Shifting Borders of Belonging 33 Minority Status States have also used the tool of citizenship deprivation against political opponents, human rights defenders, protestors, and minority groups (as defined by their religion, ethnicity, race, or culture). For example, Rohingya have been stripped of their citizenship and denied any entitlement to citizenship in Myanmar since 1982. Many Rohingya are stateless as a result of a deliberate change in citizenship law that turned them into illegal immigrants within their own country. The loss and denial of citizenship is not a benign act. At a minimum it means Rohingya cannot open a bank or a cell phone account, register births, marriages or deaths, and, more seriously, it has also meant difficulties in accessing health care, education, employment, and freedom of movement. More concerning is that citizenship deprivation has cast the Rohingya as outsiders and justified their oppression and institutionalized exclusion, leading to genocide. The state has thus harnessed the legal fact of statelessness to engage in violence, displacement, and killing of its Rohingya population. Indeed, on January 23, 2020, in response to legal action taken by Gambia, which had accused Myanmar of genocide, the International Court of Justice took a significant step by issuing a preliminary order that instructed Myanmar to take immediate measures to prevent the genocide of its stateless Rohingya Muslim minority.42 Citizenship withdrawal also takes on an ethnic dimension in the Dominican Republic, which has a long history of discriminating against individuals of Haitian descent among its citizenry. In 2013, the Dominican state systematically institutionalized this discrimination by revoking the citizenship of approximately 200,000 Dominicans of Haitian descent through Constitutional Court decision TC/0168/ 13.43 This decision permitted civil registries to audit birth registry books as far back as 1929 to find out whether a person’s ancestor had used a non-authorized document44 to secure a legal status within the Dominican state. If said ancestor was deemed to have used an unauthorized document, then that person’s Dominican descendants were stripped of citizenship. Due to international concern about the judicial decision and its retroactive effect, the Dominican government implemented a path to regularization for those citizens 42 Application of the Convention on the Prevention and Punishment of the Crime of Genocide (The Gambia v. Myanmar) (January 23, 2020), www.icj-cij.org/en/case/178/orders. 43 Sentencia TC/0168/13, Dominican Republic: Constitutional Court (September 23, 2013), www .refworld.org/cases,DR_CC,526900c14.html. 44 There has been much debate on whether the permits that granted individuals the right to work on the sugarcane plantation served as “authorized” documents or not. For more on citizenship deprivation in the Dominican Republic, see Belton, Statelessness in the Caribbean, chapter 4. For information on how similar discriminatory civil registries practices play out in the Malaysian context, see J. Liew, “Homegrown Statelessness in Malaysia: The Administratively Stateless and the Promise of the Principle of Genuine and Effective Links” (2019) 1(1) Statelessness and Citizenship Review 95–135. https://doi.org/10.1017/9781108914994 Published online by Cambridge University Press