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The deputy speaker of the Bahraini parliament, Abd al-Hadi Marhoun, recently discussed his country's naturalization policy in a lengthy article in a local newspaper.

"We must preserve our unity and our nation. Our small strip of land and the high ratio of people per square kilometer (around 1,200) have made Bahrain into the most densely populated area after the Gaza Strip. This fact brings us to the contradiction between the demand to limit the birth rate - to provide greater opportunity for economic growth, and the demand to expand the granting of citizenship to foreigners, for demographic and political reasons. This is all the more so when the new citizens do not contribute anything from a social or economic perspective, but are a burden on society because they enjoy all the benefits and services."

Bahrain is to a large extent an exception. Like Iraq, around 70 percent of its residents - who total 700,000 - are Shi'ite, while 30 percent are Sunni. As with Iraq under Saddam Hussein, it is the Sunnis - in this case under the Khalifa family - who are in power. Approximately one fourth of the population are citizens (with the same ratio of Shiites and Sunnis) and the rest are foreigners or are stateless. This demographic structure nurtures the fears of the Khalifa family and the state's Sunni citizens, especially when a Shi'ite state such as Iran shares a border with Bahrain, and when Iraq is run by a mostly Shi'ite government.

Talk of a Shi'ite revolution in Bahrain occasionally surfaces and serves to justify suppression of the Shi'ite majority. For example, the number of Shi'ite soldiers - there are almost no Shi'ite officers - in the Bahraini army has been reduced, and on the other hand, the state considerably eased the citizenship laws for Sunni Arabs, who were even imported from places such as Syria, Jordan and Egypt. Sunni Arabs can obtain Bahraini citizenship much more easily than Bahraini residents of Iranian origin who are Shi'ites and have been living in the country for many years, without any civil status.

Restrictions lifted in Saudi Arabia

If the acquisition of citizenship by Arabs and foreigners is difficult and complex in Bahrain, as it is in other Arab countries, the acquisition of citizenship by Palestinian residents of these countries is extremely difficult. The argument that granting citizenship to Palestinians will affect their right of return is heavily employed by Arab countries, even when hundreds of thousands of Palestinians living in their domain are willing to accept citizenship in their country of residence and leave the right of return for the future.

Proof of this willingness can be found in an amendment to the Saudi Citizenship Law passed last October that went into affect this month. According to the amendment, Saudi residents who have been in the country for more than ten years and work in professions that the country needs - primarily doctors, engineers and technicians - can apply for citizenship.

There are thousands of Palestinian families in Saudi Arabia who meet these criteria. Indeed, when the applications started coming in, it turned out that thousands of Palestinians had submitted requests. This will be the first time that an Arab country - with the exception of Jordan - has been ready to grant citizenship to Palestinians, even if it comes with restrictions.

Arab League decisions over the years did determine that the children of Palestinian refugees could reside, work and study in Arab countries as if they were citizens of those countries, but the League decisions also determined that they would not be able to acquire citizenship.

Egypt divides Palestinian refugees into several groups: Those who fled there in 1948 and received a permit to stay that is renewed every five years; those who came in 1956 and also received five-year renewable permits; refugees who arrived after 1967, who received permits that are valid for one to three years; and students or licensed workers, who receive one-year permits.

Until 1978, Egyptian authorities made sure to honor the Arab League's directives and granted equal rights to Palestinian refugees, even if they did not receive citizenship. In 1978, Egyptian author and minister of culture Yussuf al-Sibayi was assassinated in Cyprus by Palestinian terrorists, members of the Abu Nidal group who said the assassination came because al-Sibayi had joined president Sadat on his visit to Israel.

That year marked a sharp turn in Egypt's attitude toward Palestinians in general and toward Palestinian residents of Egypt in particular; they essentially now had the status of foreigners, contrary to Arab League resolutions.

For example, a Palestinian who left Egypt for more than six months without a satisfactory reason - studies or work - could now lose his residency permit in Egypt. The children of an Egyptian woman who married a Palestinian were now classified as Palestinians, even if the woman's husband had died or left her. (There has been some relaxation in this this area of late.) In addition, it cost approximately $200 every time they renewed her children's residency permits, and pay for their medical care as if they were foreigners. The justification given for not granting citizenship to Palestinian children was that Egypt did not want to cause the "loss of the Palestinian identity" of the children.

Jordan, which granted citizenship to Palestinian refugees who arrived there from the West Bank, does not grant it to Palestinians who fled to the Gaza Strip. The result is that Jordanian women who marry Palestinian residents of Gaza cannot obtain Jordanian citizenship for their husbands and children.

A vague exception in Kuwait

As mentioned, the issue of citizenship for Arabs who are not from the country where they reside does not end with the Palestinians. Kuwait, for example, stopped granting citizenship to foreigners in 1966. Even Kuwaiti residents who for some reason were not counted in the 1965 census could not obtain citizenship until an amendment to the law was passed two years ago. Kuwaiti women who marry foreigners - Arabs or Westerners, Muslims or Christians - lose their citizenship until such time as they divorce or are widowed. Their children are not entitled to citizenship or to the rights included therein.

These lost rights do not end with voting and running for office; they are also denied a long list of benefits that citizens of the state enjoy. For example, anyone who is not a citizen of the state and does not have any other citizenship - several tens of thousands of people who were not counted in the population census or refrained from seeking citizenship in the 1960s for economic or family reasons - cannot obtain a permanent driving license, only a temporary one. These residents cannot attend government schools or obtain official government documents. They cannot get a job in government offices and they must pay for their health care, which is provided free to citizens.

Kuwait slightly amended its citizenship law this year; residents who have "performed lofty deeds on behalf of the country" may submit a request for citizenship. There is no definition of "lofty deeds" and the law remains vague. This enables the Kuwaiti interior minister to arbitrarily decide who will receive the sought after citizenship.

Two weeks ago the interior minister said that artists who have produced "lofty" creations in Kuwait also could submit a request.

In the United Arab Emirates, for the sake of comparison, they do not even acknowledge "lofty deeds." The country does not grant citizenship to foreign citizens, Arabs or not, unless it is someone with ties to the government.

It has always been easier to obtain citizenship in Saudi Arabia than in the other Gulf States. According to recent amendments to the law, women who marry non-Saudis can keep their Saudi citizenship, their minor children will be Saudi citizens and the grown-up children of a mixed couple will have to apply for citizenship. However, the new law stipulates that the interior minister can revoke a person's citizenship within ten years of its issue if he is convicted of a security or moral offense and is sentenced to two years in jail or a fine of 30,000 riyals.

"We must carefully assess the threat on the threshold of the identity of the nation and the citizen, his ability to support himself and the future of coming generations," the Bahraini speaker of parliament, Marhoun, wrote in his article. "We cannot legislate laws to create an artificial mosaic using force. Human beings and societies are not metals or chemical substances or natural colors that can be melted and reformed - this situation [of artificially granting citizenship] will lead to separation and social and ethical divides that will never be repaired."

And he was referring to granting citizenship to Muslim Arab residents of a Muslim Arab country. This difficulty explains, perhaps, why Israel's restrictions on granting citizenship to Palestinian spouses of Israelis hardly reverberated in the Arab world.