INTERNATIONAL JOURNAL OF LATEST TECHNOLOGY IN ENGINEERING,  
MANAGEMENT & APPLIED SCIENCE (IJLTEMAS)  
ISSN 2278-2540 | DOI: 10.51583/IJLTEMAS | Volume XIV, Issue XII, December 2025  
Citizenship Rules: How Long, How Hard, And How Fair Are the  
Processes?  
Oghenehoro Eni  
Independent Researcher / Immigration and Entrepreneurship Policy Analyst LL.M., George Mason  
University  
DOI : https://doi.org/10.51583/IJLTEMAS.2025.1412000115  
Received: 31 December 2025; Accepted: 07 January 2026; Published: 12 January 2026  
ABSTRACT  
Citizenship is more than just a legal status; it is a gateway to political participation, social inclusion, and long-  
term security. However, globally, states regulate access to citizenship through rules that determine how long  
applicants must reside, how challenging the process is, and how decisions are made to conform with standards.  
Therefore, this review paper examines citizenship acquisition rules while also comparing liberal (free)  
democracies, including Canada, the United States, the United Kingdom, and selected European Union states.  
Most importantly, it asks three major questions: how long does citizenship take, how hard is it to obtain, and  
how fair are the processes in practice? Hence, drawing on legal theory, policy reports, and justice, the paper  
argues that while states have legal rights in regulating membership, prolong, complex, or unnecessary processes  
risk undermine fairness, equality, and the rule of law.  
Keywords: Citizenship, naturalization, immigration law, fairness, residence requirements, comparative law  
INTRODUCTION  
Citizenship rules matter a lot because they determine who fully is a member in a political community and on  
what terms. For individuals, citizenship provides long-term security, voting rights, access to public institutions,  
and protection from removal. However, for governments, it is an expression of sovereignty and national identity.  
This is because citizenship affects both personal lives and public institutions. Therefore, the rules governing how  
it is acquired requires a careful legal and policy cross-examination (Shachar, 2009).  
Citizenship processes have significantly changed over the past twenty years. Residence requirements is lengthy,  
language and knowledge tests have been formalized, and administrative inspection has intensified. At the same  
time, applicants often face delayed processing times, no right of appeal, and widespread management decision.  
These trends have raised concerns among lawyers, policymakers, and scholars about whether citizenship systems  
remain fair, accessible, and in consonant with the rule of law (Bauböck, 2010; Joppke, 2007).  
Conversely, this paper examines citizenship rules through three major practical questions that show the impacts  
faced by applicants and their legal advisers. Firstly, how long does citizenship take from meeting eligibility  
requirements to receiving a final decision? Long waiting periods and administrative delays can affect family  
unity, mobility, and economic stability. Secondly, how hard is it to obtain citizenship? Major requirements such  
as language proficiency, knowledge tests, fees, and “character” assessments may promote integration in theory,  
but in practice they can operate as setbacks for long-established residents. Thirdly, how fair are citizenship  
decision-making processes? Procedural fairness, transparency, and availability of solutions are essential where  
decisions have transformative consequences (Baker v Canada (Minister of Citizenship and Immigration), 1999).  
While the analysis adopts a comparative approach, Canada operates a central place in this review. Recent  
constitutional review, administrative law decisions, and legislative reforms, in relation to citizenship by descent,  
processing delays, and standards of judicial review have reshaped Canadian citizenship law and practice.  
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These developments have direct impacts for legal practitioners advising clients, challenging refusals, or seeking  
solutions for unrealistic delay. Also, they place Canada within a broad international trend in which courts inspect  
citizenship rules for compliance with equality and procedural justice principles (Howard, 2009).  
Furthermore, this paper positions citizenship law within ongoing policy debates and the everyday realities of  
legal practice. It balances legal interpretation with policy discussion, thereby drawing on case law, statutes, and  
comparative studies to assess whether the current citizenship regimes have a balance between state interests and  
individual rights. By doing so, this review paper aims to contribute to ongoing framework discussions and to  
invite further research and practice-based engagement on how citizenship processes can be made more efficient,  
inclusive, and fair for all.  
Conceptual Framework  
In law, citizenship is often defined as a formal relationship between an individual and a state. However, in  
traditional understanding, citizenship establishes a legal bond that grants a person certain rights such as the right  
to vote or to remain in the country and carry out corresponding duties, including obedience to the law and, in  
some cases, civic participation (Kelsen, 1945). In other words, citizenship is primarily a legal status, created and  
regulated by legislation.  
Conversely, present day scholars argue that citizenship should also be understood as a form of social and political  
membership. Following this method, citizenship shows a person’s genuine connection to a community built  
through residence, participation, family life, and contribution, rather than merely formal compliance with legal  
criteria (Bauböck, 2015). However, this understanding has influenced how courts and policymakers think about  
fairness, inclusion, and equality in citizenship law.  
Generally, at the global level, citizenship is acquired through three main pathways. First, is citizenship based on  
birth within a state’s territory (jus soli). The second is citizenship transmitted through parentage (jus sanguinis).  
The third pathway, and the major focus of this review paper, is naturalization. Naturalization allows non-citizens  
to become citizens after meeting statutory requirements set by the state, such as a minimum period of lawful  
residence, language proficiency, knowledge of civic institutions, and a demonstration of good character (Howard,  
2009).  
Although naturalization requirements are framed in neutral and objective terms, their application often raises  
concerns about belonging and exclusion. Residence rules may be disadvantageous to people with uncertain legal  
status or interrupted migration histories. However, language and knowledge tests may affect older migrants,  
refugees, or individuals with lack of formal education distinctively. Hence, “good character” assessments, which  
often involve a lot of administrative preference, can lead to unpredictable results (Joppke, 2007). As a result,  
citizenship law does not only regulate access to status; it also shapes who deserves full membership in the  
political community.  
Furthermore, understanding citizenship as both a legal status and a form of social membership provides a  
framework for evaluating modern immigration systems. It also highlights the pressure between state control over  
borders and the principles of fairness, equality, and inclusion that supports democratic societies. This conceptual  
framework informs the analysis that follows in assessing whether current citizenship processes are balanced,  
transparent, and in agreement with laid down goals of integration and social cohesion.  
How Long Does Citizenship Take?  
One of the most common questions asked by prospective citizens is how long the process will take. In reality,  
the answer is shaped by two separate but connected factors. First, how long an applicant must live in a country  
before becoming eligible, and second, how long government authorities take to process the application once it  
is submitted. However, these factors determine whether citizenship is a standard protocol or an long term  
uncertainty.  
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Residence requirements  
Residence requirements are a central feature of naturalization systems in most self-governing nations. They  
ensure that applicants have developed a sufficient connection to the country before being granted citizenship.  
For instance, in Canada, the Citizenship Act requires permanent residents to be physically present in the country  
for at least three years within a five-year period before applying for citizenship (Citizenship Act, RSC 1985, c  
C-29). This approach shows a moderate residence procedure when compared to other regions.  
However, the United States imposes a long waiting period. Most applicants must hold legal permanent resident  
status for five years before applying for naturalization, although this period is reduced to three years for spouses  
of United States citizens (Immigration and Nationality Act § 316). In contrast, most european countries adopt  
various residence requirements. For example, Germany requires eight years, although this period may be  
shortened for applicants with strong language skills or successful integration. France, on the other hand requires  
five years of residence respectively (Howard, 2009).  
Furthermore, governments often justify longer residence requirements, stressing that they allow time for social  
integration, cultural adaptation, and civic attachment. However, research suggests that many immigrants  
integrate socially and economically well before they become eligible for citizenship. Studies by the Organisation  
for Economic Co-operation and Development demonstrate that employment participation, language acquisition,  
and community involvement often become stable within the first few years of residence (OECD, 2011). From  
this point of view, extended residence requirements may delay formal recognition of belonging rather than  
promote integration itself.  
Processing Times  
Even after an applicant meets the residence requirement, citizenship is not often granted quickly. However,  
administrative processing times play a significant role in determining how long the overall process takes. For  
instance, applications will undergo background checks, security screening, verification of residence history,  
among others, which can contribute to delays. During periods of high application demands or administrative  
deficiency, backlogs can add months or even years to processing timelines.  
Additionally, Canadian courts have acknowledged that too much delays in immigration and citizenship matters  
is capable of raising fairness concerns. For instance, in Baker v Canada (Minister of Citizenship and  
Immigration), the Supreme Court of Canada stressed that administrative decision-making must comply with  
principles of procedural fairness, especially where decisions have serious consequences for individuals (Baker,  
1999). Although Baker did not directly involve citizenship processing delays, its principles have informed  
subsequent judicial review of delayed administrative inaction.  
Furthermore, from my point of view, delayed processing times often create uncertainty with practical  
consequences, including limitations on the freedom of movement, employment opportunities, and political  
participation. For legal practitioners, delays raise questions about accountability and available solutions, such as  
appeal and writ of mandate (mandamus). As a result of this, the duration of time citizenship takes is not just an  
administrative issue but a legal and policy concern in relation to fairness and the rule of law.  
How Difficult Is It to Obtain Citizenship?  
Beyond waiting periods and processing delays, citizenship can be difficult to obtain because of the substantial  
and unnecessary requirements applicants must meet. These requirements are often used as tools for promoting  
integration and civic responsibility. Also, they can significantly create barriers for certain groups of persons, and  
introduce uncertainty into the decision-making process. However, some of these challenges include language  
and knowledge testing, as well as the assessment of “good character.”  
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Language and knowledge tests  
Language proficiency and civic knowledge tests are some of the conditions for obtaining citizenship in a  
constitutional government. However, governments often justify these requirements for the fact that a shared  
language and basic understanding of national institutions support communal bond and democratic participation.  
From this view point, testing is framed as a requisite for those seeking to obtain permanent residence.  
In Canada, applicants between certain age bracket must demonstrate an adequate knowledge of English or French  
and also pass a written citizenship test covering Canadian history, values, institutions, and symbols. However,  
standard testing procedures also exist in the United Kingdom and Australia respectively despite appearing  
neutral and modest.  
However, some persons claim that language and knowledge tests often act as barriers rather than integration  
tools. Research shows that such tests is disadvantageous to older migrants, refugees, and individuals with lack  
of formal education, even when they are socially and economically integrated (Joppke, 2007). In some cases,  
the tests emphasize memorization of historical facts or symbolic knowledge rather than practical civic  
engagement or everyday participation in community life.  
These concerns raise important questions about proportionality. If the goal of citizenship testing is to promote  
integration, then requirements that screen out long-term residents who work, raise families, and contribute to  
their communities may undermine that objective. As a result, the difficulty of citizenship is shaped not only by  
what is tested, but by how success and failure are defined.  
Good Character and Administrative Discretion  
Another major source of difficulty in obtaining citizenship is the requirement that applicants demonstrate “good  
character”. This requirement exists in most citizenship policies and is aimed at ensuring that new citizens respect  
the law and shared societal norms. However, unlike residence or language requirements, good-character  
assessments are often not clearly stated and entirely optional.  
In Canada and comparable regions, factors such as criminal records, tax compliance, or past immigration  
violations may affect an applicant’s eligibility. While serious criminal conduct may reasonably justify refusal,  
problems arise when minor violations, and inconsistently applied standards lead to negative decisions. Also, the  
lack of clear statutory guidance gives decision-makers significant freedom, which can result in uneven results  
across similar cases.  
Scholars have long warned that broad administrative discretion in citizenship decisions risks weaken legal  
certainty and equality before the law. Moreso, Dauvergne (2008) argues that subjective evaluations of moral  
worth can reflect discretionary judgments rather than consistent legal principles, thereby making outcomes  
difficult to predict or challenge. Therefore, for applicants, this uncertainty can be troubling given the high risks  
involved. On the other hand, for practitioners, it complicates legal advice and increases reliance on judicial  
review as a corrective measure.  
Furthermore, language testing and good-character requirements demonstrate that the difficulty of obtaining  
citizenship is not just a function of formal eligibility criteria. It is also shaped by how rules are interpreted,  
enforced, and justified. Therefore, assessing how hard citizenship is to obtain requires close attention to both  
legal standards and administrative practice.  
How Fair Are Citizenship Processes?  
Fairness is central to any legitimate citizenship system. Because citizenship decisions affect an individual’s  
security, identity, and participation in public life, the processes by which those decisions are made must meet  
high standards of procedural justice and equality. Even where eligibility rules are clearly set out in legislation,  
unfair administration can threaten confidence in the system and produce unfair results.  
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Procedural Fairness  
Procedural fairness requires that decision-making processes be transparent, timely, and responsive to the affected  
parties. In Canadian administrative law, the duty of procedural fairness applies whenever a decision has serious  
consequences for an individual. Citizenship decisions however meet this threshold, as they determine whether a  
person gains permanent security of status and full membership in Canadian society (Baker v Canada (Minister  
of Citizenship and Immigration), 1999).  
At least, procedural fairness in citizenship matters requires that applicants understand the criteria being applied,  
receive reasons for unfavourable decisions, and have a meaningful opportunity to respond to concerns raised by  
decision-makers. However, delays, unexplained refusals, or reliance on undisclosed information can undermine  
these principles.  
Despite these requirements, citizenship applicants often face limited avenues for review. In Canada and many  
comparable nations, refusals are generally challenged through judicial review rather than appeal on the merits.  
Judicial review focuses on legality, reasonableness, and procedural fairness, rather than whether the decision  
was “correct” in a substantive sense.  
While this model respects administrative autonomy, it can also limit effective oversight, especially where  
standards such as “good character” are applied inconsistently. As a result, accountability depends mostly on the  
quality of reasons and the willingness of courts to investigate administrative reasoning.  
Equality and Non-Discrimination  
Even where procedures are formally fair, citizenship systems may still produce different results. Citizenship  
rules are often framed in neutral terms, but their effects may cause burden to certain groups. High application  
fees, strict documentation requirements, language standards, and digital-only processes can exclude low-income  
applicants, refugees, persons with disabilities, and racialized communities (Shachar, 2009).  
From an equality stand point, citizenship should not function as a reward reserved for those with economic  
advantage or formal education. Instead, it should demonstrate genuine connection and participation in the  
community. When otherwise long-term residents are excluded because of structural barriers rather than lack of  
commitment, the legitimacy of citizenship rules is called into question. These concerns are acute in constitutional  
democracies committed to substantive equality and inclusion.  
Recent Canadian Cases and Policy Developments  
Recent Canadian jurisprudence and legislative reform demonstrate how fairness concerns are reshaping  
citizenship law as follows:  
Pepa v Canada (Citizenship and Immigration), 2025 SCC 21  
In Pepa v Canada (Citizenship and Immigration), the Supreme Court of Canada provided important clarification  
on judicial review and remedies in citizenship-related decisions. While affirming Parliament’s authority over  
citizenship, the Court emphasized that decisions under the Citizenship Act remain subject to the rule of law and  
meaningful judicial review. Also, the Court recognized that citizenship determinations engage individual  
interests, including security of status and political membership, and therefore require careful administrative  
reasoning (Pepa, 2025).  
Conversely, the Court confirmed that the presumptive standard of review is reasonableness, but stressed that  
reasonableness must be applied thoroughly. Therefore, decision-makers must provide a rational and connective  
chain of analysis linking the evidence to statutory criteria, especially where credibility, compliance, or character  
assessments are central. The Court also warned that template reasoning threatens procedural fairness and public  
confidence (Pepa, para 68).  
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With regards to remedies, Pepa is significant. The Court acknowledged that prolonged administrative delay can  
amount to a constructive refusal and confirmed that “mandamus” remains an appropriate remedy where statutory  
duties are unnecessarily delayed. At the same time, the Court emphasized proportionality, encouraging  
reviewing courts to provide solutions that both respect institutional roles and ensure applicants are not left  
without meaningful relief (Pepa, paras 91–97).  
Citizenship by Descent and the “Second-Generation Cut-Off”  
Fairness concerns have also driven constitutional challenges to citizenship by descent rules. In Bjorkquist v  
Canada (Attorney General), 2023 ONSC 7152, the Ontario Superior Court held that the first-generation limit on  
citizenship by descent violated section 15 of the Canadian Charter of Rights and Freedoms. The Court found  
that the difference between Canadians born abroad and those born in Canada is disadvantageous and failed to  
show modern family and mobility patterns.  
Furthermore, the Court rejected arguments based on administrative convenience or fears of disenfranchisement,  
emphasizing substantial equality and lived experience. Although the declaration of invalidity was suspended to  
allow Parliament to respond, the decision enhance the judiciary’s role in ensuring that citizenship rules align  
with constitutional equality principles.  
Legislative Response: Bill C-3  
Parliament responded to sustained litigation and constitutional pressure through Bill C-3, An Act to amend the  
Citizenship Act, which came into force in December 2025. The legislation extended access to citizenship for  
individuals who were previously excluded by the first-generation limit and provided mechanisms for logical  
recognition of citizenship. The amendments reflect the acknowledgment that earlier rules operated harshly and  
inconsistently with Charter values.  
However, for practitioners, Bill C-3 introduces new considerations, including proof-of-citizenship applications,  
transitional cases, and the interpretation of any remaining connection-based criteria. While the framework  
address many inequities, their implementation is likely to generate further administrative law disputes  
concerning eligibility determinations and processing delays.  
Administrative Delay and Accountability  
Federal Court jurisprudence continues to recognize unreasonable delay in citizenship processing as a legitimate  
issue. Courts have reiterated that while not every delay warrants intervention, prolonged inactivity, especially  
where applicants have met all statutory requirements may justify mandamus. Most importantly, courts have  
clarify that generalized backlogs or resource limitations do not automatically excuse extended delays.  
Meanwhile, at the administrative level, Immigration, Refugees and Citizenship Canada (IRCC) has introduced  
updated processing-time tools and backlog reduction strategies. While these initiatives improve transparency,  
judicial decisions suggest that transparency alone does not cure unfairness where individual applications stagnate.  
Together, these developments signal growing judicial expectations that citizenship administration be efficient,  
accountable, and fair.  
Comparative Insights and Emerging Trends  
Notably, a comparative examination of systems of government in a democratic government highlights several  
trends and emerging discussions. One major development is the rise of “earned citizenship.” Under this model,  
applicants are expected to demonstrate not only residence but also active engagement within the society,  
economic contribution, language proficiency, knowledge of civic institutions, and moral or “good character”  
standards (Bauböck, 2010). Politically, this approach is often framed as promoting integration and rewarding  
commitment to the host society.  
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However, there are several risks associated with earned citizenship. By linking membership to performance or  
perceived merit, states risk transforming citizenship from a fundamental legal status into a conditional privilege.  
This shift can heighten inequalities and disadvantage individuals who, despite long-term residence or social  
integration, may not meet certain criteria (Shachar, 2009). Experts argue that stressing on merit-based measures  
threatens the principle that citizenship should show genuine membership and belonging, rather than a  
transactional reward.  
At the same time, comparative trends indicate that some jurisdictions are actively pursuing reforms to make  
citizenship processes fairer and more accessible. Examples include reducing application fees, simplifying  
documentation requirements, introducing flexible or alternative pathways to demonstrate language and civic  
knowledge, and recognizing various forms of integration, such as community engagement or economic  
participation (Howard, 2009; OECD, 2011). These frameworks suggest that it is possible to uphold state  
sovereignty and security while strengthening inclusiveness and procedural fairness.  
In Canada, these global movement cut across domestic reforms such as Bill C-3, which facilitate the access for  
second-generation applicants and recognized historical inequities in the application of citizenship laws. Similarly,  
judicial inquiry in cases like Pepa v Canada has reinforced the expectation that administrative processes must  
be transparent, reasonable, and fair. Together, these developments shows a movement toward balancing legal  
standards, policy objectives, and human rights considerations in the design and implementation of Immigration  
and integration policies  
In short, comparative analysis stress that citizenship is no longer merely a static legal status; it is increasingly  
shaped by policy choices, administrative practices, and societal expectations. Furthermore, emerging trends  
illustrates the potential for governments to design systems that reward integration without undermining  
fundamental rights, and to reconcile state interests with the principles of fairness, equality, and inclusivity.  
RECOMMENDATIONS  
Based on the analysis of citizenship processes and comparative trends, several reforms could improve fairness,  
accessibility, and legitimacy. While recognizing the state’s interest in regulating citizenship, reforms should  
prioritize clarity, inclusiveness, and procedural justice to ensure that citizenship truly reflects membership rather  
than conditional privilege.  
Match residency requirements to realistic integration timelines  
Current residence requirements in many jurisdictions, including Canada, often exceed the time necessary for  
applicants to show meaningful social, economic, and cultural integration. Policymakers should consider  
adjusting residence entry to reflect empirical evidence about how quickly newcomers integrate into society.  
However, more flexible residence periods could reduce unnecessary delays, enable timely recognition of  
belonging, and reduce the social and economic costs associated with prolonged waiting periods.  
Design Substantive Requirements to Support Inclusion  
Language proficiency, civic knowledge tests, and other substantive criteria should serve as tools for integration  
rather than as barriers to membership. Therefore, governments should ensure that these assessments are  
accessible, relevant, and culturally sensitive. Additionally, measures taken could include providing several  
pathways to demonstrate competence, offering exemptions or accommodations for older migrants, refugees, or  
those with lack of formal education, and emphasizing practical civic understanding over learning by heart. Such  
approaches would help ensure that deserving applicants are not excluded by arbitrary or strict standards.  
Strengthen Procedural Safeguards and Accountability  
Procedural fairness is essential to maintaining public confidence in citizenship systems. Decision-makers should  
provide clear, detailed reasons for refusals, especially when caution is exercised in areas such as good character  
assessments. However, broader appeal rights or simplified judicial review mechanisms could enhance  
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accountability and provide applicants with meaningful recourse where errors or delays occur. In addition,  
administrative transparency, such as updated processing-time reporting and timely communication with  
applicants, should be reinforced to reduce uncertainty and improve trust in the system.  
Incorporate Lessons from Comparative and Domestic Developments  
Reforms should also reflect emerging lessons from both Canadian experience and international practice. Recent  
judicial guidance, such as Pepa v Canada, demonstrates the importance of rigorous reasoning,corresponding  
solutions, and protection against unnecessary delay. Legislative changes like Bill C-3 demonstrate the value of  
addressing historical injustice and adapting rules to the realities of modern, transnational families. Drawing on  
these lessons, policymakers can design citizenship processes that balance state interests with fairness, equality,  
and inclusiveness.  
In summary, reforming citizenship law and practice requires a multi-dimensional approach. By adjusting  
residence requirements, making substantive criteria inclusive, and strengthening procedural fairness,  
governments can ensure that citizenship is not only a legal status but also a meaningful recognition of belonging  
and contribution. With this, such reforms will enhance the legitimacy of the system, strengthen social cohesion,  
and respect the fundamental rights of applicants.  
CONCLUSION  
Citizenship law is not merely an abstract set of rules; it has consequences for individuals, families, and society.  
This review has highlighted that while Canada’s citizenship framework has evolved to address fairness and  
inclusion through judicial investigation in cases such as Pepa v Canada and legislative reforms like Bill C-3,  
significant challenges remain. Delays in processing, uneven application of optional standards, and socio-  
economic barriers continue to affect applicants’ access to citizenship and raise questions about equality,  
transparency, and the rule of law.  
Going further, the analysis is a testament of the need for sustained attention from lawyers, policymakers, and  
scholars. Also, practitioners play an important role in identifying and challenging procedural irregularities,  
advising clients on emerging rules such as proof-of-citizenship mechanisms, and managing optional assessments  
like the “substantial connection” test. Therefore, policymakers must continue to refine residence, language, and  
knowledge requirements to ensure they reflect real integration timelines and do not inadvertently exclude  
deserving applicants. Hence, scholars and researchers can provide major insights into the lived experiences of  
applicants, the impacts of administrative delays, and the effectiveness of reforms.  
In conclusion, this paper calls for a collaborative and proactive approach to citizenship law. Monitoring  
implementation, advocating for clearer procedural fairness, and evaluating real-world experience are essential  
steps toward a system that is both efficient and fair. Also, Contributions to organizations that offer empirical  
data, comparative perspectives, or actionable guidance for practitioners are valuable. By combining conceptual  
analysis with practical insight, the legal community can help ensure that Canadian citizenship remains a  
meaningful and accessible marker of belonging for all eligible residents.  
REFERENCES  
1. Bauböck, R. (2010). Studying citizenship constellations. Journal of Ethnic and Migration Studies, 36(5),  
847–859.  
2. Bauböck, R. (2015). Morphing the demos into the right shape: Normative principles for enfranchising  
resident migrants. European Journal of Political Theory,  
14(1), 48–69.  
3. Baker v Canada (Minister of Citizenship and Immigration), [1999] 2 SCR 817.  
4. Bjorkquist v Canada (Attorney General), 2023 ONSC 7152.  
5. Canadian Charter of Rights and Freedoms, Part I of the Constitution Act, 1982.  
6. Citizenship Act, RSC 1985, c C-29.  
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7. Dauvergne, C. (2008). Making people illegal: What globalization means for migration and law.  
Cambridge University Press.  
8. Howard, M. M. (2009). The politics of citizenship in Europe. Cambridge University Press.  
9. Immigration and Nationality Act, 8 USC § 316.  
10. Joppke, C. (2007). Transformation of citizenship: Status, rights, identity. Citizenship Studies, 11(1), 37–  
48.  
11. Kelsen, H. (1945). General theory of law and state. Harvard University Press.  
12. OECD. (2011). Naturalisation: A passport for the better integration of immigrants? OECD Publishing.  
13. Pepa v Canada (Citizenship and Immigration), 2025 SCC 21.  
14. Shachar, A. (2009). The birthright lottery: Citizenship and global inequality. Harvard University Press.  
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