enjoyment of civil, political, economic, social, and cultural rights. While certain rights, such as voting and running for office, might be reserved for citizens, the principle that human rights should be universally enjoyed remains. States are thus required to ensure that non-citizens enjoy equality with citizens to the extent recognized by international law. Therefore, in the context of fundamental rights like life, health, and education, states must treat non-citizens equally. Any differential treatment between citizens and non-citizens must be justified as legitimate, reasonable, and necessary in compliance with General Recommendation No. 30. Simply citing limited educational resources as a reason for differential treatment does not meet the criteria of a reasonable distinction under international human rights standards. ii. Constitutional Protection for Non-citizens 1. Basic Rights of Non-citizens Under the Constitution Article 3 of Taiwan’s Constitution states: "A person with the nationality of the Republic of China is a national of the Republic of China." Non-citizens, therefore, refer to individuals who do not hold R.O.C. nationality, regardless of whether they possess single or multiple foreign nationalities or are stateless. J.Y. Interpretation No. 708 establishes that personal freedom is a fundamental human right, the foundation of all freedoms and rights, and must be protected regardless of nationality. This principle is a common standard in modern rule-of-law states. Therefore, the Constitution's Article 8 protection of personal freedom extends to non-citizens and ensures they receive the same protection as R.O.C. citizens. However, the exact interpretation also clarifies that non-citizens do not have the right to enter the R.O.C. freely. This means that the applicability of constitutional rights to non-citizens depends on the nature of the right in question. Regarding whether non-citizens can claim the right to equality under Article 7 of the Constitution, some scholars have noted a distinction between the language of Article 7 and Article 3, which refers to "nationals of the Republic of China." They 14

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