2021] NATIONALITY LAWS 123 adopting any policy that directly or indirectly leads to such deprivation.”169 This language of breach of obligation is striking, as it is considerably stronger than the weaker language of “concern” more commonly invoked in relation to cases of denial of citizenship. In other cases of deprivation, while the language of breach or violation is not invoked, there is nonetheless a more forceful approach. For example, in 2012 the Committee noted Jordan’s “withdrawal of citizenship from persons originating from the West Bank of the Occupied Palestinian Territory,” and “urge[d] the State party to discontinue the practice of withdrawing nationality from persons originating from the Occupied Palestinian Territory.” 170 It has further called for remedial action following unlawful deprivation in the form of reinstatement of nationality in the context of Jordan 171 and Iraq.172 The difficulty with this differential approach in relation to denial of nationality on the one hand and deprivation of nationality on the other is that its rationale is not explained in either General Recommendation Thirty or any of the Committee’s concluding observations. Such a neat dichotomy is not evident in the text of the treaty; it is, after all, not clear why a denial of nationality on racial grounds is any less a violation of Article 5(d)(iii)’s right to nationality on non-discriminatory grounds than an active withdrawal of nationality. In only a few concluding observations has Article 1(3) explicitly been mentioned, 173 although, notably, it does not 169 Comm. on Elimination Racial Discrimination, Concluding Observations on Turkmenistan, ¶16, U.N. Doc. CERD/C/TKM/CO/5∗ (Mar. 27, 2007) (emphasis added). See also Comm. on Elimination Racial Discrimination, Concluding Observations on Ethiopia, ¶ 23, U.N. Doc. CERD/C/ETH/CO/15 (June 20, 2007) (noting with concern the situation of children of parents of Eritrean origin, who were deprived of their Ethiopian citizenship in the period 1998–2000); Comm. on Elimination Racial Discrimination, Concluding Observations on Jordan, U.N. Doc. CERD/C/JOR/CO/13-17 (Apr. 4, 2012); Comm. on Elimination Racial Discrimination, Concluding Observations on Jordan, U.N. Doc. CERD/C/JOR/CO/18-20 (Dec. 26, 2017); Comm. on Elimination Racial Discrimination, Concluding Observations on Kenya, U.N. Doc. CERD/C/KEN/CO/1-4 (Sept. 14, 2011). 170 Comm. on Elimination Racial Discrimination, Concluding Observations on Jordan, ¶ 12, U.N. Doc. CERD/C/JOR/CO/13-17 (Apr. 4, 2012). 171 Id. 172 Comm. on Elimination Racial Discrimination, Concluding Observations on Iraq, ¶ 17, U.N. Doc. CERD/C/IRQ/CO/15-21 (Sept. 22, 2014). 173 Our analysis identified that Article 1(3) was mentioned in relation to six countries (being Côte d’Ivoire, Dominican Republic, France, Iraq, Namibia,

Select target paragraph3