2021] 99 NATIONALITY LAWS Tunis and Morocco Opinion, the Permanent International Justice made the following statement: Court of The question whether a certain matter is or is not solely within the jurisdiction of a State is an essentially relative question; it depends upon the development of international relations. Thus, in the present state of international law, questions of nationality are, in the opinion of the Court, in principle within this reserved domain. . . . [I]t may well happen that, in a matter which, like that of nationality, is not, in principle, regulated by international law, the right of a State to use its discretion is nevertheless restricted by obligations which it may have undertaken towards other States. In such case, jurisdiction which, in principle, belongs solely to the State, is limited by rules of international law.70 Today, it is well accepted by scholars that international human rights law has evolved to place significant constraints on states’ prerogatives in nationality matters, such that traditional notions of sovereignty have been eroded, albeit not eradicated.71 It is often stated that, in many instances and under certain circumstances, a refusal to grant nationality or a withdrawal of nationality violates norms of international law. Scholars tend to point to a cluster of intersecting areas of international human rights law to establish the claim that the traditional position has been modified in important ways. Interestingly—and perhaps tellingly—a number of scholars have pointed to ICERD 72 (together with other non-discrimination treaties, or treaties containing non-discrimination clauses) to argue that the 70 Tunis and Morocco Nationality Decrees, supra note 63, at 24. See also Nottebohm Case (Liech. v. Guat.), Judgment, 1955 I.C.J. Rep. 4, ¶¶ 20–21 (April 6). See Mads Andenas, Reassertion and Transformation: From Fragmentation to Convergence in International Law, 46 GEO. J. INT’L L. 685 (2015). 71 For detailed discussions of the phases and contours of international human rights law that constrain state sovereignty in nationality practice, see Spiro, supra note 3. 72 See, e.g., Alice Edwards, The Meaning of Nationality in International Law in an Era of Human Rights, in NATIONALITY AND STATELESSNESS UNDER INTERNATIONAL LAW 26 (Alice Edwards & Laura van Waas eds., 2014) [hereinafter Edwards, The Meaning of Nationality].