Kelly Kapianga (LCK Chambers) their death, become a citizen by birth.26 A woman marrying a Zambian citizen after 23rd October 1964;27 An adult (or married woman) Commonwealth or Irish citizen, or citizen of an African country included in a list to be published by the minister, who was ordinarily resident in (present day) Zambia for the prescribed amount of time before the application.28 It is unclear if any list of African countries or the time a person had to be resident in Zambia to be eligible to apply as contemplated by this provision were ever created. This provision for facilitated access was in line with a scheme implemented across Commonwealth countries to provide reciprocal access to citizenship, with the addition of rights for those from named African states. The Citizenship Act gave the Minister of Home Affairs the power to exercise discretion to register individual applicants who were not otherwise eligible to apply.29 This rule appeared to serve a political purpose, that is, to allow the Minister to disallow the registration of people from countries whose interests diverged from Zambia’s -- such as Rhodesia (as Southern Rhodesia had been renamed). The Citizenship Act also empowered the President to direct that a person who was not otherwise eligible for citizenship should be registered as a citizen as a token of honour in cases where that person had, in the President’s opinion, had acted honourably or special circumstances existed to warrant their registration.30 2.2.6 Citizenship by naturalisation The 1964 Constitution empowered Parliament to enact legislation allowing people not otherwise eligible for citizenship to apply for citizenship.31 The Citizenship Act, 1964 accordingly provided that a person above the age of 21 years could apply for citizenship by naturalisation, which would be granted in a discretionary basis (by contrast to the entitlement for registration) if they satisfied the Minister of Home Affairs that they: a) were ordinarily resident in Zambia and had been resident in Zambia for at least 5 years immediately before making the application. It is unclear whether the eligible time had to be before or after independence; b) Were of good character; c) Had adequate knowledge of English or other Zambian languages. d) Intended, after being naturalised, to continue residing in Zambia, or continue in the service of the Government abroad; e) Were willing to renounce any alternative citizenship they may have had at the time of the application; and f) Had not previously been denied registration as a citizen by naturalisation within the preceding 2 years.32 26 Independence Constitution, Art 4(1) and 4(4) Independence Constitution, Art 7 28 Independence Constitution, Art 8(1) 29 Citizenship Act, 1964, section 12(4) 30 Section 4A of the Citizenship of Zambia Act, 1964 31 Independence Constitution, Art 11(1) 32 Section 6(1) of the Citizenship Act, 1964 27 6 RSCAS/GLOBALCIT-CR 2020/14- © 2020 Author(s)