2020 Statelessness & Citizenship Review 2(1) the agency that makes first instance decisions in order to guarantee a free, dispassionate and impartial review process. Appeals must be possible on both points of fact and law as the possibility exists that there may have been an incorrect assessment of the evidence at first instance level. Whether an appellate body can substitute its own judgment on eligibility under the 1954 Convention or whether it can merely quash the first instance decision and send the matter back for reconsideration by the determination authority is at the discretion of the state. 89 Though not provided in the Statelessness Conventions, nor in the UNHCR Statelessness Handbook, we advise against a time limit within which an applicant must file an appeal or request review of a decision. In our opinion, it is advisable to leave open the time within which to appeal a negative decision, as this prevents the door from being shut on stateless persons, or other persons at risk of statelessness who should ordinarily benefit from such guarantees. DEVELOPING AN SDP FOR NIGERIA This Part will use the standards and criteria analysed above to propose useful guidance for Nigeria to develop its SDP. Inspiration will also be drawn from countries such as Brazil, France, Moldova, Paraguay and the UK, 90 which have a more or less appropriate legal framework in place for the protection, identification, and prevention of statelessness. The discussion in this Part is largely based on the structure used in Part III. A Current Legal Framework Nigeria acceded to the 1954 Convention and the 1961 Convention on the Reduction of Statelessness (‘1961 Convention’) in 2011. 91 Despite being the first country to ratify these conventions in the Economic Community of West African States (‘ECOWAS’) region, Nigeria has not domesticated them so as to give them the force of law amongst the laws of the Federation of the Nigerian State. Accordingly, Nigeria currently does not have a legal framework for the 89 90 91 Handbook on Protection of Stateless Persons (n 11) 30 [77]. In addition to the above mentioned standards, these states have been selected because of their compliance with the criteria mentioned in the introductory part of Part IV above, such as legality and binding nature of their SDP, structure and location of SDP, access to procedure, procedural guarantees, method of assessments of facts, management of combined refugee and stateliness claims, prospect for naturalisation, review and appeal of decisions. The United Kingdom SDP system is criticised by scholars especially with regards to its limitations on access to protection, which are arguably not in line with the 1954 Convention (n 11), as well as its extremely low recognition rates as compared to other countries with a functioning SDP: see Johanna Bezzano and Judith Carter, ‘Statelessness in Practice: Implementation of the UK Statelessness Application Procedure’ (Report, University of Liverpool July 2018) 14, 20, 24, 30, 42. See also ‘The UK’s Approach to Statelessness: Need for Fair and Timely Decisions’ (Policy Briefing, Asylum Aid September 2016). Nevertheless, the UK is included in this research because of the fact that Nigerian lawmakers, lawyers and scholars easily connect with the UK system. Nigeria and the UK both have a common law system, and their governance systems share some administrative similarities which may be relevant for developing an SDP for Nigeria. It is easier to convince Nigerian lawmakers about systems that work in the UK (and in Europe generally) rather than in Asia or the Americas. This explains why mostly European States have been included in this research. UNHCR, Submission to the Office of the High Commissioner for Human Rights, Compilation Report — Universal Periodic Review: Nigeria (March 2013) 1. 101