children who live in government shelter homes under the care of JKM do not receive assistance from the department to obtain citizenship, so remain without citizenship upon leaving the homes. 2.2.2 Scale of issue The number of stateless abandoned children or foundlings in Malaysia is difficult to estimate. The only government figure on this is from the Welfare Department, which recorded 1,933 stateless children under the age of 18 in homes nationwide, comprising 1,098 boys and 835 girls in 2019 (“Inconsistency in Granting Citizenship”, 2020). Previously, JKM revealed in 2017 that there were 246 children registered with them. However, JKM has been criticised for not assisting children under their care to obtain citizenship by an NGO that claimed to receive as many 1,758 stateless children in their welfare homes (Zulaikha Zulkifli, 2012). 2.3 Adopted children in Malaysia 2.3.1 Causation of statelessness Adoption is a practice used to protect children in need of care and protection as stipulated under the Child Act 2001. Children in need of care and protection, as defined by the Child Act 2001, include abused children, neglected children, abandoned children, children who are in danger, children found begging, and children involved in illegal hawking or activities detrimental to their health and welfare. Stateless children who are adopted by Malaysian parents do not always obtain citizenship automatically. Similar to abandoned children, adopted children are rendered stateless due to the inability to prove their link to their Malaysian birth parents. Some abandoned children are adopted by Malaysian parents. Rohana Abdullah, who was abandoned by her Indonesian biological mother and raised by a Chinese kindergarten teacher who became her adoptive mother, has been denied citizenship since 2016 (“A ‘touched’ Hamzah to look into”, 2022). Tan Soo Yin’s lawsuit seeking citizenship was rejected by High Court judge Mariana Yahya on the grounds that she had failed to prove that her biological parents were Malaysians, as required under Section 1(e) in the Second Schedule of the 33