applicants cannot apply for internal passports, and without internal passports, applicants cannot obtain the duplicate of their birth registration to apply for internal passports. The fact that registry offices refuse to issue personal documents such as duplicate birth certificates in cases where an applicant cannot present an internal passport impedes access to personal documents and leaves even Roma whose births have been registered without such documents. It is clear that the authorities in such cases are implementing the rules and regulations strictly and that such implementation is without the necessary margin of appreciation for the circumstances of the applicants. A consequence of lack of personal documents among Roma women In a number of cases, particularly in the Transcarpathia region,69 the practice of Roma women delivering children and using someone else’s identification was observed. This happens predominantly in cases when children are born to mothers who are still minors (13–17 years old). In these cases, Roma women are afraid of the consequences of their age being discovered by the authorities and decide not to use their own personal documents at the hospital if they have them. Certainly this practice brings about a whole new set of problems, from the issue of the right to legal custody of a child to what are often very complicated, costly court procedures for the determination of motherhood. Also, information has been received that Roma women with no personal documents use someone else’s passport (and consequently someone else’s identity) because they have been told that the hospital cannot release a newborn into the custody of a mother who is unable to prove her identity. The procedure to establish identity, conducted in cases where applicants cannot prove their identity by means of documents when applying to the SMS for an internal passport, illustrates these very complex administrative procedures. In accordance with the RoP,70 when the applicant cannot be identified on the basis of information in the registry, the identification procedure is to be carried out before the SMS. In these cases, the identification is performed on the basis of data available from the state and its unified registries, from other information sources at the disposal of the State, or from companies, institutions or organizations. In such cases, the SMS submits inquiries to all the relevant public authorities and checks and compares all the relevant information available about the applicant’s identity. In these cases, applicants are also obliged to provide information from three witnesses who are able to vouch for their identity. In the cases presented to the authors during the course of this study, one such act identifying a person involved authentication by means of 30 different documents,71 while in another case the number was 26 documents.72 The procedure could last up to two months. 69 According to information from the Odesa and the Kharkiv regions, this situation is very rare in Roma communities there. 70 Op. cit., note 38. 71 As presented during the meeting with the competent authorities in Kharkiv region, 30 March 2017. 72 As presented during the meeting with the competent authorities in Odesa region, 28 March 2017. 30