Statelessness Determination Procedures asylum procedure when developing an SDP for Nigeria. 115 After all, RSD is the procedure that is closest to an SDP. According to s 8 of the NCFRMI Act, an application for the grant of refugee status could be made on behalf of an applicant by a competent officer or through the office of the UNHCR. 116 The NCFRMI Act does not specify that the applicant must be interviewed, nor does it guarantee the right to an interpreter and legal aid. 117 We would in any event recommend, in accordance with what we earlier suggested in Part III(D), that when drafting an SDP for Nigeria, drawing on the asylum procedure, the following rights be specified in the SDP framework: right to interview, 118 right to free interpretation in the language of the applicant, 119 and right to legal aid. 120 Legal aid should start at the beginning of an SDP application and not commence only at the appeals stage ie the current asylum procedure in Nigeria. It should be clearly stated that no administrative fee will be charged for 115 In addition to pt V of the NCFRMI Act (n 92) on steps to applying for refugee status in Nigeria, 116 117 118 119 120 the NCFRMI has an unpublished supplementary Standard Operating Procedures (‘SOP’) on RSD jointly developed by NCFRMI and UNHCR: Standard Operating Procedures for Refugee Status Determination in Nigeria (NCFRMI and UNHCR, 2006) (‘Standard Operating Procedures — Nigeria’). A hardcopy of the SOP was retrieved and discussed in the course of this research with an official of the RSD unit at the NCFRMI. NCFRMI Act (n 92) s 8. In practice, UNHCR sponsors legal aid for refugees, as the Government has no provision for it. However, the NCFRMI supplementary SOPs do guarantee the right to an interpreter and legal aid: Standard Operating Procedures — Nigeria (n 115) 8 [2.1](xii), 20 [3.4](iii), 38 [6.1]. Interview is compulsory in Moldova, see Moldova Foreigners Regime (n 110) art 873. Interview is also compulsory in Paraguay, see Paraguay Statelessness Law (n 105) arts 33(e), 36. However, it is optional in France and the UK. For France, see Code de l'entrée et du séjour des étrangers et du droit d'asile [Code for the Entry and Stay of Foreigners and the right to asylum] (France) art R 812-2 (‘CESEDA’); Guide des Procedures a l’OFPRA [Guide to the Procedures of OFPRA] (Policy Guide, OFPRA 2019) 44 <https://www.ofpra.gouv.fr/sites/default/files/atoms/files/guide_des_procedures_a_lofpra__2019.pdf> (‘OFPRA Guide’). For the UK, see ‘Applications for Leave to Remain as a Stateless Person’ Home Office (Web Page, 1 May 2013) <https://webarchive.nationalarchives.gov.uk/20131002094719/http://www.ukba.homeoffice .gov.uk/sitecontent/documents/policyandlaw/stateless-guide/statelessguide.pdf?view=Binary>. Applicants in Moldova, UK, Paraguay and France get free interpretation. For Moldova, see Moldova Foreigners Regime (n 110) art 871. For UK, see Home Office, Stateless Leave Version 3.0. (Policy Guide, 30 October 2019) 12 <https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_d ata/file/843704/stateless-leave-guidance-v3.0ext.pdf> (‘Home Office Stateless Leave’). For France, see CESEDA (n 118) art R.812-2. For Paraguay, see Paraguay Statelessness law (n 105) art 33(e). Legal aid is guaranteed by law in Moldova, see Law No 198 of 26.07.2007 on the Legal Assistance Guaranteed by the State (Republic of Moldova) arts 6, 7. For Paraguay, legal aid is only guaranteed for applicants without financial means, see Paraguay Statelessness Law (n 105) art 38. In the UK and France, there is no such provision. For the UK, see Johanna Bezzano and Judith Carter, Statelessness in Practice: Implementation of the UK Statelessness Application Procedur (University of Liverpool Law Clinic 2018) 7. While for France, legal aid is only available to French nationals and nationals of the member states of the European Union. Foreign nationals habitually and regularly residing in France are also eligible for legal aid. However, legal aid may exceptionally be granted to persons (including stateless persons) who do not fulfil the conditions set out in the law on legal aid, when their situation appears particularly worthy of interest. See Loi n° 91-647 du 10 juillet 1991 relative à l'aide juridique [Law No 91-647 of July 10, 1991 relating to legal aid] (France) JO, art 3 <https://www.legifrance.gouv.fr/affichTexteArticle.do?cidTexte=JORFTEXT00000053761 1&idArticle=LEGIARTI000030022902&dateTexte=&categorieLien=id>. 106