By Choo Chin Low , GLOBALCIT Country expert
As reported by Singapore media (Straits Times) on 8 October 2017, the country celebrated the 60th anniversary of the establishment of Singapore citizenship through the 1957 Singapore Citizenship Ordinance. The ordinance was significant because it laid the foundation of the single citizenship regime in the country, which has remained in force in contemporary Singapore. Since the end of the 1990s, the single citizenship principle has been widely debated due to increased pressure from both immigrant and emigrant communities. The People’s Action Party (PAP) government has maintained the 60-year-old norm, citing ‘national identity’ as the main reason and rejecting the proponents’ rationale of economic pragmatism. As 2017 marks the 60th anniversary of the 1957 Ordinance, this contribution discusses the origins and rationale of Singapore’s dual citizenship restrictions. What factors reinforce the institutional norm? Why is it difficult for contemporary Singapore to introduce dual citizenship?
Background of Singapore’s Single Citizenship Principle
To understand the dual citizenship debates, it is important to examine the first citizenship ordinance of Singapore. The nation’s position on its single citizenship principle has been consistent since the inception of the 1957 Citizenship Ordinance. This has remained the governing principle through several stages of Singapore’s constitutional development – internal self-government (1959–1963), independence through its merger with Malaysia (1963–1965) and its separation from Malaysia (post-1965). Prior to 1957, the citizenship law in force was the British Nationality Act of 1948, with the native-born population of the colony of Singapore known as British subjects. This 1957 Ordinance was an important milestone because it created the status of ‘citizens of Singapore’ prior to Singapore’s full independence through the merger.
When the ordinance came into force on 1 November 1957, the single citizenship principle was the guideline. Foreigners had to renounce their citizenship and take an oath of allegiance and loyalty to Singapore in order to become Singapore citizens through registration and naturalisation. To avoid statelessness, applicants were granted Singapore citizenship if the countries of origin only allowed their citizens to relinquish their citizenship after acquiring another one. They were given a 12-month time frame to divest themselves of any foreign citizenship from the date of becoming Singapore citizens (Article 19, 1957 Singapore Citizenship Ordinance). The acquisition of citizenship in a foreign country or the voluntary exercise of any associated rights would result in the loss of Singapore citizenship (Article 21, 1957 Singapore Citizenship Ordinance). Dual nationality within the British Commonwealth of nations was allowed for citizens of the United Kingdom and Colonies (CUKC) who also held Singapore citizenship. The British Commonwealth did not fall under the category of a foreign country.
Dual nationality within the Commonwealth was reversed when Singapore gained full independence through its merger with the Federation of Malaya, Sabah and Sarawak to form the larger Federation of Malaysia in 1963. A strict single citizenship regime was introduced under the 1963 Malaysia Act. Dual citizens (CUKC–Singapore) lost their British nationality by law if they became Malaysian citizens on Malaysia Day (16 September 1963). The 1957 Ordinance ceased to exist, and citizenship provisions were governed by the Constitution of the State of Singapore of 1963 (which was interpreted together with the Malaysia Act of 1963). The single citizenship principle has remained in force in Singapore even after the state separated from Malaysia in 1965. The Republic of Singapore became an independent state within the Commonwealth. Dual citizenship became an almost impossible policy option because Singapore’s Constitution imported some aspects of the Malaysian Constitution in the post-separation period, especially the citizenship provisions.
Dual Citizenship Debates in Singapore
The current citizenship debates in Singapore are twofold, involving emigrant dual citizenship and immigrant dual citizenship. The government’s stand on its citizenship policy is clear; no Singaporean is entitled to dual citizenship. The case of immigrant dual citizenship was rejected earlier. In a 2006 parliamentary session, single citizenship was upheld as it served as an assurance that immigrants would not use Singapore ‘merely as a springboard to better offers overseas’. The need to attract ‘quality immigrants’ for economic development and boosting the dwindling birth rates could not justify the relaxation of citizenship policies as Singapore must be careful to ‘avoid the equation that quality equals loyalty’.  Since Singapore is a nation of immigrants, it is sceptical about their loyalty. Singapore wants to ensure that it is not ‘merely a springboard nation’ that Singaporean-born second generation immigrants leave to seek better opportunities and to avoid being enlisted in the National Service (NS). The need for such an assurance is legitimate. In assessing Singaporeans’ loyalty, the litmus test entails 1) requiring all potential citizens to forsake any other citizenship and 2) requiring the second-generation male permanent residents (PRs) to serve in the NS upon reaching 16.5 years of age. New citizens are thus equal to and have similar obligations as Singaporean citizens.
Similarly, emigrant dual citizenship was viewed with reservations. Dual citizenship has negative implications for Singaporean identity and the NS. Since the founding of the British settlement on the island in 1819, Singapore has been a colony (and later a nation) of immigrants resulting in an increasingly multicultural character of its population. In 2013, when asked in a parliamentary session whether Singapore was prepared to accept dual citizenship, the Deputy Prime Minister replied, ‘Singapore is a small and young nation. It is all the more important that we are clear that our citizens have a long-term commitment to building a future together here. Allowing Singaporeans to retain or acquire a second citizenship is unlikely to enhance that commitment, but could dilute it. We are not in a situation where allowing Singaporeans to hold dual citizenship would strengthen us as a people or a nation’.
When asked in a parliamentary session whether the time was right to review the citizenship policy in 2016, the Minister for Home Affairs echoed the Deputy Prime Minister’s statements (as quoted above). He added ‘Singaporeans enjoy rights and privileges as citizens, and are expected to uphold the duties and responsibilities that come with citizenship. Allowing Singaporeans to retain or acquire a second citizenship is unlikely to enhance that commitment, but could instead dilute it’. As argued by the proponents of dual citizenship during a debate on the President’s Address, obtaining foreign citizenship is often not a matter of choice. Overseas Singaporeans acquire foreign citizenship for employment or marriage purposes, which may not be tantamount to disloyalty. However, the official position prohibits obtaining foreign citizenship for reasons of convenience or expediency.
Singapore grants temporary dual citizenship to 1) children born overseas and 2) children of PRs. The major source of dual citizenship involves dual citizenship acquired at birth for children acquiring Singapore citizenship by descent. Under the option model, children born overseas are required to choose between their Singapore and foreign citizenship upon reaching the age of 21. Their failure to divest themselves of any foreign citizenship upon attaining the age of 22 will result in the forfeiture of their Singapore citizenship (Article 122 (4), Constitution of the Republic of Singapore). The second source of dual citizenship involves children of PRs of Singapore, who have acquired Singapore citizenship by registration. Article 124 (1) allows the children of the new Singapore citizens to be registered as citizens. Article 126 (3) states that children of the registered Singapore citizens are allowed to keep their foreign citizenship until they turn 21, when they will have to choose which citizenship to retain. Unless they renounce their foreign citizenship upon attaining the age of 22, they will cease to be citizens of Singapore. Under the constitution, children of successful applicants for Singapore citizenship are not required to obtain PR status to be eligible for citizenship. These children are subsequently granted Singapore citizenship together with their parents. From 1987 to 2012, on a yearly basis, approximately 3,400 minors were granted Singapore citizenship and also held foreign citizenship.
Though these provisions (Articles 122 and 124) have increased the cases of dual citizenship among minors, the Singapore government restricted dual citizenship by stipulating the option model and a strict expatriation clause. Minors holding dual citizenship are required to fulfil their NS obligations before they are allowed to divest themselves of Singapore citizenship.  The government may withhold the renunciation request if the person is subject to the Enlistment Act and has not rendered the mandatory full-time service (Article 128 (2), Constitution of the Republic of Singapore). All Singapore citizens and PRs between the ages of 16.5 and 40 years are subject to the 1970 Enlistment Act and liable to render two years of full-time service (Article 12). Failure to fulfil the obligation will result in the defaulters being guilty of an offence and being liable to a $10,000 fine or imprisonment not exceeding three years or both (Article 2, Enlistment Act).
Dual citizens would remain liable for any breaches of the Enlistment Act even if they wish to renounce their Singapore citizenship upon reaching the age of majority. Neither overseas residence nor the possession of foreign citizenship could serve as an exemption. This rule aims to prevent dual citizens from evading their NS obligation by renouncing their Singapore citizenship. The performance of the obligation is closely related to the essence of Singapore citizenship based on civic republicanism. In a 2016 parliamentary session, the government reiterated its position: ‘Singapore adheres to the fundamental principles of universality and equity for NS. All Singaporeans are expected to fulfil our NS obligations as citizens. It would not be fair to allow citizens to avoid NS just because they reside overseas’.
Singapore’s reluctance to converge to the global trend towards toleration of dual citizenship is caused by five issues. First, PAP parliamentarians strongly oppose dual loyalty, and grassroots activism is insufficient to generate a potent transformational force. Any reform requires a bottom-up initiative or a top-down effort. In Singapore’s case, a top-down reform is almost impossible under the current government due to the ‘national identity’ legacy, while a bottom-up reform is far from desirable given the limitation of the rights-based approach in the authoritarian state. The emigrant community has little impact on the policy-making of the state and pro-reform forces are not strong enough to challenge the existing policy. No motion on this issue has been tabled in the parliament despite being widely discussed in the media. The issue had been brought up during a few parliamentary oral sessions in 1999, 2000, 2006, 2013, 2014 and 2016 but had been adamantly turned down by the ruling PAP.
Second, the status of honorary citizenship was created to attract high-level foreign professionals. The Honorary Citizen Award is granted to foreigners who have made outstanding contributions to Singapore in the areas of business, science and technology, information and communication technology, education, health, arts and culture, sports, tourism, community service or security. The award includes socioeconomic rights, such as the right to reside, work and purchase property in Singapore. It neither confers voting rights nor carries obligations, such as enlistment in the NS. The argument to use dual citizenship to either attract foreign talents or retain local ones does not find resonance with the government, even with an ageing population and a low fertility rate. Unconditional application of dual citizenship for all citizens is unacceptable. Dual citizenship on a selective basis, based on meritocracy, is also rejected. Rather than selectively allow dual citizenship (such as in the case of Taiwan, officially called the Republic of China), Singapore’s single citizenship principle adheres to universality and equity. Taiwan applies selective tolerance of dual citizenship for its natural-born citizens and qualified naturalised citizens. Foreign nationals are exempted from the requirement to renounce their foreign citizenship if they are high-level professionals in the fields of technology, economics, education, culture, arts and sports, whose specialties are deemed to serve the interests of the ROC (Article 9 (2), ROC Nationality Act, 2016). Any concept of dual citizenship with reduced rights and responsibilities is unacceptable in Singapore. However, honorary citizenship is not tantamount to dual citizenship.
Third, the practice of extraterritorial citizenship was introduced in terms of political participation of overseas citizens. Singapore’s citizenship regime has been liberalised to allow overseas voting by its citizens since the 2006 general elections. It should be kept in mind that loyalty still matters in the exercise of this limited franchise. Overseas Singaporeans, whose names are included in the electoral registers of foreign countries, are excluded from the diaspora franchise. However, there is a difference between those who choose to vote in a foreign election and those who decide not to do so. A 2008 constitutional amendment to the Parliamentary Elections Act entitles overseas Singaporeans to vote as long as they do not participate in a foreign election. In other words, the disqualification criteria to overseas voting are aligned to the circumstances under which a citizen may be deprived of his or her citizenship under Article 135(2) of the Constitution. Article 135 (2) governs the deprivation of citizenship based on the voluntary claim and exercise of any rights which are accorded exclusively to the citizens of the country, including the exercise of a vote in any political election outside Singapore. Extraterritorial practices of Singapore citizenship are still based on undivided loyalty. A single allegiance, rather than domicile, is the precondition for citizenship rights. Domicile alone is not a sufficient factor in determining citizenship rights. Foreign nationals holding a PR status in Singapore are not entitled to vote.
Fourth, the state is more interested in encouraging integration and promoting active citizenship, in which dual citizenship does not fit. A naturalisation assessment called the Singapore Citizenship Journey was introduced in 2011, consisting of four components: an online component, a tour of Singapore’s historical landmarks and national institutions, a community engagement session and finally, a citizenship ceremony. National identity is the crux of Singapore’s statehood. Immigrant dual citizenship is questionable when Singapore is used merely as a ‘springboard’ nation. There have been concerns about immigrants competing with locals for job opportunities. The case of emigrant dual citizenship is less compelling as the government has given overseas Singaporeans a political voice with the introduction of external voting.
Finally, Singapore has always held reservations about dual citizenship. Singapore’s non-convergence is fathomable as long as its concern for national identity still prevails 60 years after the foundation of Singapore citizenship. In defence of national identity, the key concern is whether ‘Singapore, as a relatively young nation, has a strong enough identity to evoke the loyalty and sacrifice of our citizens, especially in times of war, if they hold two passports’. The single citizenship principle originated from the 1957 Citizenship Ordinance, and this norm was further reinforced by the 1963 Malaysia Act. The post-separation Constitution of Singapore did not make any significant changes to the underlying principle. Instead, dual citizenship restrictions in Singapore have been enforced in a stricter sense through a series of constitutional amendments after 1965. It is difficult to imagine a policy shift to a more liberal dual citizenship regime when the 60-year-old norm is deeply embedded in the state’s constitutional and historical legacies.
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