Vanuatu's highest court has clarified an important distinction between citizenship and political rights for individuals who obtain nationality through the country's Citizenship by Investment Program.
The Court of Appeal has ruled that citizens who obtain Vanuatu nationality through the Development Support Programme (DSP) cannot vote in elections, hold public office, or participate in certain political activities.
Importantly, these restrictions continue to apply even if the investor subsequently loses their original nationality.
The case involved India-born investor Sunaraparipooranan Pakshirajan, who obtained Vanuatu citizenship through the DSP in August 2021.
Under Indian nationality law, voluntarily acquiring another nationality results in the loss of Indian citizenship. This meant that after obtaining his Vanuatu passport, Pakshirajan no longer held Indian nationality.
He subsequently attempted to register as a voter in Vanuatu, arguing that because he held only Vanuatu nationality, he should no longer be classified as a dual citizen.
Vanuatu's electoral authorities rejected his application.
The case ultimately reached Vanuatu's Court of Appeal after the Supreme Court rejected Pakshirajan's challenge.
The Court of Appeal determined that an investor's constitutional status is established based on how citizenship was originally acquired.
For DSP investors, obtaining citizenship through the investment route places them within Vanuatu's constitutional dual-citizen category.
Losing another nationality at a later date does not change that classification.
Article 13(3) of Vanuatu's Constitution places specific political restrictions on dual citizens.
These include restrictions on:
The Constitution separately recognizes naturalized citizens under a route requiring 10 years of continuous residence.
Citizenship obtained through the DSP does not fall within this naturalization category.
One of the most important elements of the ruling is that the Court focused on the method of acquiring Vanuatu citizenship, rather than how many nationalities the individual currently holds.
This means a DSP investor who later becomes solely a Vanuatu citizen does not automatically gain the political rights available to other categories of citizens.
The constitutional classification established when DSP citizenship is granted remains applicable.
The restrictions also reflect concerns surrounding the potential influence of investor citizens on Vanuatu's domestic political system.
Vanuatu has a relatively small electorate, meaning comparatively small numbers of voters can potentially influence electoral outcomes.
The framework therefore allows DSP citizens to receive the benefits associated with Vanuatu citizenship while restricting their ability to influence domestic elections and political institutions.
Pakshirajan argued that his personal circumstances and contributions to Vanuatu should also be considered.
According to the case record, he highlighted his professional background as well as contributions to the country, including government service, philanthropy, and involvement in establishing the first hemodialysis unit at Vila Central Hospital.
However, the Court of Appeal maintained that political eligibility depends on the legal route through which citizenship was obtained, rather than an individual's subsequent contributions or activities.
Political rights for investment citizens vary considerably between countries.
Vanuatu therefore takes a particularly restrictive approach by permanently excluding DSP citizens from voting and certain forms of political participation.
The Court of Appeal's decision provides greater clarity for both existing DSP citizens and prospective investors.
Obtaining citizenship through Vanuatu's Development Support Programme provides the benefits associated with nationality, but it does not provide the same political rights available to other constitutional categories of Vanuatu citizens.
Most importantly, losing an original nationality does not remove the investor from the constitutional dual-citizen category.
For prospective investors considering Vanuatu citizenship by investment, the ruling highlights an important distinction that should be understood before applying.
Vanuatu citizenship obtained through the DSP can provide the benefits associated with citizenship, but political participation remains restricted.
The August 2026 Court of Appeal ruling confirms that these limitations are linked to the way citizenship was acquired and remain in place even when the investor no longer holds another nationality.
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