(iii) Agreement between the parties; (iv) Expert oral or affidavit evidence; (v) Foreign and Commonwealth Office letters; (vi) Text of relevant nationality law of country(ies) concerned;180 and, (vii) Secretary of State for the Home Department asking questions of a relevant country’s Embassy.181 In conclusion, the UK courts currently consider that if an applicant seeks to establish statelessness, the burden of proof is placed on the applicant. It appears that there is a strict requirement for the applicant “to apply to those states which might consider her to be and might accept her as a national”. In contrast, in the context of refugee status determination, the UK courts have been prepared to consider a greater number of sources of evidence. The Bradshaw approach to the interpretation of Article 1(1) of the 1954 Convention risks frustrating its object and purpose of assuring “stateless persons the widest possible exercise of these fundamental rights and freedoms”.182 The participants’ testimony explains how difficult it is for individuals to prove that they are stateless, particularly if they are vulnerable. It is therefore recommended that in assessing statelessness in the future the courts should take into account and give appropriate weight to forthcoming UNHCR Guidlines. 4.6 Guidance and training There is little UK Border Agency guidance on how to identify statelessness within asylum claims.183 Officials are aware of the guidance and it was referred to in semi-structured interviews with the New Asylum Model (NAM+) Training Team, a Senior Asylum Caseworker, the Quality Audit Team and Screening Officers at Asylum Screening Unit.184 The limited existing guidance that exists emphasises, in respect of “Doubtful Nationality Cases”, that: “It is important to keep in mind that the fact that the officer does not accept the applicant’s claim to nationality but has insufficient evidence of an alternative country or territory to which the applicant can be removed, does not mean the applicant falls to be granted asylum as a Stateless person. In order to make a claim for refugee status as a Stateless person, the applicant must satisfy the officer that they have no nationality and that they are outside the country of their last habitual residence owing to a well-founded fear of persecution for a Convention reason, and that owing to such a fear they are unable or unwilling to return to it.”185 180 The above is an edited version of the guidance in Smith (Liberia) v SSHD [2000] UKIAT 00TH02130. 181 See MA (Disputed Nationality) Ethiopia v. SSHD, [2008] UKAIT 00032, United Kingdom: Asylum and Immigration Tribunal / Immigration Appellate Authority, 17 April 2008, available at: http://www. unhcr.org/refworld/docid/48076a1c2.html. 182 1954 Convention, Preamble. 183 See UK Border Agency, Nationality Doubtful, Disputed and Other Cases, available at: http:// www.ukba.homeoffice.gov.uk/sitecontent/documents/policyandlaw/asylumprocessguidance/ specialcases/guidance/natinality-doubtful-disputed?view=Binary. 184 Anecdotal information from semi-structured interviews with the NAM+ Training Team (19 July 2011), a UKBA Senior Asylum Caseworker (15 August 2011), the Quality Audit Team (1 August 2011) and the Asylum Screening Unit (15 August 2011). 185 UK Border Agency, Nationality Doubtful, Disputed and Other Cases, op. cit., para. 5.2. in the United Kingdom 79