Citizenship Act does not explicitly state that the principle of jus soli (Section 4) needs to be read with the principle of jus sanguine (Section 5) and the Court’s interpretation has led to a legal anomaly.10 By clubbing two independent provisions of the Pakistan Citizenship Act, the Court in essence eliminated the citizenship by birth provision provided in Section 4 altogether, leaving it without any legal effect. Moreover, the Peshawar High Court further held that Afghan refugees, who had only been provided refuge temporarily and are not citizens of Pakistan, are not governed by the Pakistan Citizenship Act and fall under the purview of the Foreigners Act, 1946. Another case concerning citizenship by birth is that of Saeed Abdi Mahmud v. National Database Registration Authority. In this case, the petitioner was born in Pakistan to Somali nationals. The petitioner had approached NADRA with his birth certificate for the issuance of CNIC, but NADRA denied issuance of CNIC to him.11 In this case, the Court also emphasizes that Section 4 of the Pakistan Citizenship Act 1951 follows the principle of jus soli, which means citizenship is granted based on place of birth. The Court explained that while interpreting Section 4 of the Act, the literal rule of statutory interpretation applies. This means that the words and phrases used in the statute should be understood in their plain and obvious sense. Therefore, the Court concluded that Section 4 of the Act has only one interpretation: anyone born in Pakistan is unequivocally a citizen of Pakistan according to the law, as the language used in the section is straightforward and unambiguous.12 However, while the Court affirmed the principle of jus soli under Section 4, it also reiterated that citizenship by birth did not apply to Afghan refugees relying on the earlier ruling of the Peshawar High 10 S. N. Farhat. (2019). Citizenship laws of Pakistan: A critical review. Policy Perspectives, 16(2), 59–85. 11 Saeed Abdi Mehmud v. NADRA [2018] CLC 1588 (Islamabad), Islamabad High Court. 12 Ibid. 6