International Journal of Refugee Law, 2026, Vol. 00, Issue 00
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4. Contextualizing bilateral responses to statelessness
Although the UAE’s agreement with the Comoros was extraordinary, it did not occur in a
vacuum. This bilateral response to statelessness adopted by the UAE and contemplated by
Kuwait bears similarities to the broader phenomenon of the adoption of bilateral agreements as a response to asylum seeking and irregular migration. The turn to bilateral
Lori (n 8) 196.
Economic Citizenship Law, art 6.
117
Fred Mukinda, ‘Meet “Stateless” Man Who Has Been Stranded at JKIA for Four Months’ Nairobi News (6
April 2018) <https://nairobinews.nation.africa/stateless-man-stranded-jkia/> accessed 23 May 2024.
118
Lori (n 8) 196.
119
Kuzmova (n 8) 282.
120
Lori (n 8) 203.
121
ibid 231.
122
Abrahamian (n 33) 248; Rabuffetti and Wills (n 8) 84.
123
Lori (n 8) 230.
115
116
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satisfy the quality or substance of nationality. The substantive elements of nationality operate at two levels. At the international or external level, nationals are entitled to diplomatic
protection (intervention by the state in international legal proceedings on behalf of the
affected national) and consular protection (assistance rendered to nationals by the state
while abroad). Nationals are entitled to the right of entry or admission into the country of
their nationality, as well as the right to reside in that country. At the domestic or internal
level, nationals typically have the right to vote and to stand for public office. Nationals commonly also have obligations to their country of nationality, including to pay taxes, to perform military service, and to be bound by the state’s laws.
The grant of Comorian passports to the UAE’s bidun did not offer any of these elements
of nationality. Passport recipients are not entitled to diplomatic or consular protection from
the Comoros.115 The passports expressly prohibit the bidun from residing on the island
nation.116 This was dramatically illustrated in 2018, when a Comorian passport holder from
the UAE was arrested and deported to the Comoros but was refused the right to enter the
country, and then refused the right to re-enter the UAE, leaving him stranded for four
months in Kenya’s international airport.117 At the domestic level, the passport holders do
not have the right to vote in Comorian elections or to serve in public office,118 and are not
required to serve in the Comorian armed forces (although the UAE subsequently required
Comorian passport-holders to participate in its mandatory national military service).119 The
Comorian passports do not even reliably facilitate travel to other countries; suspicion about
the veracity of the documents has meant that passport-holders are frequently stopped at
borders when attempting to travel120 and, without consular support from the Comoros,
there is no way for passport-holders’ claims about the validity of the passports to be verified.121 The documents do not even reliably function as passports, much less amount to a
grant of nationality to the bidun.
Although the arrangement promised that passport recipients would subsequently be naturalized in the UAE, it is not known how many bidun were ultimately granted UAE nationality.122 It is likely that most remain on temporary residency visas, dependent upon their
sponsor under the Kafala Sponsorship system to maintain their status as foreign workers in
their own country.123
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