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International Case Law on Citizenship via
Naturalization
15. Security concerns as a reason for disallowing dual citizenship in
Namibia
Poppy Elizabeth Tlhoro v Minister of Home Affairs
Case No (P) A 159/2000
High Court of Namibia
Maritz & Mainga, JJ
July 2, 2008
Sometimes countries may adhere to security concerns before granting applications for dual
citizenships.
Summary of facts
The applicant was a citizen of South Africa who, in addition, wanted to obtain the
citizenship of Namibia by naturalisation. She was a South African Citizen at birth when
she entered the then South West Africa on February 2, 1981 and remained a resident there.
South West Africa was territory which became Namibia on the date of independence.
The applicant’s status in the territory changed to that of an alien when section 29 of the
Namibian Citizenship Act, No 14 of 1990, substituted the words “South African citizen”
for the expression “Namibian citizen” shortly after independence. The applicant was
excused under section 12(1)(a) of the Aliens Act from the statutory requirements relating
to temporary or permanent residence permits.
The applicant became concerned that she could be denied entry to Namibia in future after
an incident where an immigration officer hesitated to allow her entry to Namibia without a
temporary or permanent permit. She also had concerns that without official documentation
recognizing her right to residence in Namibia, she was at risk of being arrested as a suspected
prohibited immigrant. Her concerns could be addressed by applying for a permanent
residence permit but she chose to apply for Namibian citizenship by naturalisation. Her
application for Namibian citizenship was approved subject to requirements that she should
renounce her South African citizenship and take an oath of allegiance to the Republic of
Namibia before a certificate of naturalisation could be issued to her.
The applicant was unwilling to formally give up her South African citizenship as she intended
to return to South Africa and live there in future. In the meantime, she intended to work
and reside in Namibia. She filed an application seeking various declarations including those
that were to the effect that section 5(1)(g) and 26 of the Namibian citizenship Act were
CITIZENSHIP AND NATIONALITY RIGHTS CASE DIGEST
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