2020 Statelessness & Citizenship Review 2(2) maintained for different purposes (though with the possibility of cross-checks to prevent fraud). Thus a former French territory will have a code on civil status or a family code including comprehensive rules on all forms of civil registration, as well as rules on adoption, or establishing parentage in case of children born out of wedlock; and in some cases also regulating nationality. A former British territory is likely to have a births and deaths registration act, and separate laws on marriage, adoption and citizenship, and perhaps a separate child law also. 40 The detailed variations of civil registration laws, however, undermine this simple binary. 41 There are hybrid civil–common law countries (where the colonising power changed); while Islamic and (formerly) communist societies have their own important variants, as do states that have sought to formalise recognition of customary law, or those where civil registration is rather at the family or household level. The construction of civil registration systems both reflects and shapes deeply held social norms about the nature of the family, property rights, and belonging. The efforts of governments to establish or reform registration systems have therefore also created consternation among populations cleaving to different conceptions of the family, marriage and the rights of children; 42 these clashes have often been visible in the efforts of colonial officials to register ‘native’ populations. 43 Anxieties about attribution of status to abandoned children have been perennial; 44 as have those on the recognition of the fathers of children born out of wedlock. 45 The more recent development of civil registration frameworks reflects the profound influence of human rights law and norms of non-discrimination on concepts of the family. 46 Civil registration laws encode the social acceptance (or not) of same-sex partnerships and parenting, 47 or the right of indigenous peoples to self-identify. 48 40 41 42 43 44 45 46 47 48 In this article, nationality and citizenship are used interchangeably; nationality in relation to international law and, at national level, the term in relevant laws or usage in the document being referred to. Vernon Valentine Palmer, ‘Mixed Legal Systems’ in Mauro Bussani and Ugo Mattei (eds), The Cambridge Companion to Comparative Law (Cambridge University Press 2012) 368. Neil J Diamant, ‘Making Love “Legible” in China: Politics and Society during the Enforcement of Civil Marriage Registration, 1950–66’ (2001) 29(3) Politics & Society 447; Osamu Saito and Masahiro Sato, ‘Japan’s Civil Registration Systems before and after the Meiji Restoration’ in Breckenridge and Szreter (n 5) 113. Frederick Cooper, ‘Voting, Welfare and Registration: The Strange Fate of the État-Civil in French Africa, 1945–1960’ in Breckenridge and Szreter (n 5) 385. Nazan Maksudyan, ‘The Fight over Nobody’s Children: Religion, Nationality and Citizenship of Foundlings in the Late Ottoman Empire’ (2009) 41(Fall) New Perspectives on Turkey 151; Katherine O’Donovan, ‘Interpretations of Children’s Identity Rights’ in Deirdre Fottrell (ed), Revisiting Children’s Rights: 10 years of the UN Convention on the Rights of the Child (Kluwer Law International 2000) 73; Sari K Ishii, ‘Access to Citizenship for Abandoned Children: How Migrants’ Children Become “Stateless” in Japanese Orphanages’ (2020) 46 Journal of Ethnic and Migration Studies 1. Marie-Therese Meulders-Klein, ‘The Position of the Father in European Legislation’ (1990) 4(2) International Journal of Law, Policy and the Family 131. Fareda Banda and John Eekelaar, ‘International Conceptions of the Family’ (2017) 66(4) International and Comparative Law Quarterly 833. Carl Stychin, ‘Family Friendly? Rights, Responsibilities and Relationship Recognition’ in Alison Diduck and Katherine O’Donovan (eds), Feminist Perspectives on Family Law (Routledge 2006) 21. Committee on the Rights of the Child, General Comment No 11: Indigenous Children and Their Rights under the Convention, UN Doc CRC/C/GC/11 (12 February 2009); Richard Madden et al, ‘Indigenous Identification: Past, Present and a Possible Future’ (2019) 35(1) Statistical Journal of the IAOS 23. 256