The Lithuanian Constitutional Court elaborated on the reasoning behind the law in a ruling on 13 April 1994: Persons described under Article 1.1 and 1.2 became citizens of the Republic of Lithuania ex officio (by right) (…) Their choice over their citizenship in essence consisted of their right to renounce Lithuanian citizenship. In this respect, the situation of the other groups was very different. (…) Persons mentioned in Article 1.3 were different (…) because they had not previously had strong and continuous legal ties with Lithuania. For all intents and purposes, they were migrants who had arrived from other places beyond the boundaries of Lithuania. They usually were citizens of the Soviet Union. Upon the restoration of an independent State of Lithuania, they became aliens here. In other countries, citizenship for such persons is conferred only through the process of naturalization. In Lithuania, they could acquire citizenship in a much simplified manner. (…) This could be interpreted as acquisition of citizenship by option because, upon the restoration of the State and the end of occupation, a part of the residents who previously did not possess tight legal bonds with the previous state of Lithuania were given the option to choose their citizenship.35 On 11 March 1990, Lithuania declared independence. The aforementioned law was renamed, but its provisions continued to regulate the institution of citizenship until 5 December 1991, when the Law on Citizenship of the Republic of Lithuania was adopted. Pursuant to the new law the following persons were considered citizens; (1) persons who were citizens of the Republic of Lithuania until 15 June 1940 and their children and grandchildren, if they have not acquired citizenship of another State; (2) persons who had lived in the current territory of Lithuania from 9 January 1919 to 15 June 1940 and their children and grandchildren, if at the time of the entry into force of the law they were permanent residents in Lithuania and were not citizens of another State; (3) persons who had acquired citizenship through “zero option” before 4 November 1991; (4) persons who restored or exercised their right to acquire Lithuanian citizenship or (5) acquired Lithuanian citizenship under the new law. The formulation of the new law intended to firmly establish the principle of continuity between the Lithuanian State prior to and after the occupation.36 It also placed a greater emphasis on the principle of jus sanguinis, as those born in Lithuania but with no links to pre-occupation Lithuania were no longer considered citizens ex lege. According to the Government of Lithuania, almost all persons belonging to national minorities (“nearly 99 per cent”), chose to opt for Lithuanian citizenship within the “zero option” scheme.37 Under the Treaty on the Foundations of Inter-State Relations between the Republic of Lithuania and the Russian Soviet Federal Socialist Republic (RSFSR) of 29 July 1991, persons who had moved to Lithuania between 3 November 1989 and 29 July 1991 could also opt for Lithuanian citizenship until 1 July 1993. The 1991 Law on Citizenship provided for certain conditions which had to be met before a person could be naturalized.38 Even if the applicant met the required conditions, the granting of citizenship was a discretionary process “taking into consideration the interests of the Republic of Lithuania.”39 The conditions 35 Lithuanian Constitutional Court, 13 April 1994, Ruling “On the compliance of the Resolution of the Seimas of the Republic of Lithuania “On Amending Item 5 of the Resolution of the Supreme Council of the Republic of Lithuania ‘On the Procedure for Implementing the Republic of Lithuania’s Law on Citizenship’” of 22 December 1993 with the Constitution of the Republic of Lithuania.” Available at: http://www.lrkt.lt/en/court-acts/search/170/ta975/content 36 Sinkevičius, V., Lietuvos Respublikos pilietybė 1918-2001 metais / Citizenship of the Republic of Lithuania 1918-2001. Vilnius: Teisinės informacijos centras, 2002, p. 134. 37 UNGA, Human Rights Council, Working Group on the Universal Periodic Review Twelfth session, Geneva, 3–14 October 2011, National report submitted in accordance with paragraph 15(a) of the annex to Human Rights Council resolution 5/1-Lithuania, A/HRC/ WG.6/12/LTU/1, 19 July 2011, paragraph 26, available at: http://www.ohchr.org/EN/HRBodies/UPR/Pages/LTSession12.aspx. 38 Conditions will be discussed in more detail in section 4.3.5.2 on naturalization below. 39 Article 12 of the 1991 Law on Citizenship. U N H C R S TO C K H O L M , M AY 2 0 1 6 17