/22, para. 5 (calling for Myanmar to review its 1982 Citizenship Law because the law results in human rights deprivations and contributes to "systematic and institutionalized discrimination against members of ethnic and religious minorities"); E/CN.4/RES/ 1987/ 14 - (denouncing-Apartheid South Africa's practices of denationalizing and forcibly removing Black South Africans, and noting that Apartheid denied Black South Africans full citizenship rights);A/HRC/WG.6/ 12/SYR/3, para. 60-64 (discussing the effects of Syria's denial of citizenship to its Kurdish minority); CERD/C/SDN/CO/ 12-16 (noting that Sudan's citizenship revocation policies discriminated against South Sudanese populations); CCPR/C/NLD/QPR/5, paras. 10-11 (noting that the Netherlands counterterrorism measures, which include revocation of citizenship for certain offenses, may perpetuate discrimination against minority populations). 84 For example, see Human Rights Committee General Comment No. 18; Committee on the Elimination of Racial Discrimination General Recommendations Nos. 22, 23, 25, 27, 29, 30 & 34; Committee on Economic, Social and Cultural Rights General Comment No. 20. 79 38