49 231. With specific reference to the relationship between the right to equality and nondiscrimination and the right to nationality, the Court wrote that there is an inseparable connection between the obligation to respect and guarantee human rights and the principle of equality and non-discrimination, and this connection must permeate everything the State does. The State cannot act against a certain group of persons, whether for reasons of gender, race, color, language, religion or beliefs, political or any other opinion, national, ethnic or social origin, nationality, age, economic circumstance, property, civil 215 status, birth, or any other condition. 232. For its part, the Committee on the Elimination of Racial Discrimination has written that “deprivation of citizenship on the basis of race, color, descent, or national or ethnic origin is a breach of 216 States’ obligations to ensure non-discriminatory enjoyment of the right to nationality,” and that “in some cases denial of citizenship for long-term or permanent residents could result in creating disadvantage for them in access to employment and social benefits, in violation of the Convention’s anti-discrimination 217 principles.” 233. Regarding the situation in the Dominican Republic, the United Nations Independent Expert on Minority Issues said that she considered […] persons of Haitian heritage living in the Dominican Republic to be persons belonging to a minority group with rights as elaborated in the 1992 Declaration on the Rights of Minorities. They have that status regardless of whether they are duly recognized as citizens by the Dominican Republic or not. It is now recognized that the obligation of States with respect to the rights of minorities is not limited solely to its citizens. Non-citizens, including migrants, may under circumstances such as those in the Dominican Republic make legitimate claims to government to respect and protect their rights as minorities. States owe a duty to respect, protect and promote the full panoply of human rights of all within their territory with only a few limitations attaching to the status of non-citizens (certain political rights, access to public service, consular protection, the right to enter and remain in the country). Of critical importance is the right to non-discrimination on prohibited grounds as it applies to nationality. Once citizenship is acquired, it cannot be arbitrarily 218 withdrawn collectively on the basis of minority status or national origin. 234. The petitioners alleged that the Dominican authorities keep Dominicans of Haitian origin locked in undocumented status by repeatedly refusing to issue their legal documentation; they have also alleged that the actions taken by the Dominican authorities stripped the victims of their nationality, converting them into stateless persons. The State did not present any specific arguments on this point. 235. The situation of Benito Tide Méndez, William Medina Ferreras, Wilda Medina, Luis Ney Medina, Carolina Isabel Medina, Ana Lidia Sensión, Reyita Antonia Sensión Rafaelito Pérez Charles, Miguel Jean, Victoria Jean and Nathalie Jean, who were Dominican nationals and had the appropriate documentation, should be distinguished from that of Jeanty Fils-Aime, Nene Fils-Aime, Fiane Fils-Aime, Antonio Fils-Aime, Marilobi Fils-Aime, Endry Fils-Aime, Andren Fils-Aime, Juan Fils-Aime and Berson Gelin who, although born on Dominican soil –a country that subscribes to the principle of jus soli- did not have the documents that certified them to be Dominican nationals. …continuation particular racial, ethnic or national origin at a disadvantage compared with other persons, unless that provision, criterion or practice is objectively justified by a legitimate aim and the means of achieving that aim are appropriate and necessary”) 215 I/A Court H.R., Case of Servellón García et al. v. Honduras. Merits, Reparations and Costs. Judgment of September 21, 2006. Series C No. 152, paragraph 95. 216 CERD, General Recommendation XXX, Discrimination against non citizens, 65th session (2005), paragraph 14. 217 . CERD, General Recommendation XXX, Discrimination against non citizens, 65th session (2005), paragraph 15. 218 Annex 45. UN, Report of the Special Rapporteur on contemporary forms of racism, racial discrimination, xenophobia and related intolerance, Doudou Diène, and the independent expert on minority issues, Gay McDougall, Addendum, Mission to the Dominican Republic, A/HRC/7/19/Add.5, A/HRC/7/23/Add.3, March 18, 2008, paragraph 103. Annex B of the observations on the merits presented by the petitioners on April 16, 2009.