Based on the above, there are no measures that can be taken for A to be recognized as a national by the Vietnamese authorities, and A is likely to be a person who is not considered a national under the operation of Vietnamese law. In this regard, even the abovementioned Tokyo District Court decision states that the court has “doubts” about the Immigration Bureau’s determination of A’s nationality as Vietnamese, and that if the Immigration Bureau was to consider deporting A again, the destination country for deportation needs to be carefully considered. (2) Thailand Thailand has long adopted a jus soli principle along with a jus sanguinis principle with regard to the acquisition of nationality. There have been several nationality law reforms, but in principle the country has adopted the policy of having children born of foreign parents lawfully staying in Thailand acquire Thai nationality by birth. However, such a policy was fundamentally overturned by the Thailand Revolutionary Council Proclamation No.337, issued on 13 December 1972. With the complications of the Vietnam War as the background, the then Thai government cancelled the Thai nationality which the second- and third-generation Vietnamese refugees had previously acquired based on the prevailing nationality law at the time of their birth. The Proclamation also declared the government’s decision not to grant Thai nationality to descendants of Vietnamese refugees born in Thailand from that time onwards. However, the Thai government’s policy on Vietnamese refugees has again changed through the developments in international relations during the 1980s. By means of the 1992 nationality law reform, it became possible for second- and thirdgeneration refugees born in Thailand to be granted Thai nationality at the discretion of the Minister of Internal Affairs. Moreover, in 2008, the Thai nationality law was amended in light of the heightened awareness of statelessness issues within Thailand, and the opportunities for second- and third-generation persons to acquire Thai nationality became further expanded.219 As discussed above, while the status of Vietnamese refugees in Thailand has been affected by the changes in international relations and the legal policies of the government interrelated to such changes, second- and third-generation refugees born in Thailand have become able to access Thai nationality. In fact, A’s brothers and sisters residing in Thailand managed to acquire Thai nationality. However, A was residing in Japan during this period and thus was unable to go through the procedure to acquire Thai nationality. For one to acquire Thai nationality, “residence in Thailand based on residency registration in Thailand” is a legal requirement. Thus, for A to acquire Thai nationality, A would need to return to Thailand and reside there. In fact, there has been a case where 219 On the issue of stateless people and the Nationality Act of Thailand, see Yuu Ohtomo, “Tai Kokusekihouno Ichibu Kaisei – Tai Kokusekihouno Hensento Mukokusekisha Mondai [Partial Amendment of the Nationality Act of Thailand: Changes in Thai Nationality Act and Issues of Statelessness]” Gaikokuno Ripppou [Foreign Legislation], No. 249 (2011), pp.111-118. 112

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