47 wrote that “the right to identity is consubstantial to the attributes and human dignity. Consequently it is an enforceable basic human right erga omnes as an expression of a collective interest of the overall international community that does not admit derogation or suspension in cases provided in the American 199 Convention on Human Rights.” 225. For its part, the European Commission on Human Rights has written that “[a] State’s denial of citizenship combined with the issuance of an expulsion order may create a presumption that the 200 purpose of the denial was to achieve the expulsion of a citizen.” 226. Finally, on the subject of the right to equality and non-discrimination, the Commission and the Inter-American Court have repeatedly maintained that the right to equality and nondiscrimination is 201 the central, basic axis of the inter-American human rights system. The Commission has observed that 202 there are a number of concepts of the right to equality and non-discrimination. One concept is the prohibition against an arbitrary difference in treatment –with difference in treatment understood as 203 distinction, exclusion, restriction or preferencewhile another concerns the obligation to create conditions of real equality for groups that have been historically excluded and are at greater risk of 204 becoming victims of discrimination. The Commission understands that although both views may be present in certain cases, each warrants a different response from the State and different treatment under 205 the American Convention. To this must be added the fact that under the different concepts of the right to equality, a State’s actions and omissions may be with respect to rights recognized in the American Convention or they may be with respect to any undertaking of the State that does not affect the 206 enjoyment of Convention-protected rights. 227. The Commission has written the following with respect to the principle prohibiting an arbitrary difference in treatment: While the doctrine of the inter-American human rights system, like that of other human rights regimes, does not prohibit all distinctions in treatment in the enjoyment of protected rights and freedoms, it requires at base that any permissible distinctions be based upon objective and reasonable justification, that they further a legitimate objective, regard being had to the principles which normally prevail in democratic societies, and that the means are reasonable and 199 See, inter alia, OAS, “Inter-American Program for a Universal Civil Registry and “the Right to Identity.” Resolution AG/RES. 2286 (XXXVII-O/07) of June 5, 2007; resolution AG/RES. 2362 (XXXVIII-O/08) of June 3, 2008, and resolution AG/RES. 2602 (XL-O/10) of June 8, 2010 on the follow-up of the program. Here, the Inter-American Juridical Committee observed that while the American Convention on Human Rights does not establish a right to identity by that name expressly, as has been pointed out, it does protect the right to a name, the right to nationality and the right to protection of the family. See in this regard, Inter-American Juridical Committee, Opinion “on the scope of the right to identity”, resolution CJI/doc. 276/07 rev. 1 of August 10, 2007, paragraphs. 11.2, 12 and 18.3.3, ratified by resolution CJI/RES.137 (LXXI-O/07) of August 10, 2010. 200 European Commission on Human Rights, X v. Federal Republic of Germany, Appl. 3745/68, 31 Collection of Commission’s Decisions 107, 110. 201 IACHR, Application filed with the Inter-American Court of Human Rights, Case of Karen Atala and Daughters v. Chile, September 17, 2010, paragraph 74. 202 See, inter alia, IACHR, Application filed with the Inter-American Court of Human Rights, Case of Karen Atala and Daughters v. Chile, September 17, 2010, paragraph 80. 203 See, inter alia, UN, General Comment No. 18, General Comments adopted by the Human Rights Committee, Nondiscrimination, 37th session, U.N. Doc. HRI/GEN/1/Rev.7 at 168 (1989), paragraph 7; I/A Court H.R., Juridical Condition and Rights of Undocumented Migrants. Advisory Opinion OC-18/03 of September 17, 2003. Series A No. 18, paragraph 92; IACHR, Fourth Progress Report of the Rapporteurship on the Rights of Migrant Workers and Their Families in the Hemisphere, OEA/Ser.L/V/II.117, Doc. 1 rev. 1, Annual Report of the IACHR 2002, March 7, 2003, paragraph 87. 204 See, inter alia, IACHR, Application filed with the Inter-American Court of Human Rights, Case of Karen Atala and Daughters v. Chile, September 17, 2010, paragraph 80. 205 See, inter alia, IACHR, Application filed with the Inter-American Court of Human Rights, Case of Karen Atala and Daughters v. Chile, September 17, 2010, paragraph 80. 206 See, inter alia, IACHR, Application filed with the Inter-American Court of Human Rights, Case of Karen Atala and Daughters v. Chile, September 17, 2010, paragraph 80.