Bronwen Manby The new laws largely followed the model of those in effect in the metropolitan territories of the respective colonial powers (but never applied in their colonies), creating half a dozen basic templates across the continent. In the British territories a standard framework was established by the negotiated independence constitutions: citizenship was automatically attributed at independence to the second generation born in the country (the principle of double jus soli), with rights to register during a transitional period for some other categories of resident (largely those whose origins were in another British territory), followed in almost all cases by jus soli attribution to all those born in the territory after independence – the same rule established by the British Nationality Act of 1948. Elsewhere, nationality was left to the new governments to establish in law, allowing for greater variation, but still much similarity in practice. In the French territories, the new laws revolved around the French nationality code of 1945; in West Africa mostly combining a descent-based system with double jus soli, and providing transitional rights to register for those originating from other French territories. The Belgian territories of Central Africa all adopted a solely descent-based framework in line with the Belgian model. The Portuguese territories that gained independence a decade and a half later equally followed the general framework of Portuguese law at that time, with strong rights based on place of birth; but also a much greater degree of gender equality, influenced by the development of international norms and the socialist leanings of their independence movements (see generally, Manby, 2018, chap. 4). The similarities by legal system and recognition of common colonial ties could not, however, disguise the extent to which the status of those associated with the former colonial powers was immediately controversial; including the privileged ‘intermediary’ classes of Arab and Asian descent in East Africa, and Middle Eastern descent in West Africa. Measures introduced to promote the ‘Africanisation’ of the economy were paired with initiatives to restrict or block access to citizenship. In Liberia, founded by free American blacks, the constitution had since 1847 – likely inspired by the Haitian constitution of 1843 – restricted citizenship to those of ‘negro descent’; Sierra Leone copied this provision in constitutional amendments adopted within a year of independence to restrict birthright citizenship to ‘negro Africans’; and Malawi enacted a similar restriction in 1966. Following the same pan-African logic, a number of the new nationality codes in both former French and British territories adopted provisions facilitating recognition of citizenship for those originating from other African countries – as well as, or instead of, those from former territories of the same colonial power. The most common way in which the newly independent African states sought to constrain access to citizenship by those ‘non-natives’ who had dominated the colonial economy was to adopt a partial or total ban on dual nationality – a strategy shared with other post-colonial geographies. At the same time, provisions designed in principle to allow incomers to acquire citizenship of the new states at independence were implemented with reluctance and delay. Inclusion and Exclusion Over Time In the years following independence, rights based on birth in the territory were generally reduced. Most dramatically, the rule of absolute jus soli was rapidly removed across almost all the former British territories, and replaced by a purely descent-based regime. Several of the former French and Portuguese territories also diluted the role of jus soli in attribution of citizenship at birth; those with the largest populations of foreign origin (notably Algeria, Madagascar and Djibouti, when it finally gained independence in 1977), had done so from the first post-independence citizenship law. These amendments often implied a new emphasis on ethnicity in citizenship determination, especially at the procedural level. This implication was made explicit in half a dozen states by the adoption of substantive amendments to the citizenship law discriminating on the grounds of ethnic identity: in Somalia and the former Belgian Congo (now Democratic Republic of Congo) from the outset, and in Swaziland (now eSwatini), Nigeria, Uganda, South Sudan, and Rwanda over time (Manby, 2018, chap. 5). Conditions for naturalisation have generally become more restrictive (Manby, 2021a). 7 Robert Schuman Centre for Advanced Studies