Childhood Statelessness i European Courts: An Avoidable Crisis 25 a District Court in The Netherlands, holding the state in violation of the 1961 Convention, considering the Convention to be universally binding law in an Article 94 sense, noting the 2023 amendments, and confirming the child litigant’s Dutch citizenship.181 In comparison, in an earlier case from 2019 which invoked the 1961 Convention yet left a child stateless, the Court of the Hague deemed itself unable to grant Dutch nationality.182 In many statelessness cases in the Netherlands prior to 2023, many courts “shied away from touching statelessness” while awaiting Parliament’s amendments on statelessness procedures.183 This example underscores the significance of domestic law and its impact on litigation – when the law is adhered to in court. In an international law context, treaties bind European states only to the extent a sovereign European state allows itself to be bound. Without domestic incorporation of the CRC and the Statelessness Conventions, stateless children and their advocates face difficulties in court when fighting for these children’s rights to be recognized, despite other legal instruments upon which one may rely (e.g., ECHR, EU Charter, ICCPR). Children might be sympathetic litigants, but perhaps only within certain jurisdictions or certain courts. Even within those jurisdictions responsive to issues of statelessness, how a child is represented, with whom, and by whom are all variables that determine the outcome of a case. 181 Case No. BRE AWB 23/2442 RWNL (2023) Netherlands District Court Zeeland-West-Brabant, para 10. 182 Case No. ECLI:NL:RBDHA:2019:7638 (n 135). 183 Scholar B (n 69).