International Journal of Refugee Law, 2026, Vol. 00, Issue 00 • 15 4. Contextualizing bilateral responses to statelessness Although the UAE’s agreement with the Comoros was extraordinary, it did not occur in a vacuum. This bilateral response to statelessness adopted by the UAE and contemplated by Kuwait bears similarities to the broader phenomenon of the adoption of bilateral agreements as a response to asylum seeking and irregular migration. The turn to bilateral Lori (n 8) 196. Economic Citizenship Law, art 6. 117 Fred Mukinda, ‘Meet “Stateless” Man Who Has Been Stranded at JKIA for Four Months’ Nairobi News (6 April 2018) <https://nairobinews.nation.africa/stateless-man-stranded-jkia/> accessed 23 May 2024. 118 Lori (n 8) 196. 119 Kuzmova (n 8) 282. 120 Lori (n 8) 203. 121 ibid 231. 122 Abrahamian (n 33) 248; Rabuffetti and Wills (n 8) 84. 123 Lori (n 8) 230. 115 116 Downloaded from academic.oup.com/ijrl/advance-article/doi/10.1093/ijrl/eeag028/8767365 by guest on 08 October 2026 satisfy the quality or substance of nationality. The substantive elements of nationality operate at two levels. At the international or external level, nationals are entitled to diplomatic protection (intervention by the state in international legal proceedings on behalf of the affected national) and consular protection (assistance rendered to nationals by the state while abroad). Nationals are entitled to the right of entry or admission into the country of their nationality, as well as the right to reside in that country. At the domestic or internal level, nationals typically have the right to vote and to stand for public office. Nationals commonly also have obligations to their country of nationality, including to pay taxes, to perform military service, and to be bound by the state’s laws. The grant of Comorian passports to the UAE’s bidun did not offer any of these elements of nationality. Passport recipients are not entitled to diplomatic or consular protection from the Comoros.115 The passports expressly prohibit the bidun from residing on the island nation.116 This was dramatically illustrated in 2018, when a Comorian passport holder from the UAE was arrested and deported to the Comoros but was refused the right to enter the country, and then refused the right to re-enter the UAE, leaving him stranded for four months in Kenya’s international airport.117 At the domestic level, the passport holders do not have the right to vote in Comorian elections or to serve in public office,118 and are not required to serve in the Comorian armed forces (although the UAE subsequently required Comorian passport-holders to participate in its mandatory national military service).119 The Comorian passports do not even reliably facilitate travel to other countries; suspicion about the veracity of the documents has meant that passport-holders are frequently stopped at borders when attempting to travel120 and, without consular support from the Comoros, there is no way for passport-holders’ claims about the validity of the passports to be verified.121 The documents do not even reliably function as passports, much less amount to a grant of nationality to the bidun. Although the arrangement promised that passport recipients would subsequently be naturalized in the UAE, it is not known how many bidun were ultimately granted UAE nationality.122 It is likely that most remain on temporary residency visas, dependent upon their sponsor under the Kafala Sponsorship system to maintain their status as foreign workers in their own country.123