inherently justify differential treatment between nationals and foreigners, as is self-evident. 4 Justice Hsu Chih-hsiung, in his dissenting opinion on J.Y. Interpretation No. 768, discussed nationality and the subject of constitutional rights, noting: "For those who are not citizens, namely foreigners (persons without R.O.C. nationality, including stateless persons), especially foreigners residing within the territory of a sovereign state, their rights are generally recognized by constitutional law as subject to the inherent and universal nature of human rights. The Constitution’s protection of rights applies to foreigners insofar as their nature allows. The issue remains the scope and extent of rights protection for foreigners, which must be determined on a case-by-case basis. In summary, constitutional scholarship has evolved from discussing whether constitutional human rights protections apply to foreigners to exploring the specific human rights and the extent to which they are protected for foreigners." 5 Other studies have analyzed the "quasi-citizenship" status of foreigners and suggest that a further distinction should be made among foreigners based on whether they reside in the country, hold permanent residency, are regular residents working in the country, are short-term tourists, or are illegal immigrants. For legal residents, their rights concerning personal freedoms should generally align with those of citizens. However, regarding social rights, given that the state prioritizes the welfare of its citizens, reasonable differential treatment should be allowed. Nevertheless, foreigners who have acquired quasi-citizenship, such as foreign spouses of nationals or those with permanent residency, should be accorded treatment equivalent to that of citizens. 67 Li Dong-ying, "On the Fundamental Rights of Foreigners – A Comparative Study of German Law," Constitutional Times, Vol. 42, No. 3, January 2017, pp. 251-253. 5 Interpretation No. 768, Separate Opinion by Justice Hsu Chih-hsiong, partially joined by Justice Chen Bi-yu. 6 The term "quasi-citizen" does not currently exist in Taiwan's immigration regulations; however, due to the various stages of residency and permanent residency that non-citizens go through, the NIA has used the term "quasi-citizen" in its research to refer to non-citizens who have obtained permanent residency or long-term residency permits, referencing the concept of "denizenship" proposed by Swedish sociologist Tomas Hammar. 4 17