disproportionately affected by laws and policies on and practices of withdrawal of nationality.125 Such a discriminatory effect on a particular group may be present even when legislation in the State contains strong safeguards against statelessness. Articles 5–8 of the 1961 Convention distinguish between mono- and dualnationals such that different standards apply depending on whether a person is in possession of or can acquire another nationality. This is relevant to determining whether loss or deprivation of the nationality of a Contracting State would result in a person becoming stateless. There is also a variance in standards applicable to nationals by birth and nationals by naturalization. Any inequality of treatment between nationals by birth and naturalized citizens should, as a matter of good practice, be minimized through ensuring that there is a defined and limited period during which naturalized citizens may be subjected to loss or deprivation of nationality on an unequal basis with nationals by birth.126 For example, a naturalized citizen should not be subject to a different set of rules on withdrawal of nationality to a national who acquired nationality by birth after a limited and defined period (e.g., one year) from the date of their acquisition of nationality by naturalization. In addition, given that many naturalized citizens are likely to be from ethnic minority groups, Contracting States should exercise caution with respect to laws and practices which make naturalized citizens more vulnerable to withdrawal of nationality than citizens by birth. Withdrawal of nationality resulting in the removal of the individual concerned to another State may contravene the principle of non-refoulement. The principle of nonrefoulement is most prominently expressed in Article 33 of the 1951 Convention, and it has been recognized as a norm of customary international law.127 The principle of non-refoulement prohibits States from expelling or returning a refugee in any manner whatsoever to a territory where she or he would be at risk of threats to life or freedom. Non-refoulement obligations are also enshrined in international and regional human rights law instruments.128 Article 3 of the Convention against Torture and Other Cruel, 125 See e.g., Hoti v Croatia, European Court of Human Rights, App. no. 63311/14, 26 April 2018, para. 106; Case of Expelled Dominicans and Haitians v Dominican Republic, 28 August 2014, Inter-American Court of Human Rights, Series C No. 282, paras. 263-264. See also International Convention on the Elimination of All Forms of Racial Discrimination, 660 UNTS 195, Article 5(d)(iii): “In compliance with [their] fundamental obligations laid down in … [the] Convention, States Parties undertake to prohibit and to eliminate racial discrimination in all its forms and to guarantee the right of everyone, without distinction as to race, colour, or national or ethnic origin, to equality before the law, notably in the enjoyment of the … right to nationality”. 126 See e.g., Human Rights Council, Human rights and arbitrary deprivation of nationality: Report of the Secretary-General, 19 December 2013, A/HRC/25/28, para. 6. 127 Declaration of States Parties to the 1951 Convention and/or its 1967 Protocol relating to the Status of Refugees, 16 January 2002, HCR/MMSP/2001/09, www.unhcr.org/refworld/docid/3d60f5557.html, para.4. 128 UNHCR, Advisory Opinion on the Extraterritorial Application of Non-Refoulement Obligations under the 1951 Convention relating to the Status of Refugees and its 1967 Protocol, 26 January 2007, www.refworld.org/docid/45f17a1a4.html: In this Advisory Opinion, reference is made to various human rights law instruments, including the International Covenant on Civil and Political Rights, 999 UNTS 171, Articles 6 and 7, Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, 1465 UNTS 85, Article 3, American Convention on Human Rights (adopted at the Inter-American Specialized Conference on Human Rights, 22 November 1969), Article 22(8), African Charter on Human and People’s Rights (adopted 27 June 1981, entered into force 21 October 1986) (1982) 21 ILM 58, Article 5, European Convention on Human Rights, Articles 2 and 3 and the Charter of Fundamental Rights of the European Union, 2000/C 364/01, Article 19(2). UNHCR > GUIDELINES ON STATELESSNESS NO.5 34