analyse selected cases of citizenship applications by adopted children to the Court or JPN. Azizah Mohd (2012) examines whether the existing legal provisions via the Adoption Act 1952 and the Islamic family law on adoption in Malaysia are adequate to accommodate both Muslims and non-Muslims. While most of the literature focuses on different groups of stateless children, Tharani Loganathan et. al. (2022) examine the intersection of undocumented and non-citizen children in Malaysia and their vulnerabilities in education access. Using a desk review and in-depth interviews, they find that most of them rely on informal education provided by alternative learning centres that typically lack standardised curricula and resources. They also find that stateless Rohingya refugees in Peninsular Malaysia and the Bajau Laut children in Sabah are the most marginalised, having the poorest educational opportunities. Furthermore, Mazura Md Saman and Nor Hafizah Mohd Badrol Affandi (2018) look more into the Malaysian law regarding access to education to explain stateless children’s high barriers to entry into public schools. Menz (2016) is the only study that explores the intersection between statelessness and the risk of child marriage for girls in Malaysia. The risk of child marriage is especially high for the stateless Rohingya refugees as well as underaged trafficked Rohingya girls. Statelessness in East Malaysia In comparison, the literature on statelessness in East Malaysia mostly focuses on two groups of stateless populations in Sabah, namely the Bajau Laut community or the children of migrants and refugees. Seven out of the thirteen studies found focus on the Bajau Laut community while the remaining six focus on the children of migrants and refugees in Sabah. The stateless Bajau Laut are often framed as national security concerns. Using the Bajau Laut in Sabah as a case study, Marshall et. al. (2019) discuss their case study by looking at the history of illegal immigration in Sabah and the ongoing conflict between the Malaysian government and armed vigilantes. Ramli Dollah et. al. (2016) present the stateless Bajau Laut in Sabah as one of the major constraints in addressing cross-border crime in Sabah, and position them as a threat towards Sabah’s security. 25

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