whether the individual applying was stateless. Before 2008, decision-making on applications where statelessness had not been previously identified was undertaken by the asylum policy team but this was now the responsibility of the Travel Document team. It was explained that the Bradshaw test164 was adopted, the burden of proof was placed on the applicant and that the Travel Document team would not usually take any role in contacting consular authorities. Moreover, although reliance was placed upon the 1954 Convention, there was no internal guidance on how statelessness ought to be assessed. It was emphasised that the consideration of these application was a very small proportion of the team’s work.165 In conclusion, the UK should ensure that it has a procedure in place to issue identity documents to stateless persons who do not have valid travel documents and are on the UK territory. To support this, the research suggests that it may be necessary to develop guidance on the identification of statelessness and training on it could be given to members of the Travel Document team. UNHCR will issue Guidelines on the definition of a stateless person in Article 1(1) of the 1954 Convention that should inform the guidance developed. 4.5 The identification of statelessness in immigration law This section will begin by setting out UK immigration law on the identification of statelessness, before continuing to set out themes that emerged from the evidence gathered by the researchers in respect of the identification of statelessness. These findings are based on participants’ testimonies and review of their immigration files, as well as several semi-structured interviews with UK Border Agency officials. Given that the vast majority of participants had claimed asylum, much of the analysis concerns how statelessness is engaged with within the UK asylum procedure. A common feature for many of the participants interviewed was the lack of a substantive investigation of their actual or potential statelessness by the UK Border Agency. Consequently, their stateless status was hidden and did not affect the way in which they were treated by the UK Border Agency and other public authorities. A review of participants’ immigration case files showed that participants’ claims to be stateless were not prioritised. Legal representatives made detailed submissions on statelessness to the UK Border Agency in only a handful of cases.166 Where such submissions were made, they usually took the form of further submissions following the refusal of an asylum claim. 164 See Section 4.6.3. 165 In 2010, 135 Stateless Person Travel Documents were issued, whereas the team estimated that it received 20,000 applications for Travel Documents, for example under the 1951 Refugee Convention, per year. 166 Participants 2, 3, 5, 20, 28, 33 and 37. However, more cursory references to the fact of an individual being stateless were made in relation to some other participants, and for some cases it was not possible to review the full immigration file in order to assess whether representatives’ submissions engaged with the issue of statelessness. in the United Kingdom 75