The Complexities of Dual Citizenship Analysis

The prevalent conceptual approach used to assess multiple citizenship legislation is based on analysing a set of selected elements of the relevant legal framework. This paper argues that the evolution of legal rules on dual citizenship cannot be comprehensively analysed using methods created for comparative analyses and based on a narrow selection of legal rules that reflect either a restrictive or an open approach to dual citizenship. The simplified approach that focuses on the analysis of selected fragments of explicit legislation generates results that may be misleading. Therefore, the terms of reference for comparative study of multiple citizenship should be elaborated and extended. A comprehensive comparative method also has to take into account the migration context as well as relevant aspects of the legal and political context. This article explores these issues through an analysis of Polish legal rules in the field of dual citizenship.