Citizenship Education in Other Countries – SS1 Citizenship & Heritage Studies Lesson Note (Third Term)

Citizenship rules differ from country to country because each country’s law decides who belongs to it. In the USA, birth on American soil makes a person a citizen (jus soli). In the UK, Ghana, South Africa and Nigeria, a family link is normally needed.

Behavioural objectives

By the end of the lesson, students should be able to:

1. explain how citizenship works in the USA, the UK, Ghana and South Africa;
2. state the meaning of jus soli (Right of the Soil);
3. compare Nigeria with the four countries on birth citizenship, dual citizenship and key focus;
4. give reasons why we should study citizenship in other countries.

What are the key terms in this topic?

These terms explain how countries decide who is a citizen.

• Citizenship: the legal status of belonging to a country, with its rights and duties.
• Jus soli: citizenship by place of birth, also called “Right of the Soil”.
• Jus sanguinis: citizenship by blood, from a parent who is a citizen.
• Naturalisation: the legal process by which a foreigner becomes a citizen.
• Dual citizenship: holding the citizenship of two countries at the same time.
• Diaspora: people of a country or region who live abroad.
• Monarchy: a system of government headed by a king or queen.

Why do countries have different citizenship rules?

Each country makes its own citizenship law to suit its history, people and needs.

• History: colonial rule, slavery and war shape who a country welcomes.
• Population: countries built by migrants and countries of old communities make different rules.
• National values: each country teaches citizens what it considers most important, such as unity or equality.
• Constitution: the law of each country sets out who is a citizen by birth, registration or naturalisation.

How does citizenship work in four other countries?

The USA, the UK, Ghana and South Africa each have their own rules on birth, tests and citizenship education.

How does citizenship work in the United States of America (USA)?

The USA grants citizenship to almost everyone born on its soil and requires foreigners to pass a test.

• Birthright citizenship (jus soli): a child born on American soil is generally an American citizen, even if the parents are foreigners.
• The naturalisation test: foreigners must pass a test on US history and government.
• English language: applicants must show they can speak, read and write basic English.
• The oath: new citizens take an “Oath of Allegiance” to the United States.
• Key focus: loyalty to the Constitution.

How does citizenship work in the United Kingdom (UK)?

The UK is a monarchy where birth in the country does not automatically make a child a citizen.

• Not automatic by soil: at least one parent must be a British citizen or be settled in the UK (a permanent resident).
• The “Life in the UK” test: applicants for naturalisation must pass a test on British history, traditions, laws and government.
• Monarchy: British people were historically called “Subjects” of the Crown.
• Commonwealth link: Nigeria is a Commonwealth country, so Nigerians living legally in the UK can vote in elections that other foreigners cannot.

How does citizenship work in Ghana?

Ghana is our West African neighbour, and its citizenship laws are similar to Nigeria’s but stress links with the Diaspora.

• Dual citizenship: Ghana allows its citizens to hold another country’s citizenship and passport.
• Diaspora link: dual citizenship helps Ghanaians abroad to stay connected and invest at home.
• Welcome for the African Diaspora: Ghana invites people of African descent whose ancestors were taken away in the slave trade to return and settle.
• Community life: belonging to a community and respect for tradition remain important in Ghanaian society.

How does citizenship work in South Africa?

South Africa, called the “Rainbow Nation”, designs its citizenship laws and education to end the effects of apartheid.

• Apartheid: a past system in which people were treated differently because of their race.
• Equality for all: the law makes every citizen equal, whatever the person’s race.
• By descent: most people are citizens because a parent is a South African citizen.
• Human rights: citizenship education stresses human rights and ending discrimination.

What is the difference between jus soli and jus sanguinis?

Jus soli gives citizenship by place of birth. Jus sanguinis gives citizenship by the citizenship of a parent.

How do Nigeria and the four countries compare?

The table below compares Nigeria with the USA, the UK, Ghana and South Africa.

Why should we study citizenship in other countries?

We study other countries to learn good ideas, prepare for life abroad and understand people better.

1. To improve ourselves: we can pick the best ideas from the USA or Ghana for Nigeria.
2. To prepare for travel: anyone who lives or studies abroad needs to know their legal status.
3. Global connection: every country is a group of people trying to live together in peace.

Class activity

1. Which one do you prefer? Choose one rule from another country to bring to Nigeria (for example the US birthright rule). Give reasons.
2. Discussion: why is the USA the only country in our list that gives citizenship just for birth on its land?

Evaluation

1. What is jus soli, and which country in this lesson uses it?
2. State two things a foreigner must do to become a US citizen.
3. What is the main difference between the US and the UK on citizenship by birth?
4. Name two features of citizenship in Ghana.
5. Why does South African citizenship education focus on human rights?

Assignment

Research: Find out the name of the “Right of Return” programme in Ghana. (Hint: It happened in 2019.)