In her early 20s, Australian Johanna Cranitch chose to pursue her musical ambitions overseas.
For several years in her 30s, she toured with Irish rock band The Cranberries, playing the keyboard and singing backup vocals.
The frequent travel in and out of Limerick for rehearsals was made easier because she held an Irish passport.
But she did not know that getting her Irish citizenship would ultimately trigger the loss of her Australian citizenship.
"I am fiercely, loyally Australian. To have that taken from me was such a slap in the face," she told the ABC from Los Angeles.
In circumstances similar to those of Matthew Niall, who last month told the ABC how he lost his Australian citizenship under the now-repealed section 17 of the old citizenship act, Ms Cranitch put herself on the Irish foreign births register at a consulate in Australia in 1999, when she was 19 years old.
The legislation, which was repealed in 2002, meant some Australian adults who acquired another citizenship automatically lost their Australian citizenship.
They can apply to become citizens again, as Mr Niall did, for a fee of $210, but many hire a migration lawyer to help with the process.
The ABC spoke to several people who lost their citizenship in this way, including an accountant, a journalist and a management consultant.
All followed a pattern — they had an Irish grandparent but were born and raised in Australia. They got their Irish citizenship when they were over 18 before 2002 and were only notified they lost their citizenship years or sometimes decades later when they tried to get citizenship for their overseas-born children.
Several others who suspected they may have automatically lost their citizenship under the law but had never been notified by the Department of Home Affairs were reluctant to speak out, fearing the implications it could have on their work, housing, travel and legal rights.
The ABC approached Home Affairs to ask how concerned people could double-check their citizenship status and if there are any steps to consider a legislative fix for those impacted by section 17.
"After conversing with the minister's office and relevant areas, the media operations team has been advised that the department has nothing further to add regarding this situation," it responded.
'Much more than a piece of paper'
Currently a composer and creative director at Music House in LA, Ms Cranitch, 42, received an email in September of 2021 from the Department of Home Affairs determining that she had lost her Australian citizenship back in 1999.
The news came at a difficult period in her personal life, and COVID restrictions at the time meant only Australian citizens were allowed back into the country.
"What would have happened if my parents got sick? I couldn't get back. What a terrible feeling," she said.
She also feared she could be expelled from the US because her green card — which gave her permanent residency in the United States — was based on her Australian citizenship.
Her mother, Maya Cranitch, who has been awarded a medal of the order of Australia for her services to education and teaching programs for refugees, was disturbed to hear her daughter was not considered Australian.
"I came to Australia as a stateless person," Mrs Cranitch said, explaining she arrived in Australia as a baby when her family fled Hungary in the late 1940s.
She said her family were considered dissidents and their Hungarian citizenship was cancelled.
"So to have this happen to my own daughter after that, it was very emotionally difficult for me," she said.
Tangled up in the concept of citizenship was a person's identity, she said.
"It's terribly important. It's much more than a piece of paper.
"It's your birthright, but it's also the way you exist in the world. It's your sense of belonging."
From LA, Ms Cranitch said she applied to resume her citizenship, and it was granted about a year after her ordeal began.
"I've got this certificate … it says that I became an Australian a year ago," she said.
"Not only is that so monumentally offensive … but I can't get citizenship [by descent] for my son right now.
"I want to bring him home. I want him to go to school in Australia."
Children born overseas to parents who were not citizens at the time of their birth are not eligible for Australian citizenship by descent, but they can apply for citizenship by conferral.
'The safest passport to have'
As an award-winning journalist, Prue Clarke has worked in far-flung corners of the world.
"I've definitely had many situations where if I can use my Irish passport to travel, I always will," she said.
"It's sort of known in journalism – that's the best passport to have, the safest passport to have."
Speaking to the ABC from West Africa, she said her Australian citizenship was cancelled in 2008, and her voided passport, with the front cut off, was mailed to her in the post.
Like Ms Cranitch, Clarke had a US green card at the time, which could have been a problem if her application to resume her Australian citizenship had not been processed so quickly, but she said, thankfully, it was straightforward.
"I still feel indignant and angry about it," she said.
"It felt really petty and unnecessary … at the time that this was happening, dual citizenship was allowed."
Clarke, the executive director of New Narratives, a non-profit newsroom that works with media in low-income countries, said she understood she inherited her Irish citizenship through her grandfather.
"I read the rules, and they said that it was OK if you inherited a second citizenship … I thought I was doing the right thing," she said.
Lingering questions over citizenship by descent
Alison, a management consultant living in Melbourne, said she was very aware that people who got another citizenship would lose their Australian citizenship.
So, like Clarke, she made enquiries in the late 1990s and understood there was an exception for people who had their second citizenship by descent.
"I thought, well, I'm descended from my grandparents. So that shouldn't be a problem," she said.
She went to the Irish consulate and registered her name in the foreign births entry book in 1997, a few days before her 27th birthday.
Her lost citizenship went unnoticed for years – during which she lived in London, got married to a British man in Australia, and renewed her Australian passport.
After she applied for Australian citizenship for her British-born son, she received a letter in late 2004 or early 2005 from the Australian High Commission in London telling her she was not a citizen and that her passport had been kept and destroyed.
"I was pretty taken aback. I felt like my identity had just been ripped away from me," she said.
"I love Ireland. It's a lovely place. But I think I've spent a total of about four weeks there in my whole life."
But she was also told she could apply to get her citizenship back — she had maintained close ties to Australia and had to state in her application that she intended to return within three years.
According to the Irish embassy in Canberra, people were automatically granted Irish citizenship if their parent was born in Ireland before 2005, whereas people who have claimed Irish citizenship through a grandparent will likely have to apply to the foreign births register.
The embassy told the ABC while it appreciates the citizenship issue has caused difficulty and distress, "it is essentially a question of Australian law, and therefore Australian authorities will be best placed to respond to the affected persons".
Dr Rayner Thwaites, senior lecturer at the Sydney Law School, University of Sydney, pointed out that section 17 made no mention of descent or generation but instead referred to whether a person had taken an action to get another citizenship.
"If it happened automatically, so you didn't have to do anything, that's a clear cut-case where you're untouched by section 17," Dr Thwaites said.
Not all Australian citizens who acquired another citizenship will lose their Australian citizenship, depending on particular circumstances outlined in the department of Home Affairs policy, which says each case must be examined individually.
Alison said she understood the argument that ignorance of the law was no excuse but said it was difficult to get the correct information.
"Even the people who you ask who should know are not able to provide that clarity. It makes it a lot harder," she said.
Entering Australia on an Irish passport
Desmond Dowling, an accountant working in commercial finance in the UK, said he was in "complete disbelief" when he learned he had lost his citizenship.
"You're literally re-reading the email going, 'Did I read that right? Did they just say I'm not a citizen?'"
"And then, in the typical Australian way, there are expletives, and you go, 'Well, of course, I'm Australian. You can't tell me I'm not'."
Mr Dowling said Australian citizenship for his youngest daughter was initially granted, but he then received an email from Home Affairs last July telling him he may have lost his own citizenship.
Having already booked a trip to Australia in September last year, he entered the country on his Irish passport with a visa.
"It was quite funny … The customs officer said, 'Why are you visiting Australia? I said, 'I'm seeing my family', with this broad Australian accent."
Mr Dowling said when he finished university in Brisbane, he wanted to work overseas, hoping the experience would be good for future job prospects.
"The sole purpose of this was just to facilitate work in the UK," he said.
"My purpose was not to renounce my Australian citizenship. In no way, shape, or form was I undertaking this to do so."
Legal scholar Kim Rubenstein said the issue centred on a person's intention at the time and whether they believed they already held that citizenship — even if that belief was wrong.
"If you honestly believed that you had that citizenship already, and what you're doing is evidencing that or getting a passport as a result of that, then that is sufficient," she said.
Mr Dowling is gathering the paperwork to become a citizen again but said the law should be changed, as people like him are being treated differently to those who took the same action after 2002.
Lost citizenship could land people in trouble abroad
Chris Johnston from Work Visa Lawyers said while section 17 could cause inconvenience and paperwork for some, it could potentially land others in immigration detention overseas.
"You could get stuck in a third country with no passport, and then fairly quickly, your visa could expire, you could become unlawful, and you could get detained," he said.
One client, he said, had travelled to a third country on his Australian passport when he was notified he may not be a citizen, but successfully argued his dominant purpose was for study and a brief visit and was able to keep his Australian citizenship.
Mr Johnston said there were "legislative patches" to try and resolve section 17 issues, but there were still scenarios where people would fall through the gaps.
The ex-citizen visa provides permanent residency but lacks travel rights, and while there is a resumption pathway for those who lost their citizenship, they may be rejected on character grounds.
Citizenship by conferral was another solution for children of former citizens, but Mr Johnston suggested there should be priority processing for citizenship resumptions and for children of former citizens.
Wait times for conferral were around 10 months longer than descent applications, and there was a high volume to wade through — around 96,000 applications as of January 31 this year, compared to 3,700 descent applicants.
While some people have their citizenship revoked, others continue to enjoy the rights of an Australian citizen and may never come to the notice of Home Affairs.
Dr Sangeetha Pillai, a researcher at UNSW, said section 17 was a "historical relic" and highlighted the problem with automatic citizenship loss provisions.
"They can be very impractical, and they can lead to situations where people don't actually know what their rights are and what their citizenship is. It's messy," she said.
Dr Thwaites said as a high proportion of the population were dual citizens, it was important people were not made to feel less Australian because they have foreign citizenship.
"Because the system is so complicated and there's so much grey, I think it's incredibly important that the officials have goodwill and that they're really trying to do the right thing by longstanding members of the community," he said.
