30. The CNICs act as the most common proof of citizenship in Pakistan and are necessary to exercise key rights, including birth registration. People who are 18 years and above can be eligible to apply for a CNIC.59 The documents required to apply for a new CNIC include identification documents (original/copy of CNIC) of either parent or blood relatives.60 The NADRA website also provides for applicants to apply for a fresh CNIC independently by providing any two witnesses, who are CNIC holders. While priority is given to paternal/maternal relatives, “any CNIC holder personally known to applicant and of the same area/locality�� may also be a witness for the applicant.61 Based on this, stateless adolescents could be eligible to apply for a CNIC by providing any two witnesses as supporters of their application. However, in practice, NADRA officials have insufficient understanding of these governing laws and policies or appear unwilling to implement them.62 31. The case study in Annex I exemplifies how NADRA has been responsive and proactive at the higher level with an understanding of the issue and a seeming desire for resolution. There has been support and efforts to fill the implementation gap. At field level though, challenges prevail, both as a result of ignorance of government policy, and prevailing prejudice against members of certain ethnic groups. 32. It appears that the jus soli provision of Pakistani citizenship law would provide foundling children access to citizenship, however the in-practice application of this law is unclear.63 Children in orphanages can be registered with NADRA through the orphanage, and the process has been facilitated by NADRA to ensure access to rights.64 However there is a lack of a process for foundlings not living in orphanages or children’s homes. Birth registration (registration as aliens) 33. The Alien Registration Rules provide for registration of minors with issuance of Alien Cards, disregarding the birth right provision of the PCA more specifically when dealing with children that are stateless or at risk of statelessness. 34. The major impact is on stateless populations or those at risk of statelessness, specifically those that are ethnic Bengali and Bihari, who upon the creation of NARA in 2000, suffered due to discriminatory practices. The process makes it mandatory for all previous NARA card holders to register, not considering the forced registrations and the process in place for application of the cancellation of NARA cards issued wrongly. Many NARA card holders have CNICs that have been blocked. This in turn impacts entire families that are deprived of the possibility of citizenship. Access to documentation 59 Children under 18 years do not have CNICs in Pakistan. CNICs are for adults (18+). Children can either be issued a “Child Registration Certificate” and also a “Juvenile Card”. 60 NADRA Website, <https://www.nadra.gov.pk/identityrequirements/#:~:text=Original%20National%20Identity%20Card%20>, accessed July 13, 2022. 61 Ibid. 62 Musawi and Institute on Statelessness and Inclusion, The Impact of COVID-19 on Stateless Communities in Pakistan, (July 2022), forthcoming, at 20. 63 The Citizenship Act (1951) s 4 (Bangladesh); The Pakistan Citizenship Act (1951) s 4. 64 ‘NADRAS move to register orphan children’, DAWN, (Online, 21 November 2021), <www.dawn/news/1659296>, accessed July 13, 2022. 10