The situation as I understand it. Scott Ludlam has vacated his Senate seat after it came to his attention that having lived here nearly all of his life and being naturalised as an Australian did not vacate his New Zealand citizenship. This caused him to fall foul of Section 44(i) of the Constitution, which disqualifies those who are “a subject or a citizen of a foreign power”. Those who drafted this would never have imagined it might apply in Ludlam’s case, since Australians and New Zealanders alike were then British subjects – Australian and New Zealand citizenship did not exist until shortly after World War II. In my view, the section could do with a redraft – or better yet, the matter of disqualification should be removed from the Constitution altogether and left to a normal act of parliament, which has worked happily enough in the states without triggering such unproductive disqualifications as those of Robert Wood, Phil Cleary, Jackie Kelly and Heather Hill.
There now arises the issue of who replaces him, covering ground familiar from the situations faced by Bob Day and Rod Culleton, respectively due to a pecuniary interest issue and a conviction for which Culleton was awaiting sentence at the time of the election (that the conviction had since been set aside did not avail him). In both cases, the Senate referred the matter to the High Court, which ruled that neither had been validly elected. This resulted in recounts being held for their respective Senate races in South Australia and Western Australia, and the election of the next candidates along on their party tickets, Lucy Gichuhi and Peter Georgiou.
If it plays out the same way this time, there seems little reason to doubt that a further Western Australian recount will deliver a seat to the Greens’ third candidate, Jordon Steele-John, a 22-year-old disability advocate with cerebral palsy. Steele-John wrote on Facebook today that “if it comes down to it, I’d be happier putting the choice of candidate back into the hands of our party membership”. I’ve heard it suggested that the High Court might not in any case be interested in having the matter referred to it, since Ludlam has resigned and there are no new points of law to be adjudicated on as there were in the case of Bob Day, who had likewise already resigned over the separate matter of his insolvency (UPDATE: Antony Green in comments demurs).
In either case, it seems likely the matter will eventually be determined by the Western Australian Greens as a casual vacancy, and it’s impossible to say how that will play out as there has been none of the usual jockeying for position, since the situation has arisen out of the blue. Antony Green has floated the idea that Ludlam could resolve his citizenship issue before the casual vacancy officially emerges, then simply take his own place. Failing that, the four Greens in state parliament might be thought obvious contenders, those with the most parliamentary experience being Robin Chapple and Alison Xamon. Chapple is 70, which might be thought discouraging, while the notoriously heavy demands of running a federal political career from Western Australia may not sound attractive to Xamon given her family responsibilities. Newly elected at the last election were Tim Clifford and Diane Evers. The position may also be of interest to Lynn MacLaren, whose eight year career ended in her narrow defeat in March.
Another issue relates to the question of the long-term and short-term Senate positions. After a double dissolution election, the Senate gets to decide which of its members serve six-year and which three-year terms, and last year they chose to do so on the basis of the order of their election. As the Greens’ top candidate, Ludlam was third elected and duly got a long term; twelfth elected was second placed Rachel Siewert, who got a short term. If a simple recount was conducted excluding Ludlam, Siewert would them be third elected instead, and would presumably have a claim to take the long-term position. Steele-John would then be elected ninth, and on declining to take the position, that would be the vacancy that would be filled. However, things get a bit murky around about here – can the Senate promote a Senator from a short to a long term in this fashion? Might the court evade this issue by ordering a different type of recount?
Can comments here be kept on topic — the thread for general discussion is here.
Sad about Ludlam. Seems that there are issues however about eligibility that, overall need to be addressed. Given its 3 times in this parliament, it would be a good time, and i think quite reasonable, for ALL our current parliamentarians to declare that their eligibility status is confirmed and provide whatever documentary evidence is needed to unequivocally back up such a declaration.
I mean, how does it go if for a vote on a certain piece of legislation or regulation, the vote of a parliamentarian who is later found to have been ineligible is critical to its passing or failure??
Can someone with an interest then challenge the validity of that legislation or regulation in the high court?? If they can then this may not be a trivial issue.
Would there have been any such instances over the last 10 years where the vote of one Greens Senator meant legislation passed or failed?
Can’t say I’m sympathetic, since I understand on the balance of probabilities he would not have survived the 2014 election without the missing votes fiasco.
Tony Abbott renounced his British Citizenship back in the 90s apparently. Glad that’s been cleared up.
Antony Green’s take:
http://blogs.abc.net.au/antonygreen/2017/07/scott-ludlam-resigns-what-happens-to-his-senate-seat.html
William, on matters of settled law the High Court can kick the case to the Federal Court as the Court of Disputed returns. This one is pretty settled. If the High Court hears the case it will be a one judge quickie.
Thanks Antony.
I agree with Antony, it seems the logical path considering past decisions.
As I said on the other thread he has admitted he was ineligible to stand so a recount is the precedent set the High Court in its rulings of similar cases.
In the case of the Greens , no it being Ludlam or not Ludlam likely wouldn’t have mattered much, no Australian Green has excercised a conscience vote different to party inclination in the past 10 years to my knowledge (Bandt sometimes votes differently to the Senate group but thats because he generally has to take a position first and it’s close to irrelevant except during Gillard’s term).
Its situations like Day or Cullerton where different people may have voted differently that the matter becomes interesting.
There’s also a vague sort of injustice about the current arrangement whereby the work there people do is held as valid but their payment is not. Which is a bit fucked up. I can sort of understand holding their work as valid on a consistency basis, a sudden reversal of an indefinite period of laws would be bad (eg in this situation Ludlam hasn’t been valid for election at any point, so it’s not limited to one term).
In the interests of transparency, I’m a Greens voter. It would be unfair if Rachel Siewert did not receive Scott’s six-year term. Otherwise, we will have two senators standing for election in 2019 with only one candidate likely to be elected. This is of course partly what the PM was hoping to achieve in calling a double dissolution although not a strategy specifically aimed at the Greens.
That’s not right. Ludlam was allocated the 6 year term after the 2016 election. Either the elected re-count member gets the 6 year term, or the Senate will re-consider its 2016 allocation and Siewert will be re-allocated to the 6-year term and the newly elected member get the three year term. Either way only one Green faces the electorate at the next election.
From Assange, I don’t know if there is any merit to his argument
According to my reading if @SenatorLudlam took AU citizenship before changes in 1986 and didn’t “use” his NZ citizenship then he’s fine.
http://kevinbonham.blogspot.com.au/2017/07/scott-ludlam-mess-scores-four-bob-days.html
Scott Ludlam Mess Scores Four Bob Days Out Of Five
imacca @ #2 Friday, July 14, 2017 at 4:46 pm
The High Court ruled in Vardon v O’Loughlin (1907) that it has no effect and this has been followed ever since.
(Spelling correction – it’s Vardon v O’Loghlin).
William or Kevin,
I can see Ludlam coming back most probably at the next election rather than a casual vacancy.
I think to come straight back would provide too much ammunition for his opponents.
What do you guys think?
Hmm. This does raise an interesting question. Have we had the situation where an ineligibility recount also changes the party of a currently elected Senator ? If so what happens in that case ? I assume the answer is nothing, because under the GTV system you could eliminate a sizeable portion of the Senate representatives from a state in a DD recount.
(Also it’s probably slightly better for the Greens for Siewert to go to election first. Having served the longest she’s more likely to win and it gives Ludlam’s replacement a chance to establish themselves.)
Ludlam will generate non-stop fury from his opponents in any case. You should take a look at the way most of the usual suspects have written up this situation.
I suspect you’re correct though. Ludlam phrased his resignation in a way that suggests he’s not looking for an immediate come back.
Imacca and others – just think about the consequences if every law could be invalidated because of an irregularity in an election of either House, or some procedural irregularity. As a wise Sri Lankan (Ceylonese in those days) Judge said:
(PS Bus Co. Ltd v Ceylon Transport Board (1958) 61 NLR 491 per Sinnetamby J – see http://www.lawnet.lk/docs/case_law/nlr/common/html/NLR61V491.htm )
Vexatious/vexed litigants love that “everything is invalid since such-and-such a date” sort of argument, usually using it to conclude “therefore I don’t have to pay my taxes/rates/child support/parking fines” (there’s always a hip-pocket motive somewhere) but no court in any country I know of has ever accepted it.
jack a randa @ #20 Saturday, July 15, 2017 at 3:39 pm
I don’t think invalidating every law passed during the time Ludlam is what Imacca and others were getting at. The overwhelming majority of bills (99%+) pass or fail to pass the Senate with more than a 1 seat margin, so having Ludlam’s vote or not would not make any difference, so the argument about all legislation passed/rejected during the relevant period is ridiculous.
I don’t know if it’s happened, so let’s hypothetically consider a situation where the offending vote was the difference between a particular bill passing/not passing. I think it’s worth having a hard look at, particularly if the person who would have been elected but for the presence of the invalidly elected MHR/Senator would likely have voted differently to the invalidly elected MHR/Senator.
elaugaufein @ #18 Saturday, July 15, 2017 at 3:10 pm
This has never happened in the Senate – there have only been four previous recounts of this kind and they were all straightforward. It did however happen on Melbourne City Council recently. A councillor was ineligible and the next candidate on their ticket won in the recount. However because one of the other tickets had preferenced only the top candidate and not the #2 (they are using Group Ticket voting) this had the flow on effect that Michael Caiafa became unelected and his place was taken by a Team Doyle candidate.
As I point out in my article, had the original 2013 WA Senate count stood then Ludlam’s ineligibility could have flipped the result of two seats when the count was recounted without him. That was an unusual case though, even under GTV most such cases would have led to like-for-like replacement.
Barney #17 – I agree. Indeed it might be that after this he doesn’t come back to Senate politics at all. To bring him back through internal party machinations would create an impression of a culture of entitlement to the seat and would be a bad look. The question of the supposed debt for pay received while not elected will also haunt him if he comes back soon or perhaps even at all. He might be better off doing something totally different.
Grimace, the courts here and in at least the UK, New Zealand and Ceylon have made it clear that once electoral writs are returned, the people elected are entitled to exercise legislative power even if someone later discovers an irregularity. Justice Sinnathamby’s words apply even if a Bill has been passed by a majority of one – people have conducted their affairs on the basis that it is the law. If a later parliament with a different majority wants to change it, they can change it and even, at the price of throwing people’s affairs into disorder, change it retrospectively. But the courts will not go there! Partly a matter of ancient Bill of Rights principles – proceedings in Parliament not to be impeached or questioned outside parliament – reinforced by questions of the difficulty of proof – even if they tried to question proceedings in parliament other things may have changed so could you really ever prove that the vote would have been different. Partly a matter of practicality – the “de facto officers” doctrine, and see once again Sinnathamby’s remarks about upsetting everything done in reliance on the law. In fact, the decisions in the section 24 cases – McKinley and McKellar – showed that the apportionment of MHRs between the States may well have been invalid for many of the years up till 1975. See http://www.austlii.edu.au/au/cases/cth/HCA/1975/53.html and http://www.austlii.edu.au/au/cases/cth/HCA/1977/1.html But what a pointless exercise to find how many laws that were passed might not have otherwise been passed, and then to craft remedies for all the people affected by those laws over the years! Sometimes you just have to accept that those in power are in power. At least we have the chance to change them every few years.
@ Jack A Randa
Thanks
I don’t quite understand why whoever gets the 6 and 3 year terms respectively is a matter of debate. If Ludlam was invalidly elected, the courts would have considered him ineligible to run in the first place and that Siewert would have been voted in the Senate’s 3rd place as she would have appeared to be the first candidate on the Greens’ list and be given a 6 year term. Steele-John would then be elected in 12th and be given a 3 year term.
It would have been different if the citizenship issue was never a thing and Ludlam resigned on his own accounts for whatever reason. Then the WA Greens would have nominated whoever they see fit and would have taken over the remaining of Ludlam’s 6 year term.
Raaraa: ” If Ludlam was invalidly elected, … Siewert would have been voted in the Senate’s 3rd place as she would have appeared to be the first candidate on the Greens’ list and be given a 6 year term.”
All true, but the Senate has already passed a resolution putting Siewert into the “class” of 3-year senators, and if you read s 13 literally they can only do that once and can’t revisit it. So it’s a matter of whether they read it literally or “gloss” it with some practical considerations. See the discussion between Kevin and me on Kevin’s site. Short answer – arguments both ways.
raaraa @ #25 Saturday, July 15, 2017 at 8:35 pm
It’s a matter for debate because the way the Senators were originally allocated to 3 and 6 year terms resulted not from any automatic procedure, or from anything the courts have ever said, but from a decision by the Senate to allocate them that way at the time (a decision taken not because it was right but because both major parties benefited). That decision was taken under a section of the Constitution that only refers to what happens after a DD (ie the Senate decides and can do what it likes) and does not say what happens if there is a mid-term recount.
It makes sense to upgrade Siewert to a six-year term if that decision is followed but that doesn’t mean it happens automatically without a fresh Senate decision, and there isn’t even any clear authority in the Constitution for the Senate to revisit its decision. It might be the Senate just decides to treat it as if it was a casual vacancy rather than muck around with the term lengths of elected Senators.
I kinda suspect the Senate will just ignore it which will end up working like a casual vacancy. Reassigning it indirectly sets a precedent that ineligibility recounts could also unelect other senators (since the logic is the same) and I suspect no one wants to touch that can of worms unless they have too (a major parties 1st or 2nd candidate being ineligible could potentially knock out 8 Senator in a DD eligibility recount, though it’s far less likely now without GTV at least).
Fairness has pretty much never been a consideration during term allocation for the Senate , if it was it would use the alternate election order for DDs, which it has declined too on both relevant occasions.
The Senate doesn’t have anything to do with the outcome of the recount and won’t be setting any precedent there. The recount won’t unelect someone, but if it were to do so, the Senate wouldn’t have any control over it. The High Court would probably just say to the unelected Senator, stiff cheddar, you’re out. But the Senate could be setting other precedents if it does reinterpret the order instead of treating it like a casual vacancy. Once there is a ruling that a person who won a 3-year term can in some circumstances be upgraded to a 6-year term, meaning that the original allocations can be revised, the question becomes whether there are other circumstances in which this is possible or whether (and if so why) it can only happen when there is a change of personnel.
A major party’s 1st or 2nd candidate being ineligible in a DD will typically just result in the first unelected candidate on their ticket being elected instead. This would also have been true under the old system. Unless margins are very, very close it would just mean everyone else on that party’s ticket moved up a notch, so that #2 is elected at the same stage as #1 originally was, #3 when #2 originally was (etc). There’s an interesting one with Lambie in Tasmania though – if she is found to have been ineligible, then so much of her personal vote leaks below the line that her #2 doesn’t have a quota on primaries in the countback and therefore is elected in the bottom half.
There’s something bemusing about getting the boot because someone else was ineligible. I mean it follows in that case they were never elected either and so would also lose all the benefits and potentially the Senate would attempt to reclaim their salary (I can’t imagine such a claim not being waived though).
On the issue of re-counts, they are conducted according to instructions of the Court, the Court in 1988 having chosen to use the procedures in the Electoral Act for deceased candidates in such situations. The Electoral Commission does not declare the result, it does the count, reports the result to the Court, and the Court authorises the outcome.
If a perverse result were produced by the re-count, such as an elected Senator being defeated in the process of replacing a disqualified candidate, the result would be reported to the Court which would hear submissions about what to do. In those circumstances the Court might adopt a different set of procedures. These matters are covered covered by court judgments and rulings, not by the Electoral Act. Parliament has not legislated on how to deal with the situation of disqualified elected Senators, to date leaving the Court to use case by case procedures to resolve the problem.
As I understand it, the Court informs the Senate of the new Senator elected by the re-count in place of the disqualified Senator. Given the circumstances of the WA re-count, I would expect legal argument before the Court when the new elected candidate is declared arguing for the Court to formally provide the Senate with a new ordered list of elected Senators. I am inclined to the view that the Court would provide the list for the Senate to consider rather than order the Senate to deal with the list in a particular way. Or it may take the method adopted by the Senate in 2016 and say the Senate’s resolution should be interpreted according to the new order of election, but i’m inclined to the Court leaving it to the Senate to resolve by a new vote.
That is because Section 13 gives very broad powers to the Senate to make the decision on the order of rotation. It is decided by a vote of the Senate, the elected Senators make that vote, and you would need a very strong case to get the High Court to overrule the vote of the elected Senators.
The decision made in 2016 was to allocate short and long terms based on order of election. If the Senate for no good reason re-visited that allocation mid-term, I could imagine the High Court taking an interest as Section 13 states “at the first meeting”.
However, as is likely to be the case in WA, the original order of election changed due to a re-count, I believe the Senate would be entitled to re-visit the allocation of terms once it received the new ordering. And if the same procedure for allocation as used in 2016 was used with the new allocation, I would be very surprised if the High Court would take an interest.
As I think Kevin raised, if one of these issues came up after the next election when the short term Senators had already faced election again, all sorts of strange scenarios are possible, like a new Senator being elected to an old term. That’s why the Court decides these issues case by case.
Hold the argument until the status of all the house of representatives members are checked, read section 44(i) particularly the last few words which really deserves a full blown investigation for instance can you actually resign citizenship of another nation or power without still being entitled to take it up again, is there any country that you are entitled to citizenship because of your heritage Greece? Israel ? is there any country that you are entitled to a vote Greece, France? A disqualification in the house of reps will have a dramatic impact and there are several members who’s qualifications are suspect.
antony green @ #31 Sunday, July 16, 2017 at 1:14 am
As I think Kevin raised, if one of these issues came up after the next election when the short term Senators had already faced election again, all sorts of strange scenarios are possible, like a new Senator being elected to an old term. That’s why the Court decides these issues case by case.
Yes, I raised that one in comments on my site. If this situation had arisen in the second half of Ludlam’s term and in the meantime Siewert had gone to an election and been defeated, then there would be a case that Siewert should be eligible to serve out the remainder of Ludlam’s term.
The other possibility is if it arose in the second half of Ludlam’s term and Siewert had in the meantime been re-elected for a new six year term. In this case Siewert would have been entitled to a six-year term from 2016 based on the principles behind the Senate’s previous allocation, but would have also been elected to a six-year term from 2019, creating a paradox. Presumably Siewert would be allowed to keep the longer mandate in that case and a second special count would be done without her as well.
Why “hold the argument”, Peter? First, whether any MHRs are ineligible is a totally different issue from the one in the Senate. (One that admittedly could have catastrophic consequences for the government if it arose in a swing seat.) Second, you are exaggerating the difficulty. Indeed “entitled to the rights or privileges of a subject or a citizen of a foreign power” looks very broad. Even at the time of federation people were saying maybe everyone would be disqualified because Japan, in an attempt to show its friendship with Britain, had declared that all subjects of Queen Vic were entitled to the privileges of a Japanese citizen. The realists said “of course the High Court won’t read it that broadly”. And they haven’t.
In Sykes v Cleary ( http://www.austlii.edu.au/au/cases/cth/HCA/1992/60.html ), referring to the dual citizenships of candidates Delacretaz and Kardamitzis, the joint judgment said:
OK – “reasonable steps to renounce” is all you need, or possibly even believing that you have taken reasonable steps. If the other country still regards you as a citizen, too bad.
Recently, in the aftermath of the BobDay case, the ALP candidate tried to challenge Sen Gichuhi’s eligibilty and 2 judges accepted without going into every nook and cranny of the law that she had done what she thought was necessary to renounce her Kenyan citizenship, and dismissed the challenge pretty tersely. That’s reported in the HC Transcripts at http://www.austlii.edu.au/au/cases/cth/HCATrans/2017/86.html So maybe the test is a bit looser than first stated. So unless someone can find another once-dual citizen in the parliament who has done bugger-all to renounce their non-Oz citizenship, I doubt that we have to hold anything much. [And Tone, who seems to have kept no evidence of his renunucation in 1993, has now obtained a convenient letter from the Brits to say “ah, but we kept a record”, so everything’s alright there…]
That quote actually explains Ludlam’s problem too. Note that was from 92 and he was naturalized in the 80s. At the time the naturalization process was sufficient.
But Australia started recognizing dual citizenship in 96 (?) , so if your other citizenship didn’t care about your Australian one, you had to make an effort to revoke it separately.
Hmmm. Our oath of allegiance included the words “renouncing all other allegiance” until 1986. If the other country did not recognise that, the person was, whether they intended it or not, a dual citizen – though the bit at the very end of the passage I quoted above may suggest that such people were ok anyway under s 44. [Just when was Ludlum naturalised? And when did the 1986 amending Act commence? I haven’t found that in the intertubes so far, but I’ll keep looking. Depending on the two answers, and how much weight you give to the last sentence in the quote from Sykes v Cleary, Ludlum may be panicking over nothing.]
After that, from the Australian point of view you could be a dual citizen if you had held the other one first and got naturalised here and the other country didn’t regard the taking of Aust citizenship as a renunication (Kenya did until some date), but an Australian who got naturalised elsewhere lost their Aust citizenship until 2002. It’s all so complicated it’s no wonder people make mistakes. S 44 really should be amended, but that would require the major parties to agree on some sensible amendments and then to overcome their defeatism about their ability to persuade Us, the People to vote yes.
Found it in a Parliamentary Library Research Note! The repeal of the words “renouncing all other allegiance” (which may by themselves have been enough to satisfy the High Court that someone who used that form of words was not a dual citizen) commenced 20th August 1986. So when did Scott L do the deed?
I dunno. He just said in his teens and so he could vote (so before he turned 18). Which is pretty much any time from somewhere in 83 until somewhere in 88.
I dunno. He just said in his teens and so he could vote (so before he turned 18). Which is pretty much any time from somewhere in 83 until somewhere in 88.
Yes I think it’s most likely that it was after the oath/declaration was amended, in which case he’s stuffed. But we need DETAILS!
I should qualify what I’ve said above. After the 3 judges in Sykes v Cleary remarked that “it is relevant that… a person who has expressly renounced” the other nationality in a ceremony “may well believe they have renounced” it, they then went on to find that the Swiss and Greek-born candidates, even though they had taken the old form of oath with the renunication, had failed to take some simple extra steps that were available to them and therefore were ineligible for election. But the 2 judges who heard the argument about Lucy Gichuhi seemed to be impatient with the attempt to disqualify her. It does seem that the current generation of HC Justices may not be as strict about para 44(i) as the 1992 generation. But if Scott L did neither the old form of swearing allegiance which included a renunciation nor any other form of renunciation, then he’s gone. Silly law, but all candidates since 1992 should have known about it.
He’s gone anyway since he resigned. I’d guess he took it after 86 since he decided not to fight it, and I can’t imagine he wouldn’t have sort legal advice first (I mean it’s pretty much impossible the party wouldn’t have asked him to wait until they did if nothing else even if he wasn’t inclined too).
The Ludlam Case raises an interesting question, the definition of Senate terms, whose main previous hearing was Vardon v O’Loghlin (in relation to revoting in a half-Senate election). Unless the recount for the 1987 NSW was finished after the 1st of July, this is the first time a Senate recount has occurred with a different previous 1st of July to that of the original Senate election being recounted and thus raises the question of which 1st of July the Senate term of the replacement Senator commences from.
I strongly suspect (despite not being a lawyer) that it would be ruled that, for the purposes of the term, the recount is retrospective and thus the 1st of July of the original election rather than use the Constitution`s specific determination of the terms of Senators on an individual basis to have separate terms for the new Senator.
I think from a theoretically point of view the recount is now a new election but a correction to the original election, so it follows that everything is considered from the point of view of the original election.
*not
The count is not an election. It is a court ordered procedure to fill a vacancy. We call it a re-count but it is not a re-count as defined by the Electoral Act, which is a procedure undertaken to finalise the result of an election.
Thanks for the responses on the 3 year vs 6 year term debate. Interesting responses and it has left me with more questions, but I guess it will warrant further reading on my part.
elaugaufein @ #35 Sunday, July 16, 2017 at 6:19 pm
This is an interesting issue that you have raised too. It would bring about a theoretical scenario where a member in 96 might have considered himself or herself purely a naturalised citizen having lost citizenship due to Australian laws, but suddenly having to deliberately renounce their former citizenship after the new legal changes.
How does all this go for someone born before 26/01/1949?
Are they considered both British and Australian?
Well Barney I can partly answer that. S 25 of the Nationality and Citizenship Act 1948 said:
The “he”s of course refer to she-people! There are lots of following sub-sections which you can find at http://www.austlii.edu.au/au/legis/cth/num_act/naca1948831948320/naca1948831948320.pdf is you really want to.
Effect of this was that someone like me, born in 1940, became an Aust cit, but people like my da-in-law who were British and had served in the war and came here quite soon after the war and married an Aussie girl had not done the 5 years here and were not Aust cits – a source of some irritation to him when he found out!
Until 1984 0r 86 or something (I used to know it but I can’t be bothered looking it up again) we were also notionally “British subjects”. But as to whether some of these people could also have been citizens of the UK at the same time (a concept that hadn’t previously existed was invented at the same time as the former colonies adopted their own separate citizenships) you’d have to look up their citizenship laws. Since they voted for Brexit I have totally lost interest in them and their laws – wanting to leave the EU largely because of the number of Polish immigrants, after every Pole who was able had fought for them in the war! ‘orrible lot! Don’t care about ’em any more!