The largest group and the one that particularly benefited from the Mskhiladze judgment were people in precarious legal situations who arrived in Russia due to the recent conflict in Eastern Ukraine (Kuznetsova, 2017). They formed a new de facto stateless group within the post-Soviet space that testified to the legal productivity of the Mskhiladze judgement. Given the deeply rooted conservatism of the Russian judges (Hendley, 2007, 2012), and legal formalism in interpreting the law (Kurkchiyan, 2009), these cases really pushed the conformist Russian judges to the frontiers of their creativity. A word of context is required. Many civilians fled Donetsk and Luhansk areas toward the Central and Western Ukraine when the military conflict in Eastern Ukraine started. The UNHCR estimates that, as of 2019, the protracted conflict produced around 1.5m internally displaced persons in Ukraine (UNHCR, n.d.). Around 1m Ukrainian citizens from the conflict affected areas decided, however, to flee to Russia (Mukomel, 2017: 10). Russian authorities adopted legislation significantly simplifying the rules for granting temporary asylum for Ukrainian citizens (Roudik & Yatsunska, 2016); more than 300,000 Ukrainians received temporary asylum in Russia, and later citizenship (Polovinko, 2019). Others regularised their situation via the migrant worker route by securing a work licence or a work permit. However those who did not manage – due to a variety of reasons, including bureaucratic problems with the implementation of the law ‘on the ground’ – to regularise their status in Russia were treated by the immigration authorities as ‘ordinary immigration offenders’ (Kubal, 2016). The FMS, and its successor, GUVM MVD, prioritised their removal over recognizing their claims to international humanitarian protection. These Ukrainian citizens were placed in detention centres and awaited deportation that turned out, however, impossible to enforce due to the conflict in Eastern Ukraine. Furthermore, when the passports of many of the detainees expired, the central Ukrainian authorities refused to issue them certificates of citizenship given the ‘impossibility to confirm this fact with the local authorities in Luhansk and Donetsk 17