Anna Dziedzic independent states.42 This policy was animated by the desire to ensure that no-one in the former colonies would remain British citizens as well as by the concern to protect minority groups within former colonies from becoming stateless upon independence. This approach was adopted in Fiji and Tuvalu. The independence Constitution of Fiji 1970 provided that persons who were citizens of the United Kingdom and Colonies by birth, naturalisation or registration in the colony of Fiji became Fiji citizens on the day after independence.43 Similarly, the Constitution of Tuvalu 1978 provided that citizens of the United Kingdom and Colonies or British Protected Persons born in Tuvalu, or whose parents were born in Tuvalu, automatically became citizens.44 Three other states in the region, although not former British colonies, also adopted this approach. The Constitution of the Federated States of Micronesia provided for automatic citizenship upon independence for resident citizens of the Trust Territory of the Pacific.45 In Samoa, all persons who were citizens under the Citizenship of Western Samoa Ordinance 1959 became citizens of the independent state of Samoa. In Nauru, citizenship was automatically conferred on any person who, on the date of independence, was included in the ‘Nauruan Community’, as defined in the Nauruan Community Ordinance 1956-1966. Under this ordinance, members of the Nauruan community included Indigenous people of Nauru as well as Pacific islanders married to Nauruans or formally admitted to the community.46 This last category recognised the powers of chiefly leaders in Nauru to admit new members according to indigenous custom.47 (ii) Descent The second approach was to define and confer citizenship on the basis of descent. Provisions of this kind were commonly framed to confer citizenship on persons whose grandparents or ancestors were born in the Pacific island 48 or who were indigenous. 49 Recognising the movement of Indigenous peoples across what later (somewhat arbitrarily) became colonial and national borders, some constitutions also provided for automatic citizenship for persons whose grandparents were from what are now other states. For example, the constitution of Papua New Guinea conferred automatic citizenship at the date of independence on any person born in Papua New Guinea with two grandparents born in Papua New Guinea or in the adjacent Solomon Islands, Irian Jaya (in Indonesia) or Torres Strait (in Australia).50 The definition of ‘indigenous Solomon Islander’ similarly extended to persons born in Solomon Islands whose grandparents were members of a group or tribe indigenous to Papua New Guinea or the New Hebrides (now Vanuatu).51 (iii) Previous citizenship status and descent In two states, the provisions for the conferral of citizenship upon independence combine the two approaches. Palau’s Constitution conferred citizenship on citizens of the Trust Territory of the Pacific Islands who had at least one parent of recognised Palauan ancestry.52 The Marshall 42 W David McIntyre, Winding up the British Empire in the Pacific Islands (Oxford University Press 2014) 189. Constitution of Fiji 1970 s 19. The date of independence was 9 October 1970. 44 Constitution of Tuvalu 1978 s 19. 45 Constitution of the Federated States of Micronesia 1978 Art III, ss 1, 5. 46 Constitution of Nauru 1968 s 71. 47 See Tetau v Secretary of the Nauru Local Government Council [1976] NRSC 9. 48 Eg Constitution of Kiribati 1979 s 20(1). 49 Eg Constitution of Vanuatu 1980 s 9. 50 Constitution of Papua New Guinea 1975 s 65(1). 51 Constitution of Solomon Islands 1978 s 26. 52 Constitution of Palau 1979 Art III, s 1. 43 10 RSCAS/GLOBALCIT-Comp 2020/1- © 2020 Author