this criticism has not been examined by the UK Courts and the Bradshaw approach has been approved in the context of assessing statelessness in asylum applications.174 The Bradshaw approach does not result in the burden of proof being shared between the applicant and the authorities. Further, the requirement that the applicant “would have to apply to those states which might consider her to be and might accept her as a national” runs the risk of conflicting with the Prato Summary Conclusions. They found that “[w]hether an individual actually is a national of a State under the operation of its law requires an assessment of the viewpoint of that State. This does not mean that the State must be asked in all cases for its views about whether the individual is its national in the context of statelessness determination procedures”.175 Further, “given that Article 1(1) is a negative definition, ‘by any State’ could be read as requiring the possibility of nationality to be ruled out for every State in the world before Article 1(1) can be satisfied. However, the adoption of an appropriate standard of proof would limit the States that need to be considered to those with which the person enjoys a relevant link (in particular by birth on the territory, descent, marriage or habitual residence)”.176 The practical problems that result from the Bradshaw approach can be seen in the case of Steven,177 one of the participants in the study. Name: Country of origin: Date of arrival in UK: Time in detention: Time in limbo: Current status: Steven (Participant 29) Mozambique July 2003 N/A 76 months None Steven is 29. He believes he was born in Mozambique, but has no evidence of this, nor of entitlement to Mozambique or any other nationality. He spent his entire childhood travelling between Mozambique, Zimbabwe and Zambia with his mother. This cycle continued until 2000 when his mother left him alone in Zimbabwe, since which time he has not had any further contact with her. He left Zimbabwe following problems caused by his involvement with the Movement for Democratic Change (MDC) and travelled to the UK where he claimed asylum in July 2003. His asylum claim was refused, as was his subsequent appeal in December 2003. His most recent further submissions were refused in March 2011, although no removal directions have been set, apparently due to uncertainty about his nationality. He describes his efforts since being in the UK to try to establish his nationality. “I have no identity documents to show that I am from a country which I could be returned to. I contacted IOM [the International Organisation for Migration] about voluntary return, but they advised me that I need to be able to prove where I am from in order to be returned there. I have phoned the Zimbabwean embassy in London but they told me that I need to have documentary evidence to show that I am from Zimbabwe before they can assist me. I asked them if they could search the population registrar but they told me that I would have to do this physically in Harare. I also contacted the Zambian embassy but they told me the same thing. Recently 174 M.A. (Ethiopia) v. SSHD, op. cit. paras. 52-53. 175 UNHCR, Prato Summary Conclusions, para. 12. 176 Ibid., para. 22. 177 It was not possible to obtain a full paper file for this case but factual aspects were checked on CID as well as the limited papers available. in the United Kingdom 77