In addition, Article 9(2) Qualification Directive lists as acts of persecution: (a) acts of physical or mental violence …; (b) legal, administrative, police, and/or judicial measures which are in themselves discriminatory or which are implemented in a discriminatory manner; (c) prosecution or punishment which is disproportionate or discriminatory; (d) denial of judicial redress resulting in a disproportionate or discriminatory punishment; … It follows that persons specifically targeted by laws or practices of denationalization could be found to fear discriminatory treatment amounting to persecution with or without other violations of human rights in light of the formulation of the Article. ‘Arbitrary deprivation of nationality’ is not currently listed as an act of persecution in Article 9(2) of the EU Qualification Directive; a desirable option would be to have such acts explicitly included in the definition as a matter of policy.184 In sum, the CJEU has not yet dealt with a claim for refugee status based on arbitrary deprivation of nationality. Should this ever happen, there would be room for recognizing arbitrary deprivation of nationality to constitute persecution for a Convention reason, based on the wording of Article 9 of the EU Qualification Directive and the recent guidance given on the interpretation of the Article by the Court. 4 ARBITRARY DEPRIVATION OF NATIONALITY IN THE JURISPRUDENCE OF DOMESTIC COURTS By far the most developed case law on statelessness and refugee status, of the examined jurisprudence, exists in the UK. Landmark cases can also be found in the United States, Canada, Australia, and New Zealand. Further isolated cases were found in Ireland, Germany, Spain, and Belgium. An in-depth analysis of courts’ decisions in claims to refugee status based on arbitrary deprivation of nationality reveals that judicial bodies around the world are wrestling mainly with two legal issues. The first issue concerns the right to return and the inability to secure entry or admission in the country of former habitual residence. Under this scenario, a stateless person is unable to return to his or her country of habitual residence (due to lack of nationality, or proper ID or travel documents) and as a result is refused entry into his or her country of habitual residence. Courts’ jurisprudence around the world is consistent in denying protection if the obstacles are purely practical; statelessness per se is not a ground for refugee status under the 1951 Refugee Convention (technically, the 1954 Stateless Status Convention should provide the appropriate legal framework for protection). However, in some cases, the refusal of entry on ground (of lack of) nationality has been found to amount to persecution based on the violation of the right to leave and re-enter one’s country, linked closely to the arbitrary deprivation of nationality. The principle of non-refoulement further requires the removing 184 I thank Hugo Storey for this point. 33