96 COLUM. J. RACE & L. [Vol. 11:83 Dominican, thereby excluding them from citizenship.51 In effect, the decision meant that the Constitution (and its interpretation) shifted from operating under a jus soli principle—redefining Dominican citizenship to exclude and render stateless thousands of Haitian Dominicans.52 As has been noted, “[t]he current legal conceptions of Dominican citizenship reflect widespread cultural practices and historical trends, in which Haitians have historically been portrayed as racialized ‘others.’”53 More recently, the 2019 update of the National Register of Citizens in Assam, India, has been described as “possibly the largest exercise in creating conditions of statelessness” 54 in history.55 The most recent draft list excluded 1.9 million people, disproportionately impacting Bengali-speaking Muslims (with other religious and ethnic minorities caught in the intersectional xenophobic expulsion). 56 The subsequent enactment of the Citizenship Amendment Act by the Indian Parliament has been widely condemned as embodying direct discrimination against 51 Pierre v. No. Judgment 473/2012, TC/0168/13 1, 98 (Dom. Rep. Trib. Const. 2013). See also U.N. High Comm’r for Refugees, Submission by the U.N. High Comm’r for Refugees for the Office of the High Comm’r for Hum. Rts.’ Compilation Rep., Universal Periodic Rev.: Haiti, at 2 (Mar. 2016) (estimating that 133,000 Dominicans of Haitian descent were rendered stateless by the decision of the constitutional court). 52 See Jonathan M. Katz, What Happened When a Nation Erased Birthright Citizenship, ATLANTIC (Nov. 12, 2018), https://www.theatlantic.com/ideas/archive/2018/11/dominican-republic-erasedbirthright-citizenship/575527/ [https://perma.cc/6CHR-TBDK]; Alan Yuhas, Dominicans of Haitian Descent Turned into ‘Ghost Citizens’, says Amnesty, GUARDIAN (Nov. 19, 2015), https://www.theguardian.com/world/2015/nov/19/dominican-republic-violatedhuman-rights-haitians-citizens [https://perma.cc/S9AG-Z5E9]. 53 Sagas & Roman, supra note 49, at 37. See, e.g., Mejia, supra note 50; BELTON, supra note 1. 54 Priya Pillai, Of Statelessness, Detention Camps and Deportations: India and the “National Register of Citizens” in Assam, OPINIO JURIS (Jul. 12, 2019), https://opiniojuris.org/2019/07/12/of-statelessness-detention-camps-anddeportations-india-and-the-national-register-of-citizens-in-assam [https://perma.cc/7GSW-9SSV]. 55 See also Rohini Mohan, Inside India’s Sham Trials That Could Strip Millions of Citizenship, VICE NEWS (Jul. 29, 2019), https://news.vice.com/en_us/article/3k33qy/worse-than-a-death-sentence-insideindias-sham-trials-that-could-strip-millions-of-citizenship [https://perma.cc/4DE7-4H8S]. 56 See generally Anushka Sharma, Contextualizing Statelessness in the Indian Legal Framework: Illegal Immigration in Assam, 8 CHRIST U. L.J. 25 (2019) (arguing that current legal frameworks are not equipped to address statelessness); Amit Ranjan, National Register of Citizen Update: History and its Impact, ASIAN ETHNICITY, June 28, 2019, at 1.