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2025 IHC 494

Ahmed, etc vs Ministry of Interior through its secretary, etc

Citation2025 IHC 494
CourtIslamabad High Court
Case No.W.P. No. 963 of 2025
Date2025-06-26
Judge(s)Muhammad Azam Khan
ResultPetition Partly Allowed

MUHAMMAD AZAM KHAN, J.

1. Through the instant Writ Petition under Article 199 of Constitution of the Islamic Republic of Pakistan, 1973 (hereinafter referred to as the "Constitution"), the Petitioners seek direction to the Respondents to unblock their CNICs and issue valid Passports. The Petitioners also pray to declare blocking of their CNICs and Passports as illegal, unlawful, and without due process, and to order an inquiry into the arbitrary actions of the Respondents and impose penalties on responsible officials.

2. The brief facts of the case as per the contents of the petition are that the Petitioners are overseas Pakistanis by birth, born and raised in the Kingdom of Saudi Arabia. They are permanent residents of Karachi, Pakistan, and hold valid CNICs and Passports. Petitioner No. 1 [Ahmed] was born on 01.01.1972 in Makkah, Saudi Arabia. His late father, Fazal Ahmed, was born in Karachi in 1931 and was a Pakistani citizen by birth. Parents of Petitioner No. 1 held Pakistani Passports and CNICs. Petitioner No. 1 married Petitioner No. 2, Khadija, in 1998. They have five children (Petitioners No. 3 to 7) born in Saudi Arabia who are Pakistani citizens by descent under Section 5 of the Pakistan Citizenship Act, 1951. In 2022, Petitioner No. 1 visited the Pakistani Consulate in Jeddah to renew his CNIC but was informed that their CNICs had been blocked and was advised to visit Pakistan to resolve the issue.

On 31.01.2022, Petitioner No. 2 applied for the renewal of her expired Passport at the Pakistani Embassy in Jeddah and was issued Token No. 20102433135. When she went to collect her new Passport, she was informed that her CNIC and those of her family members had been blocked. In May 2024, Petitioner No. 1 visited NADRA Regional Headquarters in Karachi to resolve the issue but was refused any assistance. Petitioner No. 2 made several attempts to resolve the matter through various channels, but the Petitioners' CNICs and Passports remained blocked. Hence, the Petitioners filed the instant Petition.

3. The learned counsel for the Petitioners submits that the blocking of the Petitioners' CNICs and Passports has left them unable to exercise their fundamental rights as Pakistani citizens, including the right to travel, access banking services, and legal protections; that the actions of Respondents violate the Pakistan Citizenship Act, 1951, particularly Sections 3 and 5, which grant citizenship by birth and descent, respectively; that the Respondents have violated the Passport Act, 1974, and the Passport Rules, 2021, by failing to provide written notice for the cancellation of Passports (Section 8(2)) and by refusing to issue Passports without valid legal grounds (Rule 21(k)); that the Respondents have misapplied the National Database and Registration Authority Ordinance, 2000 (hereinafter referred to as the NADRA Ordinance, 2000), by blocking the Petitioners' CNICs without providing any valid legal basis or opportunity for a hearing; and that judicial precedents, including 2000 MLD 551, establish that the right to a Passport and CNIC is fundamental and legal, and any denial of these rights must be based on substantive legal grounds.

4. On behalf of NADRA (Respondent No. 2), a Report has been submitted stating that the instant Writ Petition is not maintainable, as there exists a factual controversy between the parties which must be resolved through trial by a competent Court of law. The Petitioners have a remedy to approach the Verification Board at the Regional Head Office Karachi or the Federal Government under Section 16 of the Pakistan Citizenship Act, 1951 read with Rule 13(a) of the Pakistan Citizenship Rules, 1952, for issuance of a Citizenship Certificate. The Report alleges that the Petitioners managed to obtain CNICs by posing as Pakistani nationals. Petitioner No. 2 was reported as a Burmese national by the Monitoring & Evolution Department (herein referred to as "MED") vide Report dated 30.12.2016. The NICOPs of Petitioner No. 2 and all family members were digitally impounded on the report of MED. That in fact, the . Petitioner No. 2 applied for a smart NICOP via Pak Identity on 28.10.2016 (TID No. 770000335770). The case was marked suspect and referred for verification. M&E recommended further verification of national status from the Intelligence Bureau ("I.B"), which reported on 14.05.2018 that the individuals were untraceable. Upon obtaining an updated address, the case was resent to the IB on 20.04.2022. M&E's Karachi regional department also conducted spot verification, reporting Petitioner No. 1 as a suspect Bengali national. A reminder was sent to the IB on 04.05.2023. The final I.B. report is still awaited. NADRA asserts it acted under Section 18 of the NADRA Ordinance, 2000, read with Rule 6 of the CNIC Rules, 2002 and Petitioners' CNICs have been digitally impounded in alien category being suspect Burmese/Bengali National. Lastly, it is prayed that instant petition may kindly be dismissed.

5. On behalf of the Directorate General, Immigration & Passports (Respondent No. 3), a Report has been submitted stating that the matter pertains to NADRA. As per the Passport tracking and reporting system, the machine-readable Passports issued to the Petitioners are active and expired.

6. I have heard the learned counsel for the parties and perused the record with their able assistance.

7. The admitted facts are that the Petitioners were duly registered by Respondent No. 2/Authority under the NADRA Ordinance, 2000 after Petitioner No. 1 had applied for issuance of their respective CNICs in accordance with the prescribed procedure and fulfilling the mandatory requirements. The registration was followed by the issuance of their respective CNICs, thereby acknowledging the fact that the Petitioners were citizens of Pakistan. The particulars of the Petitioners, as per NADRA's database, are as follows: SR.

NO. PETITIONERS CNIC PASSPORT 1 Ahmed (Father) 420003-014412-1 CB9994122 2 Khadija (Mother) 425013-335502-2 BW9995021 3 Yousaf (son) 420005-652481-9 CL9994812 4 Fawaz (Son) 420008-225620-9 CR9996202 5 Sohail (son) 422018-220856-7 CT9998562 6 Amal (son) 420001-814168-4 CC9991682 7 Albatool (son) 904030-163573-2 LD9995731 It is pertinent to mention herein that according to the submissions presented by the Respondent No. 2/Authority, the Petitioners were initially reported as Burmese National by the MED vide report dated 30.12.2016, however, the said Report has not been placed on record by the Respondent No. 2.

The Respondent No. 2 nonetheless has placed on record three reports dated 20.04.2022, 13.10.2022 and 04.05.2023.

8. The Respondent No. 2 vide Report dated 20.04.2022 intimated the Deputy DG Security, I.B., Islamabad to verify the details of the Petitioners in order to ascertain their national status as Petitioner No. 2 was untraceable at the previously given address. The proforma for verification was duly filled by Petitioner No. 2, wherein she submitted her valid and updated address via email dated 07.04.2022. Thereafter, the perusal of the second Report dated 13.10.2022 shows that the address of Petitioner No. 2 was acknowledged as correct. A distant relative of Petitioner No. 2, also residing at the given address, gave his written statement before the Respondent No. 2/Authority regarding her nationality. He informed that Petitioner No. 2 belongs to a Bengali-speaking family, thereby making her status doubtful in the eyes of the Respondents. Relying solely on the statement of her distant relative and his two witnesses, the Respondent No. 2 decided to keep the CNICs of the Petitioners blocked since 30.12.2016 based on the report rendered by MED. As the family linkages of Petitioner No. 2 could not be verified due to contradictions in her particulars, the matter was sent to the concerned verifying agency as per NADRA SOPs to determine her national status. The Report dated 04.05.2023 reveals that NADRA had again referred the matter to the I.B. for verification of national status of Petitioner No. 2. It has been observed by this Court with grave concern that the CNICs of the Petitioners have remained digitally impounded in the alien category since 2016 without following due process of law.

9. To determine the legality of the impugned action, the two relevant statutes are the Pakistan Citizenship Act, 1951 (hereinafter referred to as the "Citizenship Act") and the NADRA Ordinance, 2000. The Citizenship Act governs all matters relating to citizenship, while the NADRA Ordinance, 2000 deals with registration of all persons and for the establishment and maintenance of a multipurpose database, data warehouses, etc. For reference, Section 18 of the NADRA Ordinance, 2000 is reproduced below:- "Power to cancel, impound or confiscate cards. -- (1) A card issued under this Ordinance shall be the property of the Federal Government and may, by an order in writing under the seal of the Authority or an officer authorised by it in this behalf, be required to be returned and shall also be liable to be cancelled, impounded or confiscated by a like order: Provided that no order shall be made unless such person has been given notice in writing calling upon him to show cause why the order should not be made.

(2) An order under sub-section (1) cancelling, impounding or confiscating a card may be made only if there is reason to believe that-

(a) the card has been obtained by a person who is not eligible to hold such card, by posing himself as eligible;

(b) more than one cards have been obtained by the same person on the same eligibility criteria;

(c) the particulars shown on the card have been obliterated or tampered with; or

(d) the card is forged.

(3) Any person in respect of whose card an order under sub-section (1) has been made may, within thirty days of the order, appeal to the Federal Government against the order and the decision of the Federal Government in appeal shall be final: Provided that no order on such appeal shall be passed unless the appellant has been given an opportunity of being heard."

10. The aforesaid provision, specifically the proviso to Section 18(1) of the NADRA Ordinance, 2000 mandates issuance of a written show-cause notice prior to any impounding or cancellation action.

In the present case, Respondent No. 2 bypassed this requirement and failed to issue any show- cause notice or afford a hearing to the Petitioners, thus violating their rights under Article 10-A of the Constitution. Further, blocking of the Passports of the Petitioners have violated Section 8(2) of the Passports Act, 1974. An apparent embargo is also placed on the Federal Government under the said Act of 1974, whereby it has to give the Petitioners written notice and call upon them to show cause as to why an order should not be made against them. It is the fundamental right of the Petitioners to be given the right to fair trial and due process. In this regard, reliance is placed upon the judgement reported as Muhammad Aslam versus Member (Colonies) Board of Revenue Punjab Lahore and others (2019 CLC 1141), wherein the Lahore High Court has held as under: -

(A) Notice: Before any action is taken, the affected party must be given a notice to show cause against the proposed action and seek his explanation. It is a sine qua non of the right of fair hearing. Any order passed without giving notice is against the principals of natural justice and is void ab initio. Before taking any action, it is the right of the person to know the facts. Without knowing the facts of the case, no one can defend himself. The right to notice means the right of being known. The right to know the facts of the suit of case happens at the start of any hearing. Therefore, notice is a must to start a hearing. A notice must contain the time, place and date of hearing, jurisdiction under with the case is filed, the charges, and proposed action against the person. All these things should be included in a notice to make it proper and adequate. Whenever a statute makes it clear that a notice must be issued to the party and if no compliance or failure to give notice occurs, this makes the act void. Non-issue of the notice or any defective service of the notice do not affect the jurisdiction of the authority but violates the principle of natural justice.

(B) Hearing: - Oral or Personal Hearing- How Far Necessary: The second ingredient of audi alteram partem (hear the other side) rule is the rule of hearing. If the order is passed by the authority without providing the reasonable opportunity of being heard to the person affected by it adversely will be invalid and must be set aside. The reasonable opportunity of hearing which is also well known as 'fair hearing' is an important ingredient of the audi alteram partem rule. This condition may be complied by the authority by providing written or oral hearing which is the discretion of the authority, unless the statue under which the action being taken by the authority provides otherwise. It is the duty of the authority who will ensure that the affected party may be given an opportunity of hearing. However, the above rule of fair hearing requires that the affected party should be given an opportunity to meet the case against him effectively.

11. There is no cavil to the proposition that the CNIC carries a presumption of truth is attached with the CNIC and the particulars recorded therein. Moreover, when the law requires things to be done in a particular manner, then the same are to be done in that manner; and if anything is done contrary or in deviation to that, the same shall be deemed to have not been done at all. Thus, the requirement of issuing a show-cause notice and providing opportunity of hearing, prior to taking any action, was a mandatory prerequisite before taking measures under Section 18 of the NADRA Ordinance, 2000 or Section 8 of the Passports Act, 1974. The absence of such compliance renders the blocking of the Petitioners' identity documents legally untenable.

12. A contradictory Report dated 12.01.2022, submitted by the Deputy Superintendent of Police, Special Branch, Karachi stated that an inquiry was conducted in order to verify the particulars/statements given by the Petitioner No. 2, which have been found to be correct, on the basis of which, the status of the Petitioner No. 2 has been verified as Pakistani National. There is no cavil to the preposition that citizenship is a basic fundamental right, as it grants access to all other rights. Without it, a person becomes stateless, stripped of his dignity and recognition, and left without protection or belonging in the society. The record reveals that the CNICs of the Petitioners were digitally impounded on the basis of mere suspicion and doubt; nothing in the Reports could establish the alleged fraud and misrepresentation on the part of the Petitioners. Therefore, when a right gets accrued upon any person, the same cannot be withheld, stripped and/or taken away without due process of law or on mere suspicious or flimsy grounds. In this regard, reliance is placed on Fatima versus National Database and Registration Authority through Director General (PLD 2022 Balochistan 73), wherein it has been held that: - "The authority/respondent issued CNIC after fulfilling all codal and legal formalities which creates a right to the petitioner. Such right cannot be taken away on suspicious or flimsy grounds. When a right accrued to any person the same cannot be withheld or taken away without due process of law. Under the law the burden of proof lies on respondent to prove that petitioner is not citizen of Pakistan. Mere verbal assertion cannot be a ground to deprive a person from his fundamental rights. The right which is guaranteed by the Constitution cannot be taken away by notification."

13. Furthermore, the Respondent No. 2/Authority is empowered under the NADRA Ordinance, 2000 to cancel, impound, or confiscate a CNIC, only if there are sufficient reasons to believe that the Petitioners were ineligible and/or had obtained the card by falsely claiming eligibility. The CNICs of the Petitioners were digitally impounded in the alien category on the solitary Report dated 30.12.2016 rendered by MED, which has not been placed on record. It has been further alleged by the Respondent No. 2/Authority that the Petitioners had obtained their CNICs by falsely posing themselves as citizens of Pakistan at the time of processing of their CNICs, even though their status qua nationality is doubtful and suspected. Such stance taken by Respondent No. 2/Authority holds no veracity as neither NADRA, nor any intelligence agency is competent under the law to determine the citizenship of a person. In the case of Hafiz Hamdullah Saboor versus Government of Pakistan through Secretary Ministry of Interior, Islamabad (PLD 2021 Islamabad 305), the Islamabad High Court appropriately held that: - "As would be discussed later in more detail, the Authority nor the intelligence agencies are competent to determine the question of citizenship of a person...This Court has consistently observed that the Authority was bereft of jurisdiction to adjudicate upon a question which involves the determination of the status of a person as a citizen of Pakistan and that too, on the basis of reports received from intelligence agencies which are under the control of the Government." (Emphasis added)

14. Moreover, in the judgement cited supra, the Islamabad High Court, whilst shedding light on the arbitrary mechanism adopted by the Authority, stated the following: - "The respective agencies had reported that the petitioners were not citizens of Pakistan. The Authority issued notices. Perusal of the notices shows that particulars of the petitioners were filled in a pre-published standard form. Without disclosing the material to the petitioners and denying them the right of response on the touchstone of the principles of due process, the Authority either blocked or in some cases cancelled the CNICs of the petitioners. In a perfunctory manner the petitioners were deprived of being citizens of Pakistan merely because an intelligence agency had reported so. Despite the devastating impact of rendering the petitioners stateless, no reasoned order was passed by the Authority. The sole ground for blocking or cancellation of the CNICs of the petitioners was that they had falsely declared themselves as citizens of Pakistan." (Emphasis added)

In the instant Petition, the question of eligibility of the Petitioners, to hold valid CNICs, is in the context of their citizenship. The question to resolve here is whether the Respondent No. 1/Authority has been vested with the jurisdiction to initiate proceedings regarding eligibility stemming from citizenship? The answer is in the negative. In simple terms, the Respondent No. 2/Authority under the NADRA Ordinance, 2000, does not have the jurisdiction to initiate proceedings, whereby the eligibility of a person to hold CNIC based on his/her citizenship would be interrogated. It is pertinent to mention herein that the power to determine eligibility related to citizenship falls strictly within the exclusive jurisdiction of the Competent Authority/Federal Government under the Citizenship Act, 1951, particularly Section 16 read with the Citizenship Rules, 1952. Therefore, any action under Section 18(2)(a) of the NADRA Ordinance, 2000, concerning eligibility linked to citizenship, must be based on a prior determination by the Competent Authority/Federal Government in accordance with the Citizenship Act and its Rules. The Respondent No. 2/Authority under the NADRA Ordinance, 2000 cannot block, suspend, impound, or confiscate a CNIC on citizenship-related grounds unless a prior judicial order or final determination by the Competent Authority/Federal Government has been made under Section 16 of the Citizenship Act. In the case of Hafiz Hamdullah Saboor (supra), the Islamabad High Court held that: - "In the petitions in hand the question of eligibility is in the context of citizenship of the petitioners.

The Authority, pursuant to receiving information from one of the agencies, had purportedly initiated proceedings by blocking the CNIC or had recklessly adjudicated the status of an already registered citizen and consequently cancelled, impounded or confiscated the card. In essence the Authority, on mere suspicion or after adjudicating upon the status of a registered citizen, had either blocked or cancelled the cards, as the case may be. Was the Authority vested with jurisdiction to initiate proceedings regarding 'eligibility' stemming from 'citizenship'? The answer is an emphatic NO. It is noted that the question of 'eligibility' having a nexus with 'citizenship' could only have been adjudicated by the competent authority vested with jurisdiction in this regard and that too in the manner provided under the Citizenship Act read with the Citizenship Rules. The procedure adopted by the Authority whereby cases are referred to District Committees has no backing of the law and ultra vires the Citizenship Act and the Citizenship Rules. Once the person was declared as not being a citizen of Pakistan and adjudication under the aforementioned statute had attained finality only then would the Authority have been empowered to exercise its powers under the Ordinance of 2000, particularly under section 18(2)(a) ibid. As discussed above, the Citizenship Act is a complete self-contained statute governing all matters relating to and in connection with the status of a person as a 'citizen'. The legislature has clearly described the various categories of 'citizenship' and has provided statutory safeguards so that no person is deprived of the right of citizenship arbitrarily or in a reckless manner. No person can be deprived of citizenship except in the manner and subject to the conditions provided under section 16 of the Citizenship Act...The course of action adopted by the Authority in order to determine the eligibility of an already registered citizen on the basis of the citizenship of the latter is ultra vires the Citizenship Act read with the Citizenship Rules. The procedure regarding referring the cases to the purported District Committees is also alien to the statutory provisions and safeguards provided under the aforementioned statute. The legislature, in its wisdom, has not vested the Authority with the power to suspend or block a CNIC and as already noted, in order to do so a judicial order by a competent court would be required. Blocking a card would tantamount to suspending the citizenship of a registered citizen and exposing the latter to the horrendous consequences that follow. It is, therefore, declared that the Authority is bereft of jurisdiction or power to directly or indirectly determine or adjudicate upon the status and eligibility of a person's citizenship who has already been registered as a citizen. It is further declared that the exercise of powers conferred under section 18(2)(a) of the Ordinance of 2000 on the ground of eligibility relating to citizenship are subject to determination or adjudication made by the competent authority and in the manner provided under the Citizenship Act read with the Citizenship Rules. The Authority is bereft of the power to block, suspend, impound or confiscate a CNIC on the ground of eligibility relating to citizenship unless an order passed by the competent authority under subsection (6) of section 16 of the Citizenship Act has attained finality or the Authority has been informed that the competent authority has either confirmed renunciation of citizenship under section 14A or its loss under section 16A, as the case may be."

15. Hence, exercising power under Section 18 of the NADRA Ordinance, 2000 is subject to fulfillment of the requirement of due process i.e. issuance of a show cause notice followed by an opportunity of hearing. The Respondent No. 2/Authority is definitely not empowered to adjudicate upon the question of citizenship or status qua nationality of a person because it has to be exclusively dealt with under the Citizenship Act, 1951. Reliance in this regard is further placed on Abdul Qadir Vs. Federation of Pakistan and Others (2024 MLD 1774) wherein it is mentioned that "NADRA has no right under the National Database and Registration Authority Ordinance, 2000 to determine the question of citizenship which can only be adjudicated by the competent authority under the Act and the rules framed thereunder."

16. Moreover, in the case of Muhammad Umar Versus Federation of Pakistan, through Secretary, Ministry of Interior, Islamabad and 2 others (PLD 2017 Sindh 585), the High Court of Sindh raised the following observations regarding the applicability of Section 18 of the NADRA Ordinance, 2000: - "There will be no cavil about it that CNIC, being an important document of identification, should not go into the hands of an alien and NADRA is duty bound to check it and place embargo in respect of issuance of CNIC to a person who is not a Pakistani. It is astonishing that nothing in the entire NADRA Ordinance could be noted about blocking of a CNIC. In our view, the term 'BLOCKING' is an alien to the NADRA Ordinance. However, under section 18 subsection (1), NADRA authorities are empowered to impound a CNIC under certain conditions. The word 'impound' is defined in the online Second Edition of Black's Law Dictionary as under: "To take into the custody of the law or of a court. Thus, a court will sometimes impound a suspicious document produced at a trial".

From the above definition of 'impound', it can be said that NADRA may take into custody of a CNIC in certain cases and of course after fulfilling all the formalities and requirements mentioned in section 18 of NADRA Ordinance. CNIC issued to a person is actually a document and it is a property of Federal Government and any action regarding the same as provided under Section 18 can only be taken by the Federal Government or under its authority. The act of impounding a document is completed by taking possession of the document. Meaning thereby whenever, NADRA decides to impound a card under the directives of the Federal Government, they may direct the person to deposit CNIC to NADRA." (Emphasis added)

17. Therefore, it is necessary for the Respondents to follow the instructions given under Section 18 of NADRA Ordinance, 2000 and Section 8(2) of the Passports Act, 1974 in its letter and spirit. The relevant Sections in both enactments make it mandatory that without issuing notice to the concerned person, giving him/her a fair and proper chance of hearing, the authorities cannot put any ban, embargo or restriction on the digital record of a card-holder. Before concluding, it is imperative to examine the mechanism through which a CNIC may be cancelled, impounded, or confiscated merely on the basis of suspicion or the unfettered discretion of public functionaries, an approach that undoubtedly threatens the fundamental rights of the Petitioners, who are duly registered citizens of Pakistan. The arbitrary action taken by Respondent No. 2/Authority under the NADRA Ordinance, 2000 carries profound and grave consequences, effectively paralyzing the life of the affected individual, who is, by implication, deprived of the ability to exercise the fundamental rights guaranteed under the Constitution. Such a person loses the right of employment, education, health, access to his/her own bank accounts, the right to engage in trade, business or profession.

The family members are also equally affected. Reliance is placed on Fatima Vs. National Database and Registration Authority through Director General (PLD 2022 Balochistan 73), Hafiz Hamdullah Saboor (supra) and Hafiz Awais Zafar Vs. Judge Family Court, Lahore and 2 others (PLD 2022 Lahore 756).

18. Citizenship is the most valuable basic right of a human. A person once registered as a citizen cannot be deprived of citizenship otherwise than as is provided under the law. Moreover, Article 6 of the Universal Declaration of Human Rights (1948) affirms that every individual has the right to recognition as a person before the law. Article 15 of the same declares that everyone has the right of nationality, and that no one shall be arbitrarily deprived of his nationality nor denied the right to change his nationality. Citizenship is the primary bond between a State and an individual, enabling the latter to enjoy all rights guaranteed under the Constitution. The Citizenship Act and the Citizenship Rules, aligned with constitutional and international mandate, ensure due process. This fundamental right cannot be revoked arbitrarily or recklessly.

19. In the light of the above, this Court deems it proper for appropriate proceedings to be initiated by Respondent No. 2 before the Competent Authority/Federal Government under the Citizenship Act, which have to be concluded within a period of 30 days after providing full opportunity to the Petitioners. The act of blocking of CNICs and Passports of the Petitioners, without issuing show- cause notice and giving a chance of hearing, is hereby declared illegal and unwarranted under the law. The Petitioners are also directed to participate in the proceedings before the Competent Authority/Federal Government to facilitate the amicable resolution of their grievances. Moreover, if the intelligence agencies have credible information to the effect that ineligible persons have been registered as citizens, then they are required to report the matter along with credible material to the respective administrative Ministry or Division, as the case may be. The latter, if satisfied that a prima facie case is made out, would then refer the case for determination to the designated Competent Authority under the Citizenship Act read with the Citizenship Rules.

20. Keeping in view the detailed rationale revealed hereinabove, the Petition is partly allowed. The relevant authorities are hereby directed to restore the CNICs and Passports of the Petitioners for the time being till the decision of the Competent Authority/Federal Government is rendered upon the application of the Petitioner. The Petitioners are further duty bound to produce the relevant documents before the Competent Authority/Federal Government for consideration of their case.

Needless to mention herein that the Competent Authority, under the Citizenship Act read with the Citizenship Rules, would not be precluded from proceeding in the prescribed manner in case it is of the opinion that, based on credible material, a prima facie case is made out to deprive a person of citizenship or that the latter was not eligible for it. revisions by the competent authorities. Therefore, it is advisable to consult the official sources or legal professionals for the most up-to-date and accurate information.

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