Monday, October 31, 2022

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Are dual citizens a bad lot?

By Gamini Abeywardane

With the passing of the 21st amendment to the Constitution the issue of dual citizens holding key political positions has come to the public domain again. Unfortunately in our country greed for political power, rivalry and ill-gotten money appear to be playing a key role behind the scene and as a result there is no genuine public discussion on the matter. The majority of those who make public utterances on this issue do so, on those lines and not on what is good for the country at this point of time.

The allegations are that the restrictions imposed target individuals, but it need not be the exact case as many countries have continued to maintain such citizenship restrictions for long due to a variety of reasons.

 A key issue here is the question of loyalty to the country of origin when one has taken an oath of allegiance to another country. This could be sensitive in certain circumstances when such a person is sitting in a high position with much discretionary power.

There have been instances of nationals of one country holding important positions in another country even without dual citizenships when that person is most qualified and there are advantages for the country employing such person. Mark Joseph Carney, a Canadian economist and a former governor of the Bank of Canada was appointed the governor of the Bank of England in 2013 and served till 2020. Another example is John Exter, the American economist who founded the Central Bank of Ceylon and became its first governor. They were appointments selectively made for very valid reasons.

If one wants to argue in favour of dual citizenship holders there are so many examples, but the question is whether a country should allow a dual citizen to hold a vitally important position like a legislator, the prime minister or head of state. Most countries do not allow such things.


Our closest neighbour and comparable democracy India does not allow holding Indian citizenship and citizenship of a foreign country simultaneously. In terms of Article 9 of the Constitution of India any person voluntarily acquiring the citizenship of a foreign country will be relinquishing the Indian citizenship.

They have a scheme called Overseas Citizenship of India (OCI) which only allows people of Indian origin and their spouses to live and work in India indefinitely, but does not grant the right to vote in Indian elections or hold public office.

Although India does not allow dual citizenship at all, they have introduced this system to get the best out of overseas Indians who want to come and work in India. As of 2020, there were around six million holders of OCI cards among the Indian Overseas diaspora.


Australia is also strict in their citizenship laws and native or ‘born and bred’ Australians cannot obtain the citizenship of another country without losing Australian nationality. However since they are a country which has been enjoying the benefit of immigration for decades they allow the immigrants who obtain Australian citizenship to retain dual citizenships in their countries of origin if it is allowed by such countries. But the Australian citizenship laws expressly prohibit foreign nationals and dual citizens from sitting in the parliament. Section 44 of the Australian Constitution bars foreign citizens and dual citizens from sitting in the federal legislature.

However in this issue Australia seems to be alone compared to other major immigration countries like the USA, Canada, and New Zealand, in prohibiting its citizens from taking out another citizenship. The UK, it appears, has long promoted dual citizenship. In these countries having a dual citizenship is not a disqualification to be a legislator or to hold any other position.

Singapore despite its much liberal economic outlook has long maintained restrictions on citizenship. Anyone obtaining Singapore citizenship has to renounce citizenship in his or her home country as they do not recognize dual nationality.

 The major argument in favour of dual citizenship is that it makes sense in a world of economic globalisation, instant communications and vastly increased personal mobility. However with regard to dual citizenship there is no general consensus among countries. Some countries allow dual citizenship; some prohibit it while others recognize dual citizenship in some form.

However it appears that most countries have restrictions arising from government policy and preferences which again depend on their own circumstances. There is no universal rule to say whether dual citizenship should be allowed or even if it is allowed whether that category of persons should be given the right to sit in the legislature or hold high political positions.

National identity and sovereignty

A key factor that has gone into consideration in this matter seems to be the core issue of national identity and sovereignty and security.

Powerful countries like the US and the UK have no such issue because no country can interfere in their internal politics so that they can be quite liberal with citizenship issues. Similarly migrants are unlikely to outnumber the natives in those countries.

The sensitivity of these issues will be paramount where foreign interferences are dominant in internal politics of a country and it can be worst when a country has economically collapsed.

The decision of the Sri Lankan government to ban dual citizens from sitting in the parliament in the latest constitutional amendment has to be viewed against this background.


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