196 SOCIO-LEGAL REVIEW VOL. 17 for citizenship, it seems to echo the logic of ethnic belongingness and descent like recent amendments to citizenship laws.290 The positive takeaway that emerges from these rulings is that courts have taken cognisance of statelessness in India, and have tried to nudge the government to proactively consider granting citizenship for such persons.291 Further, invoking Article 21 in regard to stateless persons’ rights can be a route towards reading in better rights for such groups. In the interim period, courts can crack down on executive actions that prolong statelessness, and cast a positive obligation on the government to reduce statelessness by granting citizenship. However, the downside to the judgments discussed above is that they have made little headway in meaningfully lifting stateless persons and CampRefugees from their plight, and guide them onto a path for acquiring citizenship since they continue to place the decision in the hands of executive discretion. In particular, the Madras HC invoked the idea that courts cannot step beyond the “lakshmanrekha”292 and grant citizenship since that was the domain of the government alone.293 Crucially, courts have also missed opportunities to deliberate on the impact of the determination of whether an applicant or their parents is an illegal migrant on alleviating or exacerbating statelessness. For this purpose, courts can build on Felix Kaye’s holding that individuals who are on the run for their lives or for similar genuine reasons cannot be expected to provide perfect documentation to apply for Indian citizenship. With this idea in mind, courts can help break down the documentation-heavy citizenship determination process that exists today. C. The future of Indian citizenship law for stateless persons It is evident that the abovementioned solutions provide only partial relief for Camp-Refugees specifically, and stateless persons in India generally. In light of this void, this paper proposes a number of general suggestions for the future of Indian citizenship law that the government must give serious consideration. The need for India to take cognisance of its stateless population, including Camp-Refugees cannot be overstated. In recent years, citizenship, or the lack of it, has increasingly become a political weapon.294 When this threat 290 291 292 293 294 As in Part III. Centre for Public Interest Law and others, ‘Excerpt: Legal Recognition of Status of Statelessness in India’ (Parichay, 18 November 2020) <https://parichayblog.org/2020/11/18/ excerpt-legal-recognition-of-status-of-statelessness-in-india/>accessed 28 July 2021. In modern Indian parlance, Lakshman Rekha is a bright-line rule or test. Ulaganathan (n 284). Sarker (n 125).