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A REVIEW OF CITIZENSHIP LITERATURE

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Lawrence Okechukwu Emeagwali

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 Multiple Citizenship 1

Should Dual or Multiple Citizenship be Possible or not?

Introduction
For the past few years, the number of individuals holding dual or multiple nationalities

have been on the increase, and the legislatures of more and more nations are increasingly

tolerating or supporting this phenomenon. In their 2008 work titled ‘Dual Citizenship in an age

of Mobility’, Faist and Gerdes, state that this trend is surprising due to the fact that not too long

ago within the 19th and 20th centuries, nations had unanimously opposed the notion of dual or

multiple citizenship on the basis of several well founded fears. The reasons for the sudden

change of heart is not clear at the moment, but the question this research piece intends to find

answers to by means of this presentation is, if persons should or should not be allowed to hold

dual or multiple citizenship of at any one time in their lives. The following sections intend to

find answers to the questions by systematically looking at the concept of citizenship, dual

citizenship, the international perspective on both as well as the perceived benefits and

problems of dual or multiple citizenship and from these and backed by literature provide

answers to the research question.

The Concept of Citizenship

 Multiple Citizenship 2

While the terms nationality and citizenship are often used interchangeably, they actually

differ in meaning. To better understand the concept of citizenship and thus dual or multiple

citizenship, it is very important to contrast nationality against citizenship.

According to Renshon, citizenship is a term used to refer to the rights and

responsibilities people acquire, due to their having been born as or having become accepted,

recognized or certified as members of a community or state (7). He went further to define

nationality as a “psychological” terminology which refers to that intrinsic emotional connection,

tie and central understandings about the community, the world and the common experiences

which effectively bonds members of a group or community together (Renshon, 7).

Elsewhere, Faist stated that the function of nationality is two fold viz: interstate function

and intrastate function. The interstate function of nationality is to provide a clear definition of a

group or community of people based on a clearly delineated territory in order to distinguish

and also protect its citizens against outside and sometimes unfriendly communities or nations;

while the intrastate function also known as the domestic function of nationality is to define the

rights and duties of members of the community (Faist, 7,8).

On citizenship, Faist noted that it is a concept used to confer the legal status of equal

individual liberty among members of the community or nation with the recipient demonstrating

some affinity to a political community with a well differentiated collective identity to ensure

that the trust and solidarity which are entitlements of members of a community are propagated

(Faist, 8).
 Multiple Citizenship 3

To buttress Faist’s point in the preceding paragraphs, Renshon who earlier on defined

nationality as the emotional ties between members or citizens of a community or state; noted

in his writing that nationality in most cases is the foundation of citizenship, and in his own

words “citizenship without emotional attachment, is the civic equivalent of a one-night stand”

(Renshon, 7).

Dual Citizenship and why it occurs

According to Ludvig, every person who legally holds two or more nationalities, has dual

or multiple citizenship respectively (3). Also according to Faist and Gerdes, dual citizenship

refers to the situation whereby individuals hold and combine citizenship in and of two nations

(4). Ludvig went further to state that dual citizenship can be obtained through any of the

following six means: descent from one or both parents who are nationals (the principle of jus

sanguinis ); birth on the sovereign nation’s territory (the principle of jus soli); marriage,

adoption or legitimization; naturalization or territorial transfer from one nation to another (5).

To buttress the preceding point from an American perspective, Renshon illustrated that

an American can acquire dual or multiple citizenship in any of the following ways: If he/she is

born to immigrant parents resident in the USA at the time of his/her birth; since all children

born in the USA, automatically become US citizens irrespective of their parent’s immigration

status at the time (jus soli). Secondly, if he/she is born outside the USA to one parent who is an

America citizen and another who is not (jus sanguinis), third, if he/she is resident and chooses

to naturalize in the USA; fourth, if he/she comes from a country which originally has dual

citizenship with third or fourth countries and which automatically makes him/her eligible for
 Multiple Citizenship 4

dual citizenship in the USA. Fifth, being born to parents who each have dual citizenship, can

confer on him/her the citizenship entitlement to both his parent’s nationalities of origin and

his/her American one as well granting him multiple citizenship status (Renshon, 6).

International Perception of Dual or Multiple Citizenship

Faist and Gerdes noted in their work that there was an international consensus among

nations some decades ago in which nations unanimously agreed that dual citizenship should be

avoided at any possible cost. They stated that this decision was evidenced by the citizenship

laws of individual states as well as in bilateral and multilateral agreements and international

conventions at the time (5).

They quoted as an example, a very brief statement which was the preamble to the

Hague convention on citizenship attributed to the League of Nations in 1930 stating that All

persons are entitled to possess one nationality, but one nationality only. This statement the

authors claim, was a mirror reflection of the dominant international opinion and perspective on

citizenship all through the 19th and 20th century (Faist and Gerdes, 5). Elsewhere, Faist

buttressed this observation when he noted that bilateral treaties such as the treaties between

the USA and European countries around the middle of the 19 th century called the Bancroft

Treaties as well as interstate conventions such as the Hague Convention of 1930 and the

European Convention on the Reduction of Multiple Nationality (Council of Europe, 1963); all

lend credence to the dominant perspective at that time (Faist, 10).

 Multiple Citizenship 5

The dominance of this perspective did not arise out of the blue however, because, as

Faist and Gerdes continue, states and nations then saw a connection between dual citizenship

and espionage and viewed it as an aid to the occurrence of treasonable offences and other

negative activities (5). Thus from the middle of the 19 th century until way after the second world

war, the authors note that nations fashioned their citizenship laws based on one of the

following two policies: One, that to gain citizenship in a new country, one has to lose his original

citizenship in his home country. Two, individuals born in particular nations had to make a choice

between citizenship of his/her country of birth and that or those of his/her parents upon

attaining maturity age, otherwise, he/she would be expatriated (Faist and Gerde, 5).

Ludvig noted that such rules were very strict that an individual could be expatriated and

lose his original citizenship if there were any slightest evidence of the individual’s political or

social loyalty to another state (3). Faist and gerdes, noted that such show of loyalty could range

from entry into military service, assumption of political office in the other state or merely

participating in electoral activities in foreign nations (5).

Today, however, Faist notes that despite all the previous agreements, dual citizenship is

on the rise and has continued to be since the late 20th century as more and more people

migrate across state borders, and settle down, and as more immigrant populations leave home

with the intention of becoming citizens of foreign lands (10). The author further noted that the

increase in dual citizenship arose clearly from a number of factors. One, the fact that almost all

countries have jus sanguinis rules. While some have this exclusively, most other nations

supplemented their jus sanguinis rules with jus soli and other regulations. Thus he noted that
 Multiple Citizenship 6

dual citizenship always occurred as individuals were born in nations where jus soli was the

predominant law, while his/her parents had nationalities from countries where jus sanguinis

was predominant (Faist, 10). Other factors such as gender equality law reforms which

eliminated the clause which previously made a female’s citizenship dependent on that of her

husband. The European Convention on Nationality (Council of Europe, 97) made it even easier,

by stipulating that both parents can transfer their nationality to their children. Also recently,

more countries have made the acquisition of their nation’s citizenship and nationality status

less dependent on the relinguishing or giving up of the applicant’s original citizen status from

his/her originating country. Examples of nations which have done away with these restricitions

include France (1973), Portugal, (1981) and Italy (1992) among others (Faist,11).

Another contributing factor to the recent rise in dual and multiple citizenship

occurrences, have been attributed to the new relationship structure among nations (Faist, 7)

from an European perspective, the intra cooperation among nation states meant that the

threats of war and thus the need to protect and maintain a high conscriptable citizenry is no

longer necessary. Thus a lot of European countries have done away with the provisions of

compulsory military services. Where still present, the individual is allowed to perform military

service in his/her state of regular residence (Faist, 7). The end of the cold war, the decreasing

interstate wars between democracies, enhanced economic and political cooperation between

democratic nation states and the creation of the European union all have served to make more

and more nations less worried about the loyalty of their citizens, thus making it easier to

legislate in favor of dual or multiple citizenship (Faist, 8).

 Multiple Citizenship 7

To effectively arrive at a conclusion concerning whether it should or should not be

possible for a person to hold citizenship in more than one country at any one time; it is only

important to first of all take a comprehensive and objective look at the benefits and problems

of dual citizenship.

Benefits of Dual Citizenship

According to Faist and Gerdes, some benefits of dual citizenship includes high incidences

and frequencies of naturalization, the encouragement and improvement of participation among

the diverse populace, and the improvement of trans-national participation and thus tran-

national relations. These benefits are explained in details in the ensuing section.

Increased Naturalization Rates

The authors note that in many countries, not all immigrants who qualify for citizenship

acquisition actually make any effort to apply for it. They attribute this to a lot of factors, most

notably, the requirement of most nations that applicants provide proof of having renounced

their previous citizenship in their countries of origin (8). The authors cited the case of Turkish

immigrants in Netherland as contrasted against Turkish immigrants in Germany, between 1992

and 1997. In the former, this period was the period when dual citizenship was accepted without

any pre-conditions or exceptions and consequently saw a very sharp increase in the

naturalization rate of Turkish immigrants. On the other hand, due to the fact that Germany did

not accept dual citizenship; the naturalization rate of Turkish immigrants during the same

period was much more lower (Faist and Gerdes, 9).

 Multiple Citizenship 8

The authors found a similar comparison between the naturalization rates of immigrants

in the USA against immigrants in Canada. Where in the later, immigrants are more likely to

become naturalized than those in the USA due mainly to the fact that while Canada tolerates

and even promotes the need for dual citizenship; the USA’s naturalization process and legal

requirements, sends a message which implies that it does not tolerate dual citizenship even

though it is on record that the USA does not practically take action against individuals holding

other citizenship (Faist and Gerdes, 9) (Renshon, 10).

Encourages and Advances Overall Participation

Faist and gerde note that dual citizenship confers on immigrants exemptions from

applications for work permits, protects the immigrant from expulsion from the host country,

enables him/her to gain easy access to public employment, reduces bureaucratic and

administrative difficulties and from an EU perspective, also allows the free movement of the

individual around European member states without a visa (9). Although the above depends on

the applicable legal framework in the immigrant nation, these benefits attached to citizenship

will according to Faist and Gerdes “enhance the probability of socioeconomic integration” (9).

Enhances Esteem and Self-Respect

When immigrants are granted dual citizenship, they often regard the state’s acceptance

of dual citizenship as a form of recognition, respect for an legitimization of their multicultural

heritage and identities. The authors note that children who are dual citizenship holders easily

integrate if the stae welcomes or accepts dual citizenship. The authors cite the example in
 Multiple Citizenship 9

Germny, according to Schroter and Jager; where children of bi-national marriages who are dual

citizens from birth see their dual citizenship as important for their integration obviously due to

ability to develop specific capabilities and competencies related to their transnational

backgrounds such as bilingual skills as well as inter cultural mediation (Faisy and Gerdes, 10).

Enhances Trans-national Participation

Some immigrants are active globally. They engage in global transnational activities in

this age of ever increasing trans-national mobility of people, information, money, consumer

goods and services. Due to the high immigrant populations in most immigrant nations, it is now

possible for transnational connections through several networks, groups, and organizations.

Indeed dual citizenship benefits the immigrant entrepreneur who has to mobilize and interact

with contacts across borders (Faist and Gerdes, 10).

Problems of Dual Citizenship

Although dual citizenship has a lot of benefits to both the immigrant and the state,

many nations still base their opposition to the concept of dual or multiple citizenship based on

the following perceived disadvantages they found associated with dual or multiple citizenship:

dual voting implications, lack of proper integration and state loyalty and more importantly, they

believe that dual citizenship devalues national citizenship (Faist and Gerdes, 12)
 Multiple Citizenship 10

Dual Voting

One disadvantage opponents of dual citizenship always cite is the violation of the “one

person, one vote” principle. They claim that immigrants with dual citizenship, had the unfair

advantage of propagating their interests especially in the EU by casting their votes twice: one in

their originating country and the other in their country of residence (Faist and Gerdes, 12).

Whether this is truly the case would be dealt with in the sections to follow.

Lack of Integration

Faist and Gerdes reveal that patterns of failed integration due to low employment rates,

low educational levels, and high dependence on welfare by most immigrants is a very important

disadvantage often cited by opponents of dual citizenship. The authors also cite the rising

apprehension over Islamic extremism, which has given rise to high incidences of inhumane

practices such as forced, arranged marriages and honor killings (12). Post September 11 th and

other terrorist activities in select European countries have further strengthened the opposition

to dual citizenship in some quarters (Faist and Gerdes, 12).

Lack of Loyalty

Faist and Gerdes notes that there may exist certain individuals with immigrant status

who have been living as permanent residents in a foreign nation for many years, without ever

wanting to acquire the citizenship of that country. Others may want to acquire citizenship for

certain benefits but would not wish to renounce the citizenship of his/her originating country.

Since citizenship requires the holder to identify with common political values, to show a sense
 Multiple Citizenship 11

of responsibility and solidarity towards the common good, and towards fellow citizens

respectively. Within a particular country or nation-state, the dominant groups (usually natives)

of immigration countries cannot help but consider people who retain their previous citizenship

upon acquiring the host country’s citizenship as not being completely and honestly loyal to their

country of settlement (Faist and Gerdes 13)

The Devaluation of National Citizenship

One other disadvantage perceived by opponents of dual citizenship is the fear of the

erosion in value of national citizenship as a consequence of dual or multiple citizenship. To curb

this, most states have followed in the footsteps of the USA and Canada in the introduction of

naturalization tests and etc to ensure that core values of national citizenship exists in soon to

be citizens.

Faist and Gerde note that this fear is highly present among European nations who fear

that as the region shifts towards one of expanded European citizenship, the devaluation of

national citizenship sets in; as member states lower the requirements for acquiring citizenship,

open their arms to dual citizenship and institutionalize territorial birthright citizenship. The fear

is greater even as opponents view this developments a more or less inevitable (Faist and

Gerdes, 13)

Dual Citizens as Liability to the State

There exist a school of thought which believe that dual citizens especially those in the Diaspora,

constitute an unfair liability to the state as they in some particular countries such as Canada, do
 Multiple Citizenship 12

not reside at home, do not pay taxes or participate in the political process, and as such have

very little bond with Canada save the conveniences their Canadian citizenships afford them. A

practical example is the dual citizenship crisis in 2006 where it is recorded that the Canadian

government spent an enormous $100 million to evacuate its dual citizens from Lebanon, during

the Israeli-Hezbollah conflict. While critics agree that these citizens should be evacuated, they

argue that these non tax-paying, non-voting citizens did not deserve the amount of tax payers

fund spent on their evacuation. The question then is: is it fair for a government to help its dual

citizens resident abroad when they are in trouble? In November 2006, the former immigration

minister Monte Solberg was quoted as saying in response to the evacuation crisis that "If we're

in a situation where somebody's absent, isn't paying taxes but is going to be using our social

programs down the road, I think Canadians would feel that that is unfair,". His statement

reflected the feelings of many Canadians on the issue of dual citizenship.

In the light of the preceding advantages and disadvantages discussed above; should it

then be possible or not for a person to hold citizenship in more than one country at the same

time? The following sections would seek to provide answers.

Should Dual or Multiple Citizenship be Possible or not?

In order to find answers to this question, it is necessary to re-consider the fears

expressed in the disadvantages or problems of dual citizenship stated earlier on, as in there lies

the major factors opposing dual or multiple citizenship. First of all, taking the fear of dual

voting into consideration, we are reminded that opponents of dual or multiple citizenship claim

that it enables holders to propagate or have the undue advantage of being able to vote for their
 Multiple Citizenship 13

interests using two votes which dual citizenship legally grants them. Faist and gerdes notes that

people with more money and other resources and holding only one citizenship in some

countries, sometimes have and exert large influences on national elections more than other

citizens do. Although this is may not be obtainable in federal political systems, it is infact true

for others. Also the authors note that the benefit of having more residents participating

politically in a country where they reside far outweighs the disadvantage of dual voting if ever

that occurs as Faist and Gerdes reveal was the case in Switzerland where the “one person, one

vote” principle was seen to be violated with dual citizenship and that violation later ignored

due to the realizat ion of the above mentioned fact. (Faist and Gerdes, 12).

Secondly the disadvantage of lack of integration associated with dual or multiple

citizenships cannot be empirically substantiated. There are no proof or strong empirical

arguments which gives evidence that dual or multiple citizenship leads to or contributes

yochain reactions of non integration, exclusion and segregation among immigrant groups.

However, there are strong empirical findings and evidence to support the idea that dual or

multiple citizenship may lead to increase in political participation and socio-economic

opportunities.

Thirdly, Faist reveals that if we look closely at the disadvantage of lack of loyalty

associated with dual or multiple citizenship, we would find that sometimes it is only natural for

new citizens to want to maintain some ties to their countries of origin, as well as develop new

and strong emotional ties to their new country of residence. Instead of viewing the refusal to

renounce citizenship of the originating country as a negative thing, it could be seen as an

 Multiple Citizenship 14

advantage to be used in fostering closer ties and better relationships with the migrant or

immigrant originating country. The authors note that the fact remains that empirical findings

show evidence that dual or multiple citizenships are becoming inevitable. This implies that

countries should welcome this phenomenon.

Fourthly, regarding the issue of dual citizens in the Diaspora being a liability to the state, a re-

known Canadian researcher Jack Jedwab, director of the Montreal-based Association for

Canadian Studies, revealed that data obtained from an important landmark 2001 StatsCan

survey disagrees with the general perception that dual citizens have more divided loyalties or a

weak commitment to Canada. Jedwab revealed that the statistics indicated that foreign based

dual citizens were as committed to Canada in terms of loyalty as home based dual or single

citizens. In their research work titled’ Dual Citizenship and Canada’s New Diaspora’ DeVoretz

and Woo noted that the perceived problem of liability lies with the inadequacies of the dual

citizenship policies of the Canadian government and not the dual citizens themselves. They

reveal that these policies which as of then had not granted dual citizens in Diaspora the means

to exercise their electoral franchise as well as the absence of such US based system of

worldwide world income tax remitting systems. They noted that the availability of these

systems would reveal that Canadians with dual citizenship statuses resident abroad are not a

liability but just as committed as their domestic counterparts in both their loyalty to Canada as

well as their socio-economic contribution to the Canadian nation state.

In my opinion, based on the work of Faist and Gerdes, it should be possible for

individuals to hold dual or multiple citizenships at the same time as long as they have
 Multiple Citizenship 15

demonstrated ties to each of the countries in question; as depriving them of citizenship status

in any of the countries in which they have a tie either by birth, relation, marriage, or residence

would be unfair and unjust.

According to Faist and Gerdes, the arguments often made against dual or multiple

citizenships are weak because the fear of dual voting is often misinformed if at all migrants ever

consider voting in the different countries in which they hold citizenship. Also the rise in dual

citizenship has not led to any proven or noticeable increase in tensions and conflicts; and most

importantly the problems of conflicting laws, rights, tax duties, family, military service,

inheritance and even the ability to vote, can be resolved by enacting legislation similar to the

European union’s law of “state of habitual residence” which states that citizens are allowed to

vote or carry out military service in their state of habitual residence. Other bilateral or

multilateral treaties can also be enacted between nations to resolve these issues which are

obviously resolvable. Finally, Faist and Gerdes notes that when it comes to issues of loyalty of

dual citizens, it is far better to have them as citizens rather than non-citizens.

In conclusion, I believe that individuals should be allowed to hold multiple citizenship,

thus policy makers would do well to not only tolerate it, but also to support it because dual or

multiple citizenship leads to higher rates of naturalization, thus stimulating social and political

integration. It enhances democratic legitimacy and more importantly, dual or multiple

citizenship encourages integration and is cost effective, efficient and natural to recognize dual

or multiple citizenship as it reflects the multiple heritage of a whole community of people living

across borders.
 Multiple Citizenship 16

References

Faist, Thomas. “Dual Citizenship as Overlapping Membership” International Migrations and

Ethnic Relations, 2001. Print.

Faist, Thomas; Gerdes, Jurgen. “Dual Citizenship in an age of Mobility” Council on Migration.

The Migration Policy Institute, 2008. Print.

Faist, Thomas; Gerdes, Jurgen; Rieple, Beate. “Dual Citizenship as a Path Dependent Process”

Working papers, Center on Migration, Citizenship and Development, 2004. Print.

Ginieniewicz, Jorge. “Citizenship Learning and Political Participation” The Case of Latin

American-Canadians. London Review of Education, 2008. Print.

Ludvig, Alice. “Dealing with Dual Citizenship in Austria and Germany” A Comparison. European

Consortium on Political Research, 2000. Print.

Renshon, Stanley. “Reforming Dual Citizenship in the United States” Integrating Immigrants into

the American National community. Center for Immigration Studies, 2005. Print.

Renshon, Stanley. “Dual Citizenship and American National Identity”. Centre for Immigration

studies, 2001. Print.

Multiple Citizenship 17