of Discrimination against Women 30 (CEDAW - see Article 9), the International Convention on the Elimination of All Forms of Racial Discrimination 31 (CERD - see Article 5(d)(iii)), and the Convention on the Rights of Persons with Disabilities32 (CRPD - see Article 18). Furthermore, the right to a nationality is protected in Article 15 of the Universal Declaration on Human Rights. 14. The Committee against Torture has also previously recommended Latvia: (i) enhance efforts to raise the awareness of parents whose children are eligible for naturalisation and consider granting automatic citizenship at birth, without previous registration by parents, to the children of non-citizen parents who do not acquire any other nationality, with a view to preventing statelessness; and (ii) consider offering language courses free of charge to all non-citizen residents and stateless persons who wish to apply for Latvian citizenship.33 Overview of Statelessness in Latvia 15. In 2019, UNCHR estimated there to be over half a million stateless people in Europe. 34 In its Global Trends report, UNHCR provides two separate figures for the population under its statelessness mandate in Latvia at the end of 2019: 169 stateless persons under the Latvian Law on Stateless Persons of 17 February 2004 and 216,682 ‘noncitizens’ under the 25 April 1995 Law on the Status of those Former USSR Citizens who are not Citizens of Latvia or Any Other State.35 The latter, larger group, are defined in Latvian law as former USSR citizens and their descendants who have not received citizenship automatically, obtained citizenship through naturalisation or other means, or taken another country’s citizenship since the restoration of Latvian independence.36 16. Under domestic law, ‘non-citizens’ are excluded from the definition of a ‘stateless person’ as they are considered a separate legal category of persons who enjoy a significant set of rights. 37 People who fall under either category in Latvian law (‘stateless person’ or ‘noncitizen’) are stateless under international law (Article 1(1) of the 1954 Convention), and this submission addresses the human rights of both groups. Although ‘non-citizens’ are granted rights (and a route to naturalisation if they can meet certain conditions) that go beyond the minimum rights prescribed by the 1954 Convention, they are not entitled to ‘equivalent rights’ to Latvian nationals. There are important differences distinguishing non-citizens from citizens, including a lack of political rights and restrictions on employment and property ownership. Moreover, ‘non-citizens’ in Latvia clearly lack a nationality and therefore meet the definition of a stateless person under international law regardless of whether they should be 30 Accession on 14/04/1992. Accession on 14/04/1992. 32 Signature on 18/07/2008, ratification on 01/03/2010. 33 CAT/C/LVA/CO/3-5, Concluding observations on the combined third to fifth periodic reports of Latvia, 23 December 2013, 16b, 16c. 34 UNHCR (2020), Global Trends: Forced Displacement in 2019, https://www.unhcr.org/statistics/unhcrstats/5ee200e37/unhcrglobal-trends-2019.html 35 Ibid, footnote 27, p. 77. 36 Par to bijušās PSRS pilsoņu statusu, kuriem nav Latvijas vai citas valsts pilsonības (On the Status of those Former U.S.S.R. Citizens who do not have the Citizenship of Latvia or that of any Other State) https://likumi.lv/doc.php?id=77481 37 The Constitutional Court of the Republic of Latvia, Riga, March 7, 2005 JUDGMENT in the name of the Republic of Latvia in case No 2004-15-0106, Para 15.: http://www.satv.tiesa.gov.lv/wpcontent/uploads/2004/07/2004-150106_Spriedums_ENG.pdf; SKA – 472/2008, 3 October 2008 (Supreme Court Judgement): https://www.tiesas.lv/nolemumi/pdf/1 1451.pdf 31 4