Nationality Law in the Western Hemisphere: On Problems of Comparative Law and Legal Translation in Studying Different Citizenship Regimes

It is well-known that the concept of nationality plays an important role in different fields of the law, be it private or public law, private international law (‘conflicts of law’) or public international law. While nationality is also frequently the subject of comparative analysis, and therefore of comparative law, little has so far been written on the conceptual and linguistic difficulties that arise in conducting comparative analyses of the nationality laws of different countries – especially if one does not rely on translations but examines them in the original languages. After giving an overview of the legal scholarship on legal translation and comparative law and assessing its relevance for the domain of nationality law (sections 2 and 3), the paper will continue with some remarks on the usefulness and quality of bi- and multilingual legal dictionaries for these fields of study (section 4). While my own experiences in conducting comparative and multilingual research on nationality law are referred to throughout the paper, section 5 will specifically give relevant examples from my work on the book Nationality Law in the Western Hemisphere: A Study on Grounds for Acquisition and Loss of Citizenship in the Americas and the Caribbean.