Eliyeh Delavari and international human rights organisations and activists, a substantial reform to the law was approved. The amendment which allows children born to Iranian women and foreign men to acquire nationality regardless of whether they are born inside the country or abroad 9 . Nonetheless, certain gaps are still remaining and more reforms are needed to ensure that Iranian nationality law is in line with international human rights standards. The following sections of this report take a close look at the historical process of regulating citizenship in Iran and also focuses on the current modes of acquisition and loss of Iranian nationality along with the issue of gender discrimination. Moreover, a number of reform options in accordance with international norms, in particular with regard to the elimination of gender inequality in law, are discussed. 2. An Historical Overview of Citizenship Regulations in Iran 2.1. Some Terminological Remarks: Nationality vs Citizenship In Farsi, the term tabeiat [‫ ]ﺗﺎﺑﻌﯿﺖ‬is the corresponding term to nationality which literally means allegiance. However, in legal literature the term is used to describe the political relationship between an individual and the State which results in both rights and obligations 10 . Some scholars, nevertheless, have suggested a more comprehensive definition of the term11. They claim that the term tabeiat indicates a political and intellectual relationship between an individual and a State. Their argumentation is that nationality is not something that is dependent on one’s habitual residence but it is rather an intellectual relationship that one is always preserving with their country of nationality regardless of where they live12. This is while others believe that the relationship is purely a legal one and should be defined as the legal belonging of an individual to a nation or State13. Meliat [‫ ]ﻣﻠﯿﺖ‬is another term with a similar meaning for the term nationality in Farsi which is slightly different than the term tabeiat. In Iranian legal literature, the former has more of a sociological value while the latter possesses a legal and political value. In other words, the term meliat mostly implies an individual’s membership of a nation or State in a sociological context. However, the term tabeiat indicates the existence of a political and legal bond between an individual and a State14. 9 Guardian Council Ratifies Bill Granting Citizenship to Children of Iranian Mothers, Foreign Fathers, Islamic Republic News Agency, 2019, available at: https://en.irna.ir/news/83500806/Guardian-Council-ratifies-bill-granting-citizenship-to-children. 10 ١٣۵‫ ص‬,١٣٨١ ,‫ ﮔﻧﺞ داﻧش‬:‫ ﺗﮭران‬,‫ ﺗرﻣﯾﻧوﻟوژی ﺣﻘوق‬, ,‫ﻣﺣﻣد ﺟﻌﻔر ﺟﻌﻔری ﻟﻧﮕرودی‬. (Mohamad-Jafar Jafari Langroudi, the Legal Terminology, Tehran: Ganje Danesh, 2002, page 135). 11 ٣۶‫ ص‬,١٣٩٠,‫اﮔﮫ‬: ‫ ﺗﮭران‬,‫ ﺣﻘوق ﺑﯾن اﻟﻣﻠل ﺧﺻوﺻﯽ‬, ‫ﻧﺻﯾری ﻣﺣﻣد‬. ( Mohammad Nasiri, Private International Law, Tehran: Agah, 2011, page 36). 12 ٢٧‫ـ‬٢۶‫ ص‬,١٣٩٠,‫اﮔﮫ‬: ‫ ﺗﮭران‬,‫ ﺣﻘوق ﺑﯾن اﻟﻣﻠل ﺧﺻوﺻﯽ‬, ‫ﻧﺻﯾری ﻣﺣﻣد‬. ( Mohammad Nasiri, Private International Law, Tehran: Agah, 2011, pages 26-27). 13 ١٣٧‫ ص‬,١٣٩٠,‫ ﻣﯾزان‬: ‫ ﺗﮭران‬,‫ ﺣﻘوق ﺑﯾن اﻟﻣﻠل ﺧﺻوﺻﯽ‬,‫ﺳﻠﺟوﻗﯽ ﻣﺣﻣود‬. ( Mahmoud Saljoughi, Private International Law, Tehran: Mizan, 2011, page 137). 14 ١٣٢‫ ص‬,١٣٩٠,‫اﮔﮫ‬: ‫ ﺗﮭران‬,‫ ﺣﻘوق ﺑﯾن اﻟﻣﻠل ﺧﺻوﺻﯽ‬,‫ﻧﺻﯾری ﻣﺣﻣد‬. ( Mohammad Nasiri, Private International Law, Tehran: Agah, 2011, page 132). 2 RSCAS/GLOBALCIT-CR 2020/13- © 2020 Author(s)

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