Report on Citizenship Law: Kenya iv). By registration or naturalisation on an on-going basis: a) A woman who married a Kenyan citizen after independence was entitled to register as a citizen27. Quite distinct from the earlier provision regarding married women who could apply for registration, this provision was more open, without any set qualifying time frames or dates. It was a catch-all provision for all foreign women married to Kenyan citizens, and no further conditions beyond the marriage itself were imposed. b) In contradistinction to citizenship by registration, persons who qualified for naturalisation had to fulfil all the following conditions: • Must have attained 21 years of age; • Must have been ordinarily resident in Kenya for 12 months immediately preceding the naturalisation; • Must have been ordinarily and lawfully resident in Kenya for an aggregate of four years within the seven year period preceding the said 12 months; must be of good character, have an adequate knowledge of Swahili, and had intentions of continued residence in Kenya. These points had to be proved to the minister’s satisfaction. A person whose application was successful would obtain a certificate of Naturalisation from the Minister28. Thus citizenship by naturalisation was meant to provide an opportunity for those who had neither birth, descent or citizenship links to Kenya and the UK and Colonies to become Kenyans. iv. Commonwealth citizenship: An assumed status rather than a mode of acquiring citizenship, commonwealth citizenship was accorded to all citizens of Kenya under the Independence Constitution and subsequent laws, and it was also a status recognised for citizens of the UK and Colonies, Canada, Australia, New Zealand, India, Pakistan, Ceylon, Ghana, Malaysia, Nigeria, Cyprus, Sierra Leone, Tanganyika, Trinidad and Tobago, Uganda, Zanzibar, Rhodesia and Nyasaland29. Commonwealth citizens could enjoy the same rights and privileges on reciprocal terms as Kenyans were allowed to enjoy in those countries. Usually, asides from immigration expedience, a Commonwealth citizen did not really enjoy the entire gamut of rights available to a Kenyan citizen. Reciprocity was the key30. 3.1.2. Prohibition of dual citizenship A significant provision of the Kenyan Independence Constitution was the prohibition of dual citizenship. In spite of the inclusive citizenship provisions, one was required to either renounce their other citizenship or cease being a Kenyan citizen if they were 21 years and above; and those registering or naturalising as citizens had to renounce any other citizenship to qualify. Only those who had not yet attained 21 years of age could hold dual citizenship, but had to decide on which citizenship to retain once they attained that majority age. Under the Constitution, persons who had attained 21 years before and after 12 December 1963 were given a two-year grace period to renounce their other citizenship, take an oath of allegiance 27 Ibid, section 5. Ibid, section 7. 29 Ibid, section 9. 30 Ibid, section 10. 28 6 RSCAS/GLOBALCIT-CR 2020/7- © 2020 Author(s)