86 Brad K. Blitz The Home Office also issued specific guidance in the case of BOCs who were formerly citizens of Malaysia, like Teh, noting that the UK government was working with the Malaysian authorities to devise a scheme whereby they can be returned to Malaysia and reestablish Malaysian nationality from within Malaysia.72 One positive outcome from the discussions between the UK government and Malaysia was the decision to suspend removals,73 even though it did nothing to advance Teh’s request for nationality, which in turn would ground his right to remain in the United Kingdom permanently. After further refusals by the Home Office to recognize his status, Teh then sought to press the High Court for a judicial review of the Home Office’s decision, and his petition was refused in 2017 in part because the UK government contested Teh’s status as a stateless person because he holds British Overseas citizenship and is admissible to Malaysia.74 As of September 2020, Teh is no longer considered a national by Malaysia, nor of the United Kingdom, and remains in limbo. Teh’s case bears many similarities to the plight of the Oxford-based Kashmiri families, where neither India nor Pakistan was prepared to address their claims. In their case, we see how historical antagonism between neighboring states can undermine the prospect of collaboration in determining “ineffective nationality,” as Massey proposes. These examples are far from exceptional. Across the globe, there are many ways in which states may obstruct individuals from securing recognition of their claims or affirming their status. Even more glaring is how some states have conspired to keep people in precarious situations. Thus, minorities in Assam are currently facing the threat of exclusion from the all-India National Register of Citizens. Although the government claims to be updating the register to prevent immigrants from Bangladesh settling in India, millions of long-term-settled residents have been caught up in this exercise in retrospective immigration control. When a draft register was released in 2018, an estimated 4.1 million people were left off the list. Although this number has come down to approximately two million, many remain at risk of statelessness since local authorities refuse to accept official documents such as school leaving certificates (known as migration certificates) as evidence of status.75 These case studies also challenge other methodological assumptions that underlie UNHCR’s results framework, above all the belief that some of its indicators accurately reflect the outcomes they seek to measure. As Teh’s case shows, the United Kingdom’s accession to both UN statelessness conventions and its introduction of statelessness determination procedures does not mean that the United Kingdom has 72 Ibid. Ibid. 74 Teh v. Secretary of State for the Home Department, [2018] EWHC 1586 (Admin) (June 22, 2018). 75 For a comprehensive list of those categories of people who qualify to be registered, see “What Is NRC? Here Is What You Need to Know,” India Today (June 20, 2019), www.indiatoday.in/ information/story/what-is-nrc-here-is-what-you-need-to-know-1552817-2019-06-20. 73 https://doi.org/10.1017/9781108914994 Published online by Cambridge University Press