51 (c) The Central Electoral Board insists that a series of documents must be presented in order to proceed with a late declaration of birth. These requirements violate not only rights contained in the Constitution and laws deriving from it, but also rights enshrined in the American Convention, because they are difficult to comply with, involve expenditure and constitute obstacles that prevent the enjoyment of the right to nationality of most children in the same situation as the children Dilcia and Violeta; namely, Dominicans of Haitian origin; (d) The inconsistent procedures of the civil status registrars did not allow the children Dilcia and Violeta to obtain their birth certificates for four years and four months, even though they had complied with the requirements established for children under 13 years of age; (e) The delivery of the birth certificates to the alleged victims in the instant case was the result of a decision of the State, which could possibly deny their validity in the future, owing to the way in which they were granted, and (f) The collaboration agreement signed by the State at the end of 2001 eliminated several requirements that tended to hinder the late declaration procedure; however, it retained the principal requirement of the parents’ identity cards, which is a contradiction to the principle of ius soli. 112. that: Regarding Article 24 of the American Convention, the Commission indicated (a) States may establish distinctions in the enjoyment of certain benefits between its citizens, foreigners in a regular situation, and foreigners in an irregular situation. Nevertheless, to do this, the content and scope of the norm must be examined in detail, together with its justification and consequences; (b) The treatment that the alleged victims received was due to considerations relating to their origin, their name and the migratory status of their parents. Policies and practices that are deliberately discriminatory, as well as those that have a discriminatory impact on a specific category of individuals are prohibited, even if the discriminatory intention cannot be proved; (c) The secondary legislation applicable in this case is open and allows the authorities of the Central Electoral Board and the Civil Status Registry Office to establish the requirements for late declarations of birth and to apply them discretionally, and (d) Although it has indicated that some officials may have shown a discriminatory attitude, the State has not investigated or penalized such practices. 113. With regard to Article 3 of the Convention, the Commission stated that:

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