Statelessness Determination Procedures determination procedure is finally established. Like in the UK, 140 applications for administrative review of negative decisions regarding statelessness determinations could be sent to the ACNC. The problems with such a system, however, are that administrative review committees, such as the ACNC, usually only look into the procedural correctness of a decision, and, moreover, do not reverse decisions: they only make recommendations to the responsible agency. Appeals, however, usually lead to a reversal of earlier decisions if the procedures where not properly applied. 141 We would therefore recommend the system in Moldova, where SDP appeals go to regular courts. 142 In the case of Nigeria, we would specifically recommend the Federal High Court, as the court with constitutional power to entertain matters concerning citizenship and naturalisation, 143 or alternatively, the establishment of a special Administrative Court, as France has done. 144 However, the French Administrative Court’s decision has no suspensive effect, which means that, if the foreigner is the addressee of a deportation order, the administration can carry it out, even if the Administrative Court has not yet decided on the appeal. 145 Whatever approach Nigeria decides to take, administrative review or judicial appeal, as argued in Part III(H), the initiation of the relevant procedure should suspend the order of expulsion pending the outcome of the review or appeal. CONCLUSION Over the last years, the phenomenon of statelessness has attracted particular attention, perhaps in the light of the strong connection between statelessness and irregular immigration. 146 Yet neither of the two UN Statelessness Conventions places an explicit obligation on contracting states to establish a statelessness determination procedure. However, it is widely agreed that it is impossible to effectively implement many of the provisions of these conventions without having 140 See UK Immigration Rules (n 136) appendix AR [AR2.3]. 141 We would advise that an SDP system to allow self-auditing or external auditing of negative decisions. 142 See Moldova Foreigners Regime (n 110) arts 878(2), 879(3). 143 Nigerian Constitution (n 113) s 251(1)(i) provides inter alia that ‘the Federal High Court shall have and exercise jurisdiction to the exclusion of any other court in civil causes and matters’ relating to ‘citizenship, naturalisation and aliens, deportation of persons who are not citizens of Nigeria, extradition, immigration into and emigration from Nigeria, passports and visas.’ The Federal High Court is the only competent court in Nigeria to entertain issues of citizenship, naturalisation and other immigration matters in Nigeria. The court is a central court but with divisions in each of the 36 States of Nigeria. 144 ENS Statelessness Index Survey: France (Report, European Network on Statelessness March 2019) 23 <https://index.statelessness.eu/sites/statelessindex.eu/files/ENS_Statelessness_Index_Surve y-France-2018.pdf>. See also the French Public Administration website on appeals to administrative judge: ‘Apatride: titre de séjour, document de voyage’ [Stateless Persons: Residence Permit, Travel Document], Service-Public (Web Page) <https://www.servicepublic.fr/particuliers/vosdroits/F15402>. 145 For more information, see ‘Apatridie: Les voies de recours’, Office français de protection des réfugiés et apatrides [French Office for the Protection of Refugees and Stateless Persons] (Web Page) <https://www.ofpra.gouv.fr/fr/apatridie/les-voies-de-recours>. 146 Konstantina Keramitsi, ‘Addressing Statelessness in Greece under EU Law’ (PhD Thesis, University of Macedonia, 2019) 6 <http://www.lse.ac.uk/HellenicObservatory/Assets/Documents/HO-PhD-Symposia/The-9th-HO-PhDSymposium/Symposium-Papers/Session-1/Migration-I-Security.pdf>. 110

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