It is well recognised that litigation can only play a ‘strategic’ role within a broader ecosystem of advocacy.200 However, it is evident that nationality litigation has been particularly important both at the outset of a trend in reforms and in those States that continue to hold onto a policy even when most others have adopted reforms—as in the cases challenging discrimination based on sex brought in Botswana in 1991201 and, at thirty years’ remove, in Sudan,202 Malaysia203 and Eswatini.204 Litigation has overturned residual discrimination based on sex affecting children born out of wedlock, in cases before the ECtHR,205 the United States (US) Supreme Court,206 the Bahamian Court of Appeal (confirmed by the Judicial Committee of the Privy Council)207 and the South African Constitutional Court.208 Litigation is also being employed to challenge those States holding out against the international trend to accept dual nationality.209 Litigation has been an especially important tool for those groups of people with the least lobbying power for legislative reform, such as those born from assisted reproduction, before the ECtHR (in a case against France210) and the CJEU (in cases against Bulgaria211 and Poland212). But litigation has also been critical to advocacy on behalf of the poorest and much more numerous groups, such as those born in the territory with no real claim to another nationality, but who are nonetheless considered to be foreign (including the litigation referenced throughout this article before regional and international human rights bodies, and in national courts all over the world). Even though political shifts may be more important to law and policy reform in some cases (for example, in Côte d’Ivoire), these judgments help to create a framework for advocacy focused on implementation of the Court’s orders.213 Litigation may of course also have perverse effects. The national backlash in the Dominican Republic against the IACtHR’s Yean and Bosico judgment is widely noted,214 and a very large number of 200 L Bingham and L Gamboa, ‘Litigating against Statelessness’ in L van Waas and M Khanna (eds), Solving Statelessness (Wolf Legal Publishers 2017) 129; Manby (n 199); more generally, see JA Goldston and E Dailey, ‘Strategic Litigation Impacts: Insights from Global Experience’ (Open Society Justice Initiative 2018). 201 U Dow (ed), ‘The Citizenship Case: The Attorney General of the Republic of Botswana vs. Unity Dow, Court Documents, Judgements, Cases and Materials’ (Metlhaetsile Women’s Information Centre 1995), discussed extensively in Knop and Chinkin (n 28). 202 ACJPS & PLACE v Sudan (n 48) paras 33, 38, 41. 203 See ‘Case example: Family Frontiers Litigates for Equality in Malaysian Citizenship Laws’, Box K in Manby (n 199) 66; see the resources at Family Frontiers <https://familyfrontiers.org/>. 204 Machakata v Minister Home Affairs Case No 846/23 (High Court of Eswatini) (for the Notice of Application and Founding Affidavit, see Citizenship Rights in Africa Initiative <https://citizenshiprightsafrica.org/eswatinimachakata-v-minister-home-affairs-others-notice-of-application-and-founding-affidavit/>). 205 Genovese v Malta (2011) 58 EHRR 25, para 46. 206 Jefferson B. Sessions III, Attorney-General v Luis Ramon Morales-Santana (2017) 137 SCR 1678, 1693. See also discussion in Knop and Chinkin (n 28) 528–29. 207 Attorney-General v Rolle Case No 62 of 2020 (Judgment of 21 June 2021) (Court of Appeal of the Commonwealth of the Bahamas); Attorney General (Appellant) v Rolle (Respondents) (Bahamas) [2023] UKPC 13. 208 Centre for Child Law v Director-General Dept of Home Affairs and Others (2021) ZACC 31, para 56 (South African Constitutional Court). 209 Manby (n 95). 210 Mennesson v France App No 65192/11 (ECtHR, 26 June 2014) paras 96–97. 211 Case No C-490/20 VМА v Stolichna obshtina, rayon ‘Pancharevo’ ECLI:EU:C:2021:1008. 212 Case No C-2/21 Rzecznik Praw Obywatelskich v KS ECLI:EU:C:2022:502. 213 A Sesay and A Dongo, ‘Addressing Cote d’Ivoire’s Statelessness Problem: Utilizing Multiple Tools to Support Implementation of Judgments’ in C de Vos and R Murray (eds), Implementing Human Rights Decisions: Reflections, Successes, and New Directions (Open Society Foundations 2021) 29; Jain (n 5) 253. 214 L Marsteintredet, ‘Mobilisation against International Human Rights: Re-Domesticating the Dominican Citizenship Regime’ (2014) XLIV Iberoamericana: Nordic Journal of Latin American and Caribbean Studies 73; S Martinez, ‘The Price of Confrontation: International Retributive Justice and the Struggle for Haitian-Dominican Rights’ in G Andreopoulos and ZF Kabasakal Arat (eds), The Uses and Misuses of Human Rights (Palgrave Macmillan US 2014) 89; PP Zuloaga, ‘Judging Inter-American Human Rights: The Riddle of Compliance with the Inter-American Court of Human Rights’ (2020) 42 HRQ 392.