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Court of Appeal Before Jackson, Lloyd Jones and Floyd LJJ, [2013] EWCA Civ 616 (see here), the Home Secretary argued that the decision made Pham de facto stateless (with nationality but denied the protection which should go with it), but not de jure stateless (without nationality under the laws of any state) and therefore it did not make him stateless within the meaning of section 40(4) of the 1981 Act. [read post]