Submission on the discussion paper 'Australian citizenship: much more than just a ceremony'

September 2006

Submission of: The Human Rights and Equal Opportunity Commission

To: The Citizenship Taskforce, Department of Immigration and Multicultural Affairs

On the Discussion Paper 'Australian citizenship: much more than just a ceremony'

Human Rights and Equal Opportunity Commission
Level 8, 133 Castlereagh St
GPO Box 5218
Sydney NSW 2001

A: INTRODUCTION

The Human Rights and Equal Opportunity Commission (‘the Commission’) provides this submission to the Department of Immigration and Multicultural Affairs (DIMA) in response to the discussion paper Australian Citizenship: Much more than just a ceremony, September 2006 (‘the Discussion Paper’).

B: SUMMARY

The Human Rights and Equal Opportunity Commission submission to the Discussion Paper is divided into Part 1 and Part 2.

Part 1 – Should Australia introduce a formal citizenship test?

The Commission considers that, in order to comply with its obligations under international law, the government must ensure that the proposed citizenship test is

pursuant to a legitimate aim;

proportionate to achieving its aims; and

based on reasonable and objective criteria.

Although the Discussion Paper proposes some legitimate aims for the introduction of a formal citizenship test, the Commission considers that it does not provide adequate justification for the introduction of the proposed test to meet these aims.

The Discussion Paper does not provide convincing evidence of problems with or inadequacy within the current system, and does not explain how the proposed changes would better achieve its aims.

It also fails to consider the negative impact of the proposed changes and whether other approaches would alleviate these risks whilst achieving the same goals.

Part 2 – Safeguards should a formal citizenship test be introduced

Should a formal test be introduced, the Commission submits that the government would need to seriously consider the format, content and implementation of such a test to ensure that it did not have a discriminatory impact on certain communities within Australia.

The government should ensure that

the content and format of the proposed test does not have a discriminatory impact on certain groups and individuals wishing to apply for citizenship;

alternatives to a formal test are provided;

appropriate services and assistance are provided to citizenship applicants;

certain categories of people are specifically exempted from the proposed test;

there are appropriate safeguards in place for those who fail the proposed test; and

it introduces programs and education campaigns which promote human rights and responsibilities and the need to respect diverse cultures, as part of the government’s obligations to assist people from other countries to successfully integrate into the community.

In addition, the Commission submits that there is no demonstrated need to introduce a similar test for permanent residents across the board, as visas need to be tailored to meet specific needs. This is currently provided for through the existing Australian Migration Program.

C: RESPONSE TO THE DISCUSSION PAPER

PART 1- Should Australia introduce a formal citizenship test?

Overview of Part 1

The government’s Discussion Paper considers the merits of introducing a formal citizenship test that consists of the following elements:
- English test which will test English to the level that allows the applicant to participate in education and employment (para 26).
- Test of the applicants knowledge of the Australian way of life and values (para 28). The values aspect of the test will ensure the applicant understands common values such as:
  - our respect for the freedom and dignity of the individual;
  - our commitment to the rule of law;
  - the equality of men and women;
  - the spirit of the fair go; and
  - mutual respect and compassion for those in need (para 26).

The test will also ensure that prospective citizens understand the Citizenship Pledge, their responsibilities, privileges, what they are committing themselves to and a greater understanding and ability to take up the opportunities which Australian citizenship provides (para 37).

The Commission considers that the proposed citizenship test involves an implicit differentiation between citizen and non-citizen. There is also a real prospect of the proposed citizenship test having a discriminatory impact on the ground of language, national or social origin and/or birth. That is, the Commission is concerned that a person from a non-English-speaking background is likely to be at a disadvantage in passing an English test compared with a person from an English-speaking background. Likewise, the Commission is concerned that a person from a developed country is likely to have a greater level of education and therefore at an advantage in passing a formal test compared with a person from a less developed country.
Accordingly, for the reasons set out below, the Commission considers that the government must, in order to comply with its obligations under international law, ensure that the proposed test is: pursuant to a legitimate aim;

Discrimination under international law

ICERD

The International Convention on the Elimination of all forms of Racial Discrimination (ICERD) prohibits discrimination on the basis of race. Pursuant to Article 1(2), ICERD expressly excludes from its scope:

distinctions, exclusions, restrictions or preferences made by a State Party to this Convention between citizens and non-citizens.

However, the Committee on the Elimination of Racial Discrimination (CERD), the body responsible for administering ICERD, has confirmed that Article 1(2) must be construed to avoid undermining the basic prohibition against discrimination under international law.[1] It therefore concluded:

Under the Convention (ICERD), differential treatment based on citizenship or immigration status will constitute discrimination if the criteria for such differentiation, judged in the light of the objectives and purposes of the Convention, are not applied pursuant to a legitimate aim, and are not proportional to the achievement of this aim. (emphasis added)

ICCPR

Article 26 of the International Covenant on Civil and Political Rights (ICCPR), states:

All persons are equal before the law and are entitled without any discrimination to the equal protection of the law. In this respect, the law shall prohibit any discrimination and guarantee to all persons equal and effective protection against discrimination on any ground such as race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth or other status.
The Human Rights Committee (HRC), the body responsible for administering the ICCPR, has confirmed that Article 26 does not merely duplicate the guarantee of freedom from discrimination contained in Article 2 of the ICCPR. Article 26 also requires State parties to ensure that its legislation is not discriminatory on the grounds of race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth or other status.[2]
However, the HRC went on to qualify the scope of Article 26, concluding that:

not every differentiation of treatment will constitute discrimination, if the criteria for such differentiation are reasonable and objective and if the aim is to achieve a purpose which is legitimate under the Covenant.[3]

These qualifications are also reflected in the jurisprudence of the HRC.[4]

Conclusions on the application of ICERD and Article 26 of the ICCPR to the proposed citizenship test

The Commission considers that the proposed citizenship test involves an implicit differentiation between citizen and non-citizen. There is also a real prospect of the proposed citizenship test having a discriminatory impact on the ground of, most relevantly, language, national or social origin and/or birth.

Accordingly, in line with the comments of ICERD and the HRC referred to above, the Commission considers that the government must, in order to comply with its obligations under ICERD and Article 26 of the ICCPR, ensure that the proposed test is:

Does the proposed Citizenship Test have a legitimate aim?

The Discussion Paper suggests that the aims of the proposed citizenship test are to:
In the Commission’s view these are, on their face, legitimate aims and are not contrary to ICCPR and ICERD. Nevertheless, the Commission considers that in order to demonstrate that it is pursuing a legitimate aim, the government should provide a cogent and convincing justification for the proposed amendment to the current citizenship laws. This should include:

These issues are discussed below.

Evidence of problems with or inadequacy within the current system and an explanation of how the proposed changes would better achieve its aims

The Commission considers that the Discussion Paper does not provide adequate evidence of problems with or inadequacy within the current system or an explanation of how the proposed changes would better achieve its aims. The paper does not provide a proper evaluation of the capacity of the current system to achieve the stated goals nor an analysis of how the proposed changes would overcome any perceived inadequacies in the current system.
In relation to the current system, data appearing on the Department of Immigration and Multicultural Affairs (DIMA) website and the Australian Bureau of Statistics (ABS) website indicates that a high proportion of people born overseas wish to become Australian citizens, in that:
In addition, under the current system there are already mechanisms to ensure that many migrants entering Australia are proficient in English. For instance, to obtain a visa through the General Skilled Migration Program, the majority of applicants need to pass an English test to ensure they have the requisite level of English to aid employment opportunities upon arrival in Australia. The 2005-2006 Migration Program accepted between 130,000 and 140,000 migrants to Australia. Of these places, 97,500 were migrants coming through the Skill Stream.[7] Hence English language testing is an unnecessary imposition for a number of people.
Further, the majority of people in Australia that are eligible for citizenship are from Mainly-English-Speaking Background (MESB) countries, therefore rendering English testing superfluous. It is interesting to note that people from the U.K and New Zealand were the two largest groups to take up citizenship in the last three years. However, when considered in the standardised citizenship rate, they have a much lower take-up of citizenship than their Non-English-Speaking Background (NESB) counterparts.[8] This infers that barriers to citizenship take-up and benefits that this brings to the individual and the Australian society are not necessarily related to a lack of English language skills.

Consideration of the negative impact of the proposed changes

There are a number of significant public policy and human rights concerns in relation to any test that has the potential to increase the grounds for withholding citizenship from non-citizens residing within Australia. These concerns arise from the increased vulnerability of non-citizens politically, socially and economically.
The vulnerability of non-citizens is highlighted in the Discussion Paper at paragraphs 7 and 8, which outlines the value and benefits of citizenship as;
The Commission also considers that there is a further important benefit of citizenship that has not been referred to in the Discussion Paper – the freedom from deportation enjoyed by citizens.[9] The Commission refers in particular to the broad discretion of the Minister under s 501 of the Migration Act 1958 (Cth) to remove non-citizens from Australia by cancelling their visa on ‘character grounds’.[10]
The significance of these concerns is borne out by a consideration of the relatively recent history of citizenship policy in Australia which includes the de facto withholding of citizenship from Aboriginal people up until 1967 and the introduction of the ‘White Australia Policy’ from the 1850’s through to 1973. The broad heading ‘White Australia Policy’ refers to a number of policies introduced to restrict non-European immigration to Australia and promote white, European immigration to Australia.
In view of this history and these concerns it is important to ensure that adequate consideration is given to the risks of introducing a formal citizenship test and to weigh this against the aims that the proposed test is seeking to achieve. In particular the Commission is concerned that there is a risk that the proposed changes will increase social disharmony and divisiveness.
As a result of the national consultations that the Commission conducted with Arab and Muslim Australians through the Isma project in 2003-2004 and through further consultations with African communities and Middle Eastern communities in 2006, the Commission is of the view that there currently exists in Australia an increased level of fear and discrimination directed towards particular sections of Australia’s ethnic communities. In this climate there is a risk that the introduction of a formal test on English language and ‘Australian’ values will have the effect of further marginalising these groups rather than encouraging social cohesion. For instance, it may send a message to the broader Australian community that certain migrant groups and refugees do not value the Australian way of life or understand its values and hold values that are different to the rest of Australian society. These messages can only exacerbate the current climate of fear and discrimination and reinforce the negative stereotypes on which this fear and discrimination is based. The potential risk of increasing social disharmony and divisiveness is directly contrary to the stated aims of introducing the citizenship test.
The Commission also submits that the concept of testing Australian values is ill-defined and divisive rather than inclusive. While the Commission acknowledges that there is merit in educating prospective citizens about Australian law and government, the testing of values raises a number of difficulties, not least of which are defining what the values are, determining which ones are core values and how they can be tested. Further, citizenship does not guarantee the practice of “Australian values” and it is an un-evidenced assumption that Australian values are commonly shared. The Commission questions the ability to test whether applicants know these values and more importantly, whether passing such a test would indicate or lead to a greater acceptance and adoption of these values.
The values deemed important by many Australians and considered to be fundamental to an Australian way of life may include tolerance, fairness, compassion and respect for difference. These are not unique to Australia but are values held by many peoples across the world. Testing these values is inherently difficult and the failure to pass this test should not be interpreted as the inability of the applicant to fit into Australian society or respect its values.

Whether other approaches would alleviate these risks whilst achieving the same goals

In view of the potential risk to social cohesion through the introduction of a formal citizenship test it is necessary to consider other approaches for achieving the stated goals of the proposal which do not incur the risks associated with the proposal.
The Commission submits that a commitment to Australian values and way of life develops through positive interaction within the community, through school education, community activities and employment. Such endeavours are viewed by the Commission as a more positive and successful approach to integration than the study and completion of a formal citizenship test.
One approach to consider would be to augment the current incentives available and create a course of study directed to participation and inclusion through citizenship, which could be compulsory for applicants for citizenship. A course of similar nature to the Adult Migrant English Program (AMEP) course Let’s participate: A course in Australian Citizenship, is considered a better approach to achieving the goals of the changes proposed in the Discussion Paper. Participation in a course would be a more inclusive and constructive way of ensuring that people wishing to become citizens have adequate English and the knowledge of Australia to fully participate in Australian society. However, the granting of citizenship should not be contingent on passing a test at the end of the course. As mentioned in Part 2, paragraph 39 of the submission, such a course would need flexibility and appropriate services to cater for the various needs of participants.

Conclusions for Part 1

The Commission does not suggest that the government is pursuing an illegitimate aim in seeking to introduce a formal citizenship test. Nevertheless, the Commission considers that, to date, the government has failed to adequately articulate its aims in introducing the proposed changes.
For the reasons discussed above, the Commission submits that the Discussion Paper fails to demonstrate that:

The Commission considers that, as the Discussion Paper fails to make a case for the proposed test, the government should not introduce a formal citizenship test.

PART 2 – Safeguards should a formal citizenship test be introduced

Overview of Part 2

As noted above in Part 1, the Commission is yet to be convinced that there is a need to introduce a formal citizenship test as proposed in the Discussion Paper. Indeed, at this stage the Commission considers that any potential benefits are likely to be outweighed by the negative impact the changes will have on social cohesion within our community.
Notwithstanding the above, this Part of the Commission’s submission sets out the Commission’s views should such a formal test for citizenship be introduced.
The Commission considers that the comments below are important for ensuring that any differentiation on the ground of language, national or social origin, birth or citizenship arising from a formal citizenship test is:

Content and format of test

In Part 1 the Commission has outlined its concerns with the testing of values. In light of these concerns, the Commission submits that the testing of values not be undertaken as part of the Citizenship Test.
Even if the Test includes the testing of knowledge of Australian way of life and Australian law, the government should carefully consider what type of material should be included as an adequate reflection of the stated aims of the proposed test. The Discussion Paper included sample questions from various international citizenship tests, covering history and way of life, such as:
- Which of these statements is correct – a television licence is required for each television in a home or a single television licence covers all televisions in the home?[11]
- Which President was the first commander in chief of the US military?[12]

The Commission queries whether the ability to answer questions of this type is either indicative of a person being a good citizen, or necessary for citizenship. Indeed it is questionable whether a test of this type would be passed by all current Australian-born citizens.

The format of the proposed test should also be considered carefully. Certain types of tests could disadvantage some groups. For example, the introduction of on-line testing (para 70) could create difficulties for applicants without the necessary computer skills, for example, the elderly and those from developing countries. Many applicants from developed countries will have greater proficiency than their counterparts from developing nations. While the Life in the U.K. test [13] website offers instruction in Mouse training and Keyboard training, a certain amount of computer proficiency is needed to access this training. In order to minimise the risk of the proposed test having a discriminatory impact on persons who, because of their birth or previous nationality, have not developed computer literacy skills, the Commission considers that the government would need to ensure that all applicants for citizenship had access to personal help in the most basic of computer skills. Alternatively, the format of the proposed testing should not be exclusively on-line, but could include more traditional types of testing, such as in paper form.

Alternatives to formal testing

Even if a formal test were to be introduced, there should be alternatives and flexibility to testing for those who wish to become citizens. As discussed in Part 1, the Commission suggests that a course-based approach could meet some of the aims of the Discussion Paper. The government could provide a course as an alternative to certain groups unable to sit the test for various reasons.
If the government were to implement such a course, consideration would be needed to ensure that non-citizens are provided with appropriate services and assistance to attend the course. The Commission submits that the following arrangements should be implemented to assist attendance at English/citizenship classes:

Another possible alternative is to offer applicants for citizenship the chance to gain citizenship through an interview process. This would ensure that those unable to pass a formal test would be given an alternative method to demonstrate their eligibility for citizenship. Within an interview, an applicant could be tested for English proficiency and given the opportunity to provide supporting evidence of participation and integration in the community, for example;

Provision of appropriate services and assistance to citizenship applicants.

The Commission considers that, in order to advance its stated aims of enhancing skills, employment and participation of new citizens, the government must ensure that citizenship applicants are provided with appropriate services and assistance to assist them to pass the proposed test.
In relation to the provision of such programs the Commission notes with concern the recent statements made by Ms Anna Burke in Australian Parliament recently, to the effect that the government has cut funding to the AMEP. As stated in Hansard:

But, if we are to encourage people to ensure that they have English when they take up their citizenship, surely we must be putting in the resources so they can actually do it. The government has in fact slashed money from English classes by $11 [$10.8] million. It has under funded programs. It does not ensure that there are sufficient hours. It does not ensure that the classes are at flexible times and it does not provide child care.[14]
Cutting of funding to migrant English programs and Migrant Resource Centres, another invaluable tool in helping new arrivals in Australia to integrate, is counter-productive to the government’s desire for new citizens to be highly proficient in English, in order to fully participate in Australian society.

Exemptions from the test for certain individuals and groups

If the proposed test were to be introduced the government would need to implement appropriate safeguards, in the form of exemptions, to ensure that the government meets its international obligations. The Commission submits that the following groups should be exempt from the testing:

The Commission is particularly concerned about the possible outcome of formal citizenship testing rendering a child stateless. The Convention on the Rights of the Child (CRC) seeks to ensure that a child is protected from discrimination regardless of the status of his or her parents, guardians or family members.[15] The CRC also sets out the right of every child to acquire a nationality (Article 7) and the right of every child to preserve his or her identity (Article 8). Article 24 of the ICCPR also protects a child’s right to a nationality. The government should make certain that a child would not be denied any of the rights in the CRC because his or her parents cannot obtain citizenship.
Refugees, by their very definition, do not have effective protection of their original nationality and it is therefore imperative that they have access to a new nationality. Article 34 of the Refugee Convention requires Australia to tale steps, ‘as far as possible, to facilitate the assimilation and naturalisation of refugees’.[16] A citizenship test should not be a bar to this right.
The Commission submits that steps should be taken to protect the family unit if formal citizenship testing were to be introduced, in accordance with Article 23 (family life) of the ICCPR.[17] In addition, Article 10 of the CRC emphasises the importance of family reunification. All family members should be entitled to citizenship without all having to pass the proposed test.
The government should ensure that the failing of a citizenship test would not lead to statelessness, in accordance with the Convention relating to the Status of Stateless Persons. [18]
The Commission submits that exemptions should also be granted to older applicants, incapacitated persons, persons with a mental, learning or other relevant disability and long term residents.

Safeguards for those who fail the test

As noted above, the Commission is concerned that the proposed citizenship test may have a discriminatory impact on certain groups of persons, particularly on the grounds of language, national or social origin and/or birth. In light of these concerns, the Commission considers that it is appropriate that the proposed citizenship test is accompanied by a clear and effective right of appeal, including the possibility of full merits review. This is important for ensuring that persons whose rights and freedoms are violated by the test or its application have access to an effective remedy, as required under Article 3 of the ICCPR. It would also ensure that any areas of discretion within the test, or aspects of the testing open to subjective interpretation, can be reviewed with ‘fresh eyes’.
The Commission also submits that there should be no limit on the amount of times an applicant is permitted to re-sit the proposed citizenship test and no waiting period in between failure to pass the proposed test and the opportunity to re-sit. Many people who repeatedly failed the proposed test would continue to go on living in Australia as permanent residents. The danger of this situation is that these people will be labelled as ‘outsiders’, unable to integrate fully into Australian society through citizenship.

Human rights programs and education campaigns

One of the stated aims of the proposed citizenship test is to build social cohesion and assist people from other countries to successfully integrate into the community. As indicated above, the Commission considers this a legitimate aim consistent with human rights principles. One aspect of integration is ensuring participation in the broader society through employment and other activities. The Commission acknowledges the importance of knowledge of English and an understanding of the underlying legal and governing institutions in achieving these goals. Another aspect of integration, not referred to in the Discussion Paper are the rights enjoyed by citizens and non-citizens alike to practice and enjoy their culture and religion and to be protected from discrimination when they seek to do this.
The Commission submits that if the government is to implement the proposed test for prospective citizens it should also, as part of the same process, embark on an education program for the broader society about human rights and responsibilities. Such a program would further advance the aim of promoting mutual respect between diverse cultures, whilst acknowledging the contribution that migrants and refugees make to Australia.
To develop this, funding for specific programs to change community attitude, combat prejudice and discrimination against all Australians would improve opportunities for new Australians to gain meaningful employment.

Permanent Residents

Australia’s Migration Programme currently provides a range of permanent residency visas tailored to meet both Australia's needs and the needs of refugees and migrants. The Commission recognises that English language proficiency may be essential for certain occupations; however English language is already recognised as criteria in a number of visa categories. There is no evidence provided in the Discussion Paper to indicate that the current criteria for visa categories for permanent residency and long term temporary residency is unsuccessful and should be replaced by a formal test. Further, introducing such a test would run the risk of creating a shortage of workers for certain trades and occupations where high level English is not necessary.
The Commission also finds that the Discussion Paper provides no convincing evidence of a need for testing permanent visa applicants for their knowledge of Australian values, for the same reasons identified in Part 1 of this submission. The majority of migrants entering Australia under the Skill Stream have high rates of participation in the labour market.[19] As a consequence these same people are, on the whole, integrating into the wider Australian community through their participation in work.
For non-work related permanent visa applicants, English language and values tests may be highly inappropriate. Humanitarian applicants should not have to demonstrate English language competency, or an understanding of values, in order to find permanent refuge and settlement in Australia. It would also be inappropriate to require family reunion applicants, such as applicants for aged parent or spouse visas, to pass a test of English or Australian values. Such testing may also be counterproductive to encouraging skilled migrants to choose Australia as a place of permanent settlement, as they, quite reasonably, wish to have their families join them.

Final Conclusions for Part 1 and Part 2

The Commission does not suggest that the government is pursuing an illegitimate aim in seeking to introduce a formal citizenship test. Nevertheless, the Commission considers that, to date, the government has failed to adequately articulate its aims in introducing the proposed changes.
The Commission therefore considers that, as the Discussion Paper fails to make a case for the proposed test, the government should not introduce a formal citizenship test.
However, should a formal citizenship test be introduced, the government would need to seriously consider the content, format and implementation of the proposed test to ensure that it did not have a discriminatory impact on certain communities within Australia. There would also need to be various safeguards and exemptions in place to ensure that a formal citizenship test is a transparent and fair process.

[1] Committee on the Elimination of Racial Discrimination (CERD), General Recommendation 30 (Discrimination against non-citizens), paras 2 – 3.

[2] Human Rights Committee (HRC), General Recommendation 18 (Non-discrimination), para 12.

[3] Human Rights Committee (HRC), General Recommendation 18 (Non-discrimination), para 12.

[4] See, eg, Broeks v. The Netherlands (172/1984), ICCPR, A/42/40 (9 April 1987) 139 at para. 13; Borzov v Estonia (1136/2002), ICCPR C/81/D/1136/2002 (2 November 2001) at paras 7.3 – 7.4.

[5] Department of Immigration and Multicultural Affairs (DIMA). Available at http://www.citizenship.gov.au/resources/facts-and-stats/stats.htm

[6] Australian Bureau of Statistics (ABS). Year Book Australia, 2006. Available at http://www.abs.gov.au/ausstats/abs@.nsf/bb8db737e2af84b8ca25717
80015701e/01408D0F3CFFA83ECA2570DE0006E28E?opendocument

[7] Bob Birrell, Lesleyanne Hawthorne and Sue Richardson (2006), Evaluation on the General Skilled Migration Categories, Commonwealth of Australia, 2006, p 10

[8] ABS, Year Book Australia, 2006. Available at http://www.abs.gov.au/ausstats/abs@.nsf/bb8db737e2af84b8ca25717
80015701e/01408D0F3CFFA83ECA2570DE0006E28E?opendocument

[9] The Minister’s power to deport persons under the Migration Act 1958 (Cth) is limited to non-citizens: see Part 2, Division 9. Similarly, unlike the case with non-citizens, a citizen can not be removed from Australia on the basis of being an unlawful non-citizen: see s 14 of the Migration Act.

[10] The breadth of the Minister’s discretion under s 501 was recently confirmed by the High Court in Minister for Immigration and Multicultural and Indigenous Affairs v Nystrom [2006] HCA 50.

[11] DIMA, Australian Citizenship: Much more than just a ceremony, Life in the UK Test , p 21

[12] DIMA, Australian Citizenship: Much more than just a ceremony, United States – Citizenship Test, p 27

[13] Available at http://www.lifeintheuktest.gov.uk/htmlsite/mouse_10.html. Available at http://www.lifeintheuktest.gov.uk/htmlsite/keyboard_10.html

[14] Ms Anna Burke, House of Representatives Hansard, Wednesday 1st November 2006, pp 108-109

[15] Article 2: ‘State parties shall take all appropriate measures to ensure that the child is protected against all forms of discrimination or punishment on the basis of the status, activities, expressed opinions, or beliefs of the child’s parents, legal guardians, or family members.’

[16] Article 34: ‘The Contracting States shall as far as possible facilitate the assimilation and naturalization of refugees. They shall in particular make every effort to expedite naturalization proceedings and to reduce as far as possible the charges and costs of such proceedings.’

[17] Article 23: ‘The family is the natural and fundamental group unit of society and is entitled to protection by society and the State.’

[18] Article 32: ‘The Contracting States shall as far as possible facilitate the assimilation and naturalization of stateless persons. They shall in particular make every effort to expedite naturalization proceedings and to reduce as far as possible the charges and costs of such proceedings.’

[19] Productivity Commission , Economic Impacts of Migration and Population Growth, , 24 April 2006, pp 59-60

Last updated 12 August 2003.

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