R (on the application of Enein) v Secretary of State for the Home Department

Citizenship – British citizenship. It was within the defendant Secretary of State's broad discretion to decide that, as a matter of policy, he normally would consider an applicant for naturalisation who had not complied with immigration requirements in the ten years before his application, including by working in the UK without permission, to not be of good character. The Administrative Court held that did not render the part of the three year lawful residence requirement in para 3(d) of Sch 1 to the British Nationality Act 1981 otiose, as it was a separate and different requirement.

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