7.  CONCLUSION Overall, the phenomenon of statelessness has not received much attention in Ireland. While it is positive that Ireland has ratified the 1954 and 1961 Conventions, it is apparent from this research that they have not been incorporated fully into law and administrative practice at the national level. There appears be a limited understanding of statelessness and its implications. Stateless persons in Ireland are not a visible population and the absence of accurate statistical data collection and recording hampers understanding of the issue. This invisibility of stateless persons may mean there is a lack of political resolve to address statelessness matters. While the number of stateless persons in Ireland may be low, this research highlights the fact that such persons may face lengthy delays in accessing their rights, if at all, and experience administrative hurdles and challenges any time they engage with government authorities in relation to their status. Practice by officials in ISD at the Department of Justice appears to indicate an unwillingness to accept assertions of statelessness without substantiation, but in the absence of a formal determination procedure and policy, these individuals, who are already in a vulnerable situation, are left with no guidance as to how to demonstrate their lack of nationality and resolve their situation. This research demonstrates that the problems stateless individuals encounter reoccur regularly at various stages of administrative procedures, including renewal of permission to remain and requesting a travel document. This is amplified by the fact that they appear to face the same challenges at times of renewal of their permission to remain and when reissuing a travel document. Stateless persons can spend a considerable amount of time, over years, trying to rectify their situation in a state of heightened anxiety. Without practical procedures to enable them to assert their rights under the 1954 Convention, such persons, in effect, are being denied their rights. Some stateless persons may appear in the international protection procedure, but this is also not without its challenges. If an individual fails to be correctly registered as stateless upon entry to Ireland and the protection procedure, it can be difficult to amend and rectify their status subsequently in the procedure. This is so even if an IPO authorised officer and/or IPAT Tribunal member finds that the applicant is stateless in their decision. The analysis of IPO section 39 reports and IPAT decisions shows that there is an understanding of statelessness, albeit inconsistently interpreted, but this does not appear to fully translate to the individual person concerned being accurately recorded as stateless across ISD systems. As regards the prevention and reduction of statelessness, the national legal framework provides for the reduction of childhood statelessness, but the absence of a transparent procedure and guidance means there is a lack of clarity on how to enable stateless children born in Ireland to assert their right to citizenship under section 6(3) of the Irish Nationality and Citizenship Act 1956. Section 6.2 of this report also highlights the lack of legal safeguards to prevent statelessness in the current revocation procedure. Following the Supreme Court decision of Damache v. Minister for Justice and Equality there is an opportunity for the Irish authorities to reform the law in this area in order to avoid statelessness as a result of revocation. A lot of the issues raised in this report would be solved by the establishment of a clear and transparent determination procedure. A statelessness determination procedure would facilitate access to the rights guaranteed to stateless persons under international and national law. Formalising a determination procedure would ensure fairness, transparency, and efficiency to the benefit of stateless persons and the Irish authorities. Presently, and in the absence of a determination procedure, UNHCR recommends greater co-ordination between state agencies both in the way that data is collected and recorded and the way that statelessness is assessed in individual cases. There are practical steps that can be taken to alleviate the burden on stateless persons in both the international protection and immigration procedures through more coordination and understanding of the issues faced by this cohort of people. UNHCR remains at the disposal of the government to provide technical legal advice on the formulation of a statelessness determination procedure and to assist with capacity building activities for the relevant government authorities. UNHCR 37