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 ap-proach 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 compar-ative 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.

This article analyses the protection of stateless persons under the most recent case law of the European Court of Human Rights (i.e. Hoti v. Croatia and Sudita Keita v. Hungary). The article briefly discusses the phenomenon of statelessness and the basic mechanisms governing it, as well as the general standard for the application of Art. 8 of the European Convention on Human Rights in cases involving foreigners who are stateless. This is followed by a discussion of the aforementioned ECtHR judgments, highlighting their principal findings. Thereafter the impact of UN standards concerning stateless persons on the ECtHR’s reasoning is assessed (based on the UNHCR’s third-party intervention in Hoti), as well as the differences between the approaches taken by the Strasbourg Court and the UN Refugee Agency. Finally, the treatment of foreigners in the Polish legal system is examined, and the importance of the Hoti and Sudita Keita judgments to the potential improvement of the situation of stateless persons in Poland is assessed.