5HSRUWRQ5XVVLD between the individual and the state, which can be compared with marriage.19 Accordingly, the Soviet legislator proclaimed that the duty of every citizen of the USSR was ‘to bear with dignity the high calling of citizen of the Soviet Union’; ‘citizens of the USSR are obliged to uphold the honour and dignity of Soviet citizenship’ (art.59(1) of the 1977 Constitution of the USSR). Following this logic in the case of a breach in fidelity to the state, citizenship could be terminated on the initiative of the state. Therefore, the 1978 Soviet Citizenship Law (art.18) kept the provision regarding deprivation of citizenship: ‘the deprivation of citizenship of the USSR can take place in the exceptional case based on the decision of the Presidium of the Supreme Soviet of the USSR, if the person has performed actions discrediting the high calling of citizen of the Soviet Union, and damaging the honour (prestige) and state security of the USSR’ (Shetinin 1975: 4; Vitruk 1979: 38). 3.2.4 The Gorbachev Era After the new Soviet leader Mikhail Gorbachev initiated glasnost ("openness") and perestroika ("restructuring") it became clear that a lot of Soviet legislative acts had to be reviewed and amended. In 1990 the new and last Citizenship Law of the USSR was adopted and entered into force on 1 January 1991.20 The 1990 Soviet Citizenship Law can be considered as the most detailed and longest lex specialis among other Soviet citizenship laws. The competence to grant and revoke citizenship was transferred from the Presidium of the Supreme Soviet of the USSR to the President of the Soviet Union, i.e. to Mikhail Gorbachev. The 1990 Soviet Citizenship Law kept the provisions with regard to the deprivation of citizenship, but the conditions of this act were limited. Thus, according to Article 23 of the Soviet Citizenship Law, deprivation of citizenship could only occur in exceptional cases and only to Soviet citizens living abroad if that citizen had performed actions substantially damaging the state’s interests and the security of the USSR. Article 22 specified the following grounds for loss of Soviet citizenship: 1) as a consequence of the fact that the person has entered into the service of military forces, security forces, police, organs of justice or other governmental, administrative bodies of a foreign state; 2) if a Soviet citizen with permanent residence abroad failed to register in the respective Soviet consulate for five years without any reasonable excuse; 3) if Soviet citizenship was obtained by use of fraudulent documents or by knowingly using false information. Thus, by the adoption of the Soviet Citizenship Law 1991, the first real steps were made towards democratization and establishment of legal clarity in the relations between the Soviet state and its citizens. The adoption of the last Soviet Citizenship Law was undoubtedly a great improvement on the preceding citizenship regimes. Despite the fact that the deprivation of citizenship remained in the law, the provision of a comprehensive list of reasons for this measure was a step forward (previously it was entirely dependent on the discretion of the Soviet authorities). Of course, the 1990 Citizenship Law must be seen a product of its time; it also continued to maintain the provision regarding non-toleration of dual citizenship (art.11) (Tunkin 1979: 22). In summary, the following main features of Soviet Citizenship Laws between 1917-1991 can be highlighted: 1) During all Soviet history citizenship of the USSR remained de facto in the form of a single union (federal) citizenship. The declared citizenship of the Soviet Republics can be regarded as a legal fiction which existed until the end of the Soviet Union. This conclusion is proved by the fact that 19 In this regard we can recall the ideas regarding citizenship which were present elsewhere in the nineteenth century: ‘Letter from George Bancroft to Lord Palmerston (Jan. 26, 1849), in S. EXEC. DOC. NO. 36–38, at 164 (1850) [nation-states should “as soon tolerate a man with two wives as a man with two countries; as soon bear with polygamy as that state of double allegiance which common sense so repudiates that it has not even coined a word to express it”]. (Spiro 2010: 114) 20 The Law of the USSR from 23 May 1990 N 1518-1 ‘About the Citizenship of the USSR’. Svod Zakonov SSSR, Vol.1. p.47. 1990. 56&$6(8'2&,7&5‹$XWKRU