Revenko v. Secretary of State for the Home Department.201 The case involved an applicant who was born in Moldova, then a part of the USSR. Under the new rules of citizenship he was not considered a citizen of Moldova, and following a visit to the UK, he was unable to reenter his country. His application for asylum was rejected because ‘not all stateless persons are refugees’.202 To be a refugee in accordance with Article 1A(2) of the Refugee Convention he would need to show a well-founded fear of persecution for reasons of race, religion, nationality, membership to a particular social group or political opinion if, hypothetically, he were to be returned to Moldova. The Court of Appeal held that the purposive approach is the proper approach in such cases: ‘The text of article 1A(2) should be interpreted in accordance with the ordinary meaning to be given to its terms in their context and in the light of the object and purpose of the treaty’.203 Accordingly, Article 1A(2) sets ‘a single test for refugee status’, namely, the need to show a well-founded fear of being persecuted; this test applies to everyone claiming refugee status, irrespective of whether they have a nationality or not.204 In addition, both categories of person must show that they are outside their country (of origin or residence) and that they are unable, or owing to such fear, unwilling to return to it. Pill LJ explains, ‘Though they may be related, the phenomenon of statelessness is distinct from that of persecution giving rise to a right of asylum’.205 Indeed, the 1954 and the 1961 Statelessness Conventions are immaterial to a proper construction of Article 1A(2); 206 the 1961 Convention was designed to reduce new cases of statelessness from arising, the 1954 Convention was designed to confer rights (civil, economic, social and cultural rights) on stateless persons who found themselves in the territory of a Contracting State (whether inside or outside their country of habitual residence) although, as with the 1951 Refugee Convention, some provisions are not restricted to persons in the territory. Accordingly, ‘mere statelessness or inability to return to one’s country of former habitual residence is not sufficient of itself to confer refugee status under the [Refugee] Convention’.207 However, this does not mean that issues of nationality are entirely irrelevant to an assessment of persecution under Article 1A(2). In YL (Eritrea) v Secretary of State for the Home Department, the UK Asylum and Immigration Tribunal (AIT) recalled that the burden of proof rests on the claimant and held that it is always relevant to consider the steps taken by claimants to apply for nationality of the country of formal habitual residence and Revenko v SSHD [2001] Q.B. 601. See also EB (Ethiopia) v Secretary of State for the Home Department [2007] EWCA Civ 809; MA (Ethiopia) v Secretary of State for the Home Department [2009] EWCA Civ 289; ST (Ethiopia) v SSHD [2011] UKUT 252 (IAC), discussed below. 202 Revenko, [2001] QB 603-H, referring to paras 101 and 102 of the UNHCR Handbook. 203 Pill LJ, Revenko, 621-H. 204 For Pill LJ, ‘the phrase “well-founded fear of persecution” is the key phrase in the definition of article 1A(2)’, Pill LJ, Revenko, 622-H. 205 Revenko, 610-A. 206 Revenko, 604-G. 207 Revenko, 601-E. The UK is nonetheless required to secure admission and entry into the suggested country prior to removal (see Amie and Others v Bulgaria, judgment of the European Court of Human Rights discussed above in section 3.3) 201 37