ElectronicJournalofcomparativeLaw,vol.8.3(october2004),<http://www.ejcl.org/> 1981 British declaration, it can be concluded that former British Dependent Territories Citizens, who became British Overseas Territories Citizens by Royal Assent on 26 February 2002, on 21 May 2002 also received European citizenship through having been granted British citizenship. 29 However, there is one exception: British citizenship was not extended to persons who after 26 February 2002 were British Overseas Territories Citizens by virtue of a connection with the Sovereign Base Areas of Akrotiri and Dhekelia 3 These base areas, located on the island of Cyprus, are British Overseas Territories, but extending British citizenship was deemed to be inappropriate because of the military nature of these British possessions. For this reason, these British Overseas Territories Citizens do not possess British citizenship and are therefore definitely not European citizens Furthermore, it should be borne in mind that British citizenship is conferred to the other British Overseas Territories Citizens in addition to the status they possess. The consequent of this is that the persons in question may issue a declaration of renunciation in order to divest themselves of British citizenship If this happens, they are exclusively British Overseas Territories Citizens, not possessing European citizenship, of course These legal constructions show that the status of British Overseas Territories Citizen has not been abolished furthermore, acquisition of this status on the basis of the provisions of the amended British Nationality Act does not result in acquisition of British citizenship Persons who acquired British Overseas Territories Citizenship after 21 May 2002 can only apply to be registered as British citizens. Registration is at the discretion of the Secretary of State 31 In respect of all these changes concerning British Dependent Territories Citizens,it can be concluded that the United Kingdom is to review the 1981 declaration It is not the British Dependent Territories Citizens, but some British Overseas Territories Citizens(and some other categories such as British Overseas Citizens)who are now excluded. Furthermore it is useful to know whether the United Kingdom will preserve the statement that, for Community purposes, all British citizens are British, including those living in British Overseas Territories The validity of the exclusion of certain British nationals from European citizenship was challenged before the European Court of Justice in 2001 in the Manjit Kaur Case. 32 Manjit Kaur was a British Overseas Citizen(not a British Overseas Territories Citizen )of Indian extraction, who lived in East Africa. She argued that the British declaration deprived her of European citizenship. The European Court of Justice concluded that she was not deprived of European citizenship because she had never been a European citizen, according to the british declaration The numberof persons involved is approx 200,000, living in thirteen British overseas territories Anguilla, Bermuda, British Antarctic Territory, British Indian Ocean Territory, British Virgin Islands, Cayman Islands, Falkland Islands, Gibraltar, Montserrat, Pitcairn Islands, St Helena and Dependencies, South Georgia and the South sandwich Islands and the Turks and Caicos islands Both base areas are located in the south of the island of Cyprus S. 4A BNA 1981, as amended by the British Overseas Territories Act 2002: . the Secretary of State may if he thinks fit cause the person to be so registered. Another category of British Overseas Territories Citizens without Brit ish cit izenship are the lois, covered by s. 63)of the Brit ish Overseas Territories Act 2002 ECJ 20 February 2001, Case 192/99, ECR I-1237Electronic Journal of Comparative Law, vol. 8.3 (October 2004), <http://www.ejcl.org/> 7 1981 British declaration, it can be concluded that former British Dependent Territories Citizens, who became British Overseas Territories Citizens by Royal Assent on 26 February 2002, on 21 May 2002 also received European citizenship through having been granted British citizenship.29 However, there is one exception: British citizenship was not extended to persons who after 26 February 2002 were British Overseas Territories Citizens by virtue of a connection with the Sovereign Base Areas of Akrotiri and Dhekelia.30 These base areas, located on the island of Cyprus, are British Overseas Territories, but extending British citizenship was deemed to be inappropriate because of the military nature of these British possessions. For this reason, these British Overseas Territories Citizens do not possess British citizenship and are therefore definitely not European citizens. Furthermore, it should be borne in mind that British citizenship is conferred to the other British Overseas Territories Citizens in addition to the status they possess. The consequence of this is that the persons in question may issue a declaration of renunciation in order to divest themselves of British citizenship. If this happens, they are exclusively British Overseas Territories Citizens, not possessing European citizenship, of course. These legal constructions show that the status of ‘British Overseas Territories Citizen’ has not been abolished: furthermore, acquisition of this status on the basis of the provisions of the amended British Nationality Act does not result in acquisition of British citizenship. Persons who acquired British Overseas Territories Citizenship after 21 May 2002 can only apply to be registered as British citizens. Registration is at the discretion of the Secretary of State.31 In respect of all these changes concerning British Dependent Territories Citizens, it can be concluded that the United Kingdom is to review the 1981 declaration. It is not the British Dependent Territories Citizens, but some British Overseas Territories Citizens (and some other categories such as British Overseas Citizens) who are now excluded. Furthermore, it is useful to know whether the United Kingdom will preserve the statement that, for Community purposes, all British citizens are British, including those living in British Overseas Territories. The validity of the exclusion of certain British nationals from European citizenship was challenged before the European Court of Justice in 2001 in the Manjit Kaur Case.32 Manjit Kaur was a British Overseas Citizen (not a British Overseas Territories Citizen!) of Indian extraction, who lived in East Africa. She argued that the British declaration deprived her of European citizenship. The European Court of Justice concluded that she was not deprived of European citizenship because she had never been a European citizen, according to the British declaration: 29 The number of persons involved is approx. 200,000, living in thirteen British overseas territories: Anguilla, Bermuda, British Antarctic Territory, British Indian Ocean Territory, British Virgin Islands, Cayman Islands, Falkland Islands, Gibraltar, Montserrat, Pitcairn Islands, St Helena and Dependencies, South Georgia and the South Sandwich Islands, and the Turks and Caicos Islands. 30 Both base areas are located in the south of the island of Cyprus. 31 S. 4A BNA 1981, as amended by the British Overseas Territories Act 2002: ‘. . . the Secretary of State may if he thinks fit cause the person to be so registered.’ Another category of British Overseas Territories Citizens without British citizenship are the Ilois, covered by S. 6 (3) of the British Overseas Territories Act 2002. 32 ECJ 20 February 2001, Case 192/99, ECR I-1237