Statelessness in Southern Africa Lesotho citizens to hold dual nationality with at least South Africa, given what the court characterised as “the economic interdependence of the two countries.”127 A handful of countries provide in their laws for dual citizenship to be allowed only for citizens from birth: they include Namibia and Swaziland.128 In Zambia, in 2008, a National Constitutional Conference resolved to approve this idea; though a new Constitution has yet to be adopted.129 Several High Court rulings in Namibia have affirmed that under the Constitution a citizen from birth can only lose his or her nationality by voluntary renunciation and that dual nationality is permitted for citizens from birth, despite section 26 of the Citizenship Act, which states that no Namibian citizen may also be a citizen of a foreign country.130 Some governments, however, have moved in the opposite direction. This is most evident in Zimbabwe, where, in recent years, persons with a potential claim on another citizenship have been required to renounce it, even if they have never had any legal relationship with the second state.131 A constitutional amendment adopted in early 2009 as part of the process of installing a government of national unity opened up the possibility of dual citizenship, by stating that parliament “may” provide for the prohibition of dual citizenship; the issue remains under discussion. Meanwhile, the rules on presumed dual nationality are still being applied, despite court orders to the contrary.132 127 Director of Immigration and others vs. Pholoana Adam Lekhoaba and Anor. C of A (CIV) No.22/07 (unreported), available on the website of the Southern African Legal Information Institute (SAFLII) at http://www.saflii.org/ls/cases/LSCA/2008/4.html. 128 As well as Comoros, Gambia, São Tomé and Príncipe, and Uganda. 129 Constitution of Zambia Bill 2007. See also debates on the Zambian Economist blog for June 2008, available at http://zambian-economist.blogspot.com. 130 Tlhoro v Minister of Home Affairs (Case No. (P) A159/2000) [2008] NAHC 65 (2 July 2008), reaffirmed by Le Roux v Chief of Immigration and Others (A 322/2010, High Court of Namibia). See also Werner Menges, “Court confirms legality of dual citizenship for some Namibians,” The Namibian, 9 July 2008; Werner Menges, “Dual citizenship legal for born Namibians”, The Namibian, 7 June 2011. 131 See Bronwen Manby, Struggles for Citizenship in Africa, Zed Books, 2009, pp.39-50. 132 See Alex Bell, “Registrar General faces court action after refusing Zim man passport”, SWRadio, 26 October 2011; “Lawyers dump Mudede again: Registrar-General Tobaiwa Mudede has changed lawyers for the third time in five months in a matter in which he faces jail for allegedly defying a High Court order”, ZLHR Legal Monitor, 2 November 2011. 30