Former Justice Lee Zhen-shan used the immigration system to argue that applicants for permanent residency have already identified with the host country and are willing to settle and live there, essentially possessing the characteristics of "quasi-immigrants." The only difference lies in their willingness to renounce their original nationality. Such individuals should not be treated as ordinary foreigners but more leniently, akin to citizens. Suppose foreigners are allowed to obtain permanent residency. In that case, their basic rights protection should be as close as possible to that of citizens, and even their political participation rights should be considered differently from those of ordinary foreigners, aligning with the legal principles related to differential treatment and the hierarchy of basic rights. 8 C. Right to Education in International Human Rights Covenants i. Protection of the Right to Education in International Human Rights Covenants 1. ICESCR The right to education is recognized as a fundamental human right and is essential for the realization of other human rights. Article 13 of the ICESCR is the most comprehensive provision in international human rights law regarding the right to education. It begins with the clear assertion that "the States Parties to the present Covenant recognize the right of everyone to education." The ICESCR then specifies that primary education should be free and compulsory for all, secondary education should be available and accessible to all, and higher education should be made equally accessible to all based on capacity. General Comment No. 13 of the CESCR elaborates on how the right to education should be implemented by proposing a 4A framework in Paragraph 6. This framework asserts that for the right to education to be meaningful, it must have the Xu Yi-bao, May 2013, "A Study on Issues Related to Foreigners as Subjects of Fundamental Rights," in Journal of Homeland Security and Border Management, No. 19. 8 Li Zhen-shan, ibid., p. 64. 7 18