How Other Countries Prove Citizenship: Does India Need a Single National Document?

A senior official of the Ministry of External Affairs on Wednesday said that a passport is merely a travel document and not conclusive proof of citizenship. Although passports are issued only to Indian citizens, the Ministry clarified that the document should not be treated as definitive proof of citizenship.

The statement has triggered a political row, with Opposition parties questioning the government over what documents conclusively establish Indian citizenship. The controversy is the latest chapter in the broader debate over citizenship that has dominated Indian politics in recent years, particularly following the Citizenship Amendment Act (CAA) and the Special Intensive Revision (SIR) exercises carried out before elections.

Across the world, citizenship is generally determined through one of two legal principles: jus sanguinis (right of blood) and jus soli (right of the soil). These determine citizenship based on parentage and place of birth, respectively.

Outlook takes a look at how these principles are applied across different countries and how citizenship is determined in India.

The US System

The United States follows a combination of jus soli and jus sanguinis, with birthright citizenship serving as the primary principle. Any individual born within the territory of the United States automatically becomes a US citizen, regardless of the immigration status of their parents. This right is guaranteed under the 14th Amendment to the US Constitution.

The US also recognises jus sanguinis. Children born outside the United States to American citizens may acquire citizenship, provided their parents satisfy certain legal requirements.

According to the website of the US Embassy and Consulates in India, a valid US passport, a US birth certificate, a Consular Report of Birth Abroad, a Certificate of Naturalization, or a Certificate of Citizenship all serve as proof of US citizenship.

UK Rules

The United Kingdom primarily follows the jus sanguinis principle. A child born to a British citizen is generally eligible for British citizenship, while birth within the UK alone does not automatically confer citizenship.

British citizenship laws have evolved over time, reflecting the country's imperial history and successive immigration reforms.

According to the UK government's official website, a British passport, a UK birth certificate, or a certificate of naturalisation or registration can all serve as proof of citizenship.

European Models

Most major European countries also determine citizenship primarily through the jus sanguinis principle, with citizenship inherited from parents. Unlike the United States, no European country grants unconditional jus soli. Instead, many countries supplement descent-based citizenship with conditional birthright provisions and naturalisation pathways.

Across much of Europe, passports and birth certificates serve as the primary documents establishing citizenship. National identity cards are also standardised across the European Union and commonly function as proof of citizenship.

Some countries maintain dedicated citizenship registries. Nations such as Austria and Croatia issue separate Citizenship Certificates to officially establish an individual's nationality.

India's Multiple-Document Approach

India, like most European countries, primarily follows the jus sanguinis principle. Citizenship is governed by the Citizenship Act, 1955, although the legal framework has evolved significantly to accommodate migration during Partition, later amendments, and the unique circumstances of the North East.

Unlike many countries, India does not issue a single, universally recognised national citizenship card. Since most Indians acquire citizenship automatically through birth or descent, citizenship is established through what is commonly described as a "multiple-document approach."

Under this system, an individual's citizenship is verified by establishing a chain of facts relating to their date of birth, place of birth, and parentage using a combination of official records.

When government processes, such as a National Register of Citizens (NRC) exercise, require proof of citizenship, the burden of proof rests on the individual. In the absence of a standalone citizenship document, applicants are typically required to submit a combination of birth certificates, parental records, educational certificates, and other government-issued documents to establish eligibility under the law.

The Debate Ahead

Citizenship emerged as one of the defining political issues during Prime Minister Narendra Modi's second term, particularly following the passage of the Citizenship Amendment Act and the proposed NRC exercise.

With the government's stated commitment to identifying and removing illegal immigrants—especially in border regions such as West Bengal and the North East—the debate over citizenship is likely to remain politically significant.

Special Intensive Revision (SIR) exercises conducted before Assembly elections in several states have also brought citizenship into focus, as electoral authorities have sought to verify voter eligibility and revise electoral rolls.

The government has repeatedly faced criticism from Opposition parties and civil society groups over its citizenship policies. The recent clarification that a passport is not, by itself, conclusive proof of citizenship has further intensified the debate.