nationality and/or membership of a particular social group, namely bedoon’.285 Finally, the NZ RSAA has held that: if the nationality of a candidate for refugeehood is indeterminable, it would be best in keeping with the Convention, as well as the humanitarian spirit underlying the instrument, to give the applicant the benefit of the doubt. This would mean in some cases considering him a national of his country of origin … but should it, for some reason, be more favourable for a person of indeterminable national status to be considered a stateless person, he should be considered as such.286 For the NZ Authority, this latter view often applies in practice because it considers the ‘nationality’ ground of persecution in Article 1A(2) to include statelessness. Thus, ‘persecution for reasons of nationality is also understood to include persecution for lack of nationality’;287 the problem with such an approach is that it may lead to the circular notion that persecution cannot define the ground. In any case, in this Appeal No. 1/92, the NZ RSAA rejected the social and economic problems faced by the appellant, a Palestinian stateless person, as insufficiently intolerable or causing unbearable suffering to amount to a well-founded fear of being persecuted. In Australia, cases involving stateless persons indicate that the courts have recognized in principle the existence of a particular social group for the purpose of the Refugee Convention in cases of ‘non-citizen Latvians, non-citizens Latvians of Russian origin or Russian speakers’288 or even ‘persons in HKSAR or the PRC or in Indonesia who share the characteristic of having difficulty finding work because of their age’289 but denied protection if there is a lack of ‘a selective and discriminatory withholding of State protection from noncitizen Latvians of Russian origin for a Convention reason’.290 Finally, in the US, the Supreme Court held the deprivation of nationality of a US citizen to be ‘more primitive than torture, for it destroys for the individual the political existence that was centuries in the development’.291 In Haile v. Gonzalez (Haile I), the Seventh Circuit recognized, in principle, the arbitrary expulsion and denationalization by Ethiopia of thousands of ethnic Eritreans born in Ethiopia, to be ‘a particularly acute form of persecution’.292 In Haile v. Holder (Haile II), the Seventh Circuit explained that ‘[i]f Ethiopia denationalized the petitioner because of his Eritrean ethnicity, it did so because of hostility to Eritreans’ and NZ RSAA Appeal No.76506, decision of 29 July 2010, para.84. NZ RSAA, Refugee Appeal No.1/92, 30 April 1992. 287 Ibid, referring to the writings of Grahl-Madsen and Hathaway. 288 Case no. 0908370 [2010] RRTA 33, 18 January 2010, at para.44. 289 Case no. 0908992 [2010] RRTA 389, 14 May 2010, at para.144. 290 Case no. 0908370 [2010] RRTA, 18 January 2010, at para.46. 291 Trop v Dulles, 356 U.S. 86 (1958), at 102. 292 Haile v. Gonzales (Haile I), 421 F.3d 493 (7th Cir. 2005) at 496. See also, for the same point of law, Mengstu v. Holder, 560 F.3d 1055 (9th Cir. 2009) at 1056-7. 285 286 50