Canadian citizen parents to be granted citizenship if the child meets certain criteria. The provision states that the Minister shall grant citizenship to a person who: • Is born outside Canada; • Has a birth parent who was a citizen at the time of the birth; • Is less than 23 years of age; • Has resided in Canada for at least three years during the four years immediately before the date of his or her application; • Has always been stateless; and • Has not been convicted of a terrorism offence, treason, intimidating Parliament, sabotage or various offenses under the Security of Information Act.510 Grants of Citizenship: Ministerial Discretion The Citizenship Act also allows the Minister to grant citizenship at his or her discretion “to any person to alleviate cases of special and unusual hardship or to reward services of an exceptional value to Canada.”511 In such applications, statelessness can be taken into account for compassionate consideration.512 However, jurisprudence from the Federal Court of Canada has also held that statelessness is more of an inconvenience rather than a sufficient hardship to warrant a grant of citizenship.513 There is little information available on the procedure and application requirements for the Minister to grant citizenship in discretionary cases and what factors are to be considered. The limited information available from Citizenship and Immigration Canada reiterates that it is an exceptional application: Grants under this subsection are only used in very exceptional cases and each case is considered on its own merit. It is important that applicants appreciate the significance of being conferred a grant of citizenship under this provision and that it should not be used as a means of circumventing the normal citizenship process.514 Grants of Citizenship: Eligible Permanent Residents Other than the exceptions mentioned above, obtaining permanent resident status is a prerequisite to naturalization in Canada. Stateless persons may apply for citizenship after they have been Citizenship Act, supra note 22 at s. 5(5); see also Citizenship and Immigration Canada, “Citizenship grants: Statelessness” (16 July 2014), available at: http://www.cic.gc.ca/english/resources/tools/cit/grant/stateless.asp 511 Citizenship Act, ibid., at s. 5(4). In addition, s. 5(3) of the Citizenship Act also has specific “compassionate grounds” upon which the Minister may grant a waiver from having to meet certain requirements to obtaining Canadian citizenship. These exceptions include having knowledge of one of the official languages, having knowledge of Canada and the responsibilities and privileges of citizenship, having to take the oath, etc. 512 Statelessness in the Canadian Context, supra note 4 at 50, referring to the case of Daifallah (Re), [1992] F.C.J. No. 441 (FCTD). 513 Goudimenko v. Canada (Minister of Citizenship and Immigration), 2002 FCT 447, at para. 22, available at: http://canlii.ca/t/ksb. 514 Citizenship and Immigration Canada, “Citizenship: Ministerial discretion to grant citizenship in special cases” (27 March 2015), available at: http://tinyurl.com/okdwff7. 510 106