Statelessness & Citizenship Review 2020 2(1) entitled to a permanent residence permit, labour and social security rights, access to basic and essential services, travel document etc, as we argued in Part III(G). 136 In terms of responsible agencies, Brazil and the UK are recommended as best practices. In these countries, the same agency is responsible for both SDP and naturalisation. 137 An SDP embedded in the Directorate of Citizenship and Business of the Nigerian Ministry of Interior may thus create a pathway from determination of statelessness status to acquisition of nationality. H Proposed Review and Appeal of Decisions Section 8 of the NCFRMI Act guarantees the right to an effective remedy where an application for a grant of refugee status is rejected, by providing that the applicant may appeal against the decision of the Eligibility Committee to the Refugee Appeal Board. This is a good practice that should be retained when an SDP is developed in Nigeria. Still, we have some doubts regarding the requirement in the NCFRMI Act that the applicant should appeal within 30 days of being notified of the refusal. While such a time limit does not as such violate international law, 138 as argued in Part III(H), we advise to leave open the time within which to appeal a negative decision. As far as administrative review is concerned, it is of note that Nigeria has an Advisory Committee on Nigerian Citizenship (‘ACNC’), 139 which reviews applications and decisions of the Ministry of Interior and makes recommendations for grant or refusal of Nigerian nationality. What is not clear, however, is the extent to which the ACNC reviews the decisions of the Ministry. If the ACNC actually reviews the decisions of the Ministry, then this could be adapted when a 136 See 1954 Convention (n 13) arts 15, 17, 19, 21, 23, 24, 28; Handbook on the Protection of Stateless Persons (n 11) 49 [136]–[137], 53 [150]. For Brazil, see Brazil Migration Law (n 134) art 26. For France, see CESEDA (n 118) arts L.313-1, L.313-26, L.812-7, L380-1 and French Civil Code (n135) art 21–17. For Moldova, see Moldova Foreigners Regime (n 110) arts 4, 877(3). For Paraguay, see Paraguay Statelessness Law (n 118) arts 23–28. For UK, see Immigration Act 1971 (UK) s 3(1)(c); Housing Act 1996 (UK) pts 6, 7; Immigration Rules 1994 (UK) pt 14, rr 405, 410–16 (‘UK Immigration Rules’). Note that, in the UK, permanent residency is only granted to a person who has had leave to remain as a stateless person for at least five years. In France, the resident permit issued is not a permanent residence permit (renewable). However, stateless persons have access to naturalisation after five years of legal residence. 137 See Brazil’s National Secretariat of Justice website via ‘Migrações’, [Migrations] Justica e Segurança Publica [Justice and Public Security] (Web Page) <https://legado.justica.gov.br/seus-direitos/migracoes>; Home Office Stateless Leave (n 119); Guide AN Naturalisation Booklet — The Requirements (Policy Guide, Home Office March 2019) <https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_d ata/file/794168/Guide_AN__Naturalisation_Booklet.pdf>; and ‘Citizenship and living in the UK’, GOV.UK (Web Page) <https://www.gov.uk/browse/citizenship/citizenship>. 138 See NCFRMI Act (n 92) art 8(7) and Law of the Republic of Moldova, Administrative Court Act (Moldova) [2000] No 793-XIV, art 17(1) both of which provides for 30-day appeal period, while for France it is within months. 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>. The international law instruments such as the 1951 Refugee Convention (n 36) art 31(2) on appeal; the 1954 Convention (n 13), and the Handbook on the Protection of Stateless Persons (n 11) 19 [47] on appeal/review did impose a specific time frame for submission of appeal applications. 139 See, E I Nwogugu, ‘Recent Changes in Nigerian Nationality and Citizenship Law’ (1976) 25 International and Comparative Law Quarterly 423, 434. 109