Racial Discrimination has stated that “deprivation of citizenship on the basis of race, colour, descent, or national or ethnic origin is a breach of States Parties’ obligations to ensure nondiscriminatory enjoyment of the right to nationality. 72 Similarly, in a resolution on the right to nationality for women and children, the Human Rights Council acknowledged that “the right to nationality is a universal right and that no one may arbitrarily be denied or deprived of nationality, including on discriminatory grounds, such as race, sex, language, religion, political or other opinion, national or social origin, property, birth, disability or other status and urged States to “reform nationality laws that discriminate against women .73 In his report on the prohibition of arbitrary deprivation of nationality of the child, the Secretary General states that “where a child is precluded from obtaining a nationality on discriminatory grounds, this amounts to arbitrary deprivation of nationality .74 46. The 2009 Secretary-General’s report on arbitrary deprivation of nationality recalls that “the principle of non-discrimination is a common feature applicable to the context of international human rights instruments , including in respect to “issues related to nationality .75 Any deprivation of nationality on discriminatory grounds is considered arbitrary for the purposes of international law. This is affirmed across different international conventions, soft law instruments, jurisprudence, and enjoys broad consensus in doctrinal writings. The 2016 resolution of the UN Human Rights Council on this issue provides the following non-exhaustive list of discriminatory grounds in relation to understanding when the deprivation of nationality is arbitrary: “race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth, or other status, including disability .76 47. Article 9 of the 1961 Convention prohibits the deprivation of nationality on racial, ethnic, religious or political grounds, irrespective of whether the deprivation would lead to statelessness or not. In other words, the Article 9 prohibition is not subject to the limitations and exceptions set out in Articles 5 8 of the Convention (see also the commentary to Principle 5 above77). It clearly establishes the principle of non-discrimination as a stand-alone and absolute bar against nationality deprivation in any context. 48. The 1961 Convention explicitly refers to race, ethnicity, religion, and political opinion as prohibited grounds. However, through a purposive reading of the Convention, in line with developments in human rights law, other protected characteristics may also be imputed. As there is no reasonable justification to privilege these four grounds over others such as gender, disability, and sexual orientation (to name a few) a human rights based interpretation and application of the Convention will lead to the conclusion that any form of discriminatory deprivation of nationality is to be prohibited. The UNHRC Guidelines No. 5 establish that the list of discriminatory grounds is continuously non-exhaustive and that “Article of the 72 General Recommendation 30, Discrimination against Non-citizens (2004), para 14. Human Rights Council, Resolution 20/4 (2012), A/HRC/RES/20/4. 74 Human Rights Council, ‘Impact of the arbitrary deprivation of nationality on the enjoyment of the rights of children concerned, and the existing laws and practices on accessibility for children to acquire nationality, inter alia, of the country in which they are born, if they would otherwise be stateless: Report of the Secretary-General’, A/HRC/31/29 (2015), para 8. 75 UN Human Rights Council, ‘Human rights and arbitrary deprivation of nationality: Report of the Secretary-General’, A HRC , available at: http://www.refworld.org/docid/4b83a9cb2.html, paras. 18 and 26. 76 UN Human Rights Council, A/HRC/RES/32/5 (2016), paras. 2 and 4. 77 As set out in the commentary on Principle 5 on the avoidance of statelessness, many of these limitations have anyway been surpassed. 73 37