Extract of joint submission:
“We have found there to be a widespread misunderstanding of this area of law on the part of many people – including many lawyers, policy advocates, campaigners and parliamentarians. That misunderstanding has done and continues to do considerable harm to people born and growing up in this country. That harm is done in several ways. Many people are poorly advised and assisted, or otherwise misled, into losing their citizenship rights. Moreover, the practice of, particularly, the Home Office in introducing and maintaining significant barriers that obstruct and deny the citizenship rights of many people has frequently gone unchallenged. It is even wrongly given support in much advocacy relating to citizenship rights. Parliament has acceded to Home Office legislation establishing barriers to citizenship rights without proper scrutiny of the flawed analysis presented by Ministers in seeking to explain or justify that legislation.
 Government policy – including in setting fees – wrongly treats the right to register as a British citizen as if an aspect of or akin to the discretionary power to naturalise an adult migrant; and this false conflation is repeatedly relied upon in Ministerial statements seeking to justify above-cost fees charged, including to children born in the UK with statutory entitlements to British citizenship. Yet, many advocates and campaigners similarly conflate these distinct provisions giving false credibility to a policy that does considerable harm to many children deprived of their citizenship rights by a fee of £1,012.
 For example, it did so in relation to the introduction of the statutory requirement of good character for registration by the Immigration, Asylum and Nationality Act 2006 as briefly described in our joint submissions to the Joint Committee on Human Rights for its consideration of the British Nationality Act 1981 (Remedial) Order 2019, see: http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/human-rights-committee/draft-british-nationality-act-1981-remedial-order-2019/written/102809.pdf