UK: Nationality Law under the Christian Lens
The British Nationality Act 1981, St. Paul’s Letter to the Romans 13, and
the Limits of an Argument from the Fathers
The 1981 Act already ended the old automatic jus soli. What follows is not a party programme. It is an account of what the statute still leaves open, of what has changed around it in the last three years, of how a restrictionist reading of St. Paul’s Letter to the Romans 13 and the Fathers tries to close those openings, and of why that reading is contested inside the tradition it claims. The argument is offered in the conviction that a Christian may hold a hard view of membership without pretending that Scripture dictates it, and may hold a generous one without pretending that the Magistrate/State has no office.
I
What the 1981 Act Actually Did
Before 1 January 1983, birth in the United Kingdom or the Islands generally made a person a British citizen regardless of the parents’ status. The British Nationality Act 1981 broke that. Section 1 confers citizenship at birth in the United Kingdom only if, at the time of birth, a parent is a British citizen or is “settled” — ordinarily resident and free of immigration time limits, whether by indefinite leave, right of abode, or the equivalent.[1]
That was a real tightening. It was not the last word.
Citizenship still arrives automatically for a child born here to a parent who is merely settled, not British. A child who is not British at birth may later register by entitlement if a parent becomes British or settled during the child’s minority, or after ten years’ continuous presence subject to limits on absence. Adults naturalise after a qualifying residence period, good character, sufficient language, and knowledge of life in the United Kingdom. Descent transmits citizenship one generation abroad where the parent is British otherwise than by descent.[2]
Deprivation exists under section 40: fraud, false representation or concealment of a material fact, or conduct which the Secretary of State considers it conducive to the public good to answer with the loss of citizenship. Those powers have been enlarged repeatedly — in 2002, in 2006, in 2014, and in 2022 — and they remain unequal in their reach.[3]
That inequality is usually described as two-tier. It is in fact three-tier, and the distinction matters to any argument that trades on it. A person who holds no other nationality and who is British otherwise than by naturalisation cannot be deprived at all, because section 40(4) forbids an order that would leave a person stateless. A person who holds no other nationality but who acquired citizenship by naturalisation may be deprived under section 40(4A), inserted in 2014, but only where the Secretary of State is satisfied that the conduct was seriously prejudicial to the vital interests of the United Kingdom and has reasonable grounds to believe that the person is able to become a national of another country. A dual national may be deprived under the ordinary conducive-to-the-public-good test in section 40(2). The middle tier is narrower than the polemic on either side generally allows. A restrictionist who describes it as a broad power overstates; a critic who describes naturalised citizens as holding their status on sufferance overstates in the other direction.[4]
A candid restrictionist case starts here. The 1981 Act already said that soil is not enough. What it left standing is a set of routes by which presence plus time ripens into membership, and a status that is hard to lose for those who hold no other.
II
What Has Changed Around the Act, 2023–2026
Any argument written today has to reckon with three years of movement, and the shape of that movement is more interesting than the individual measures.
The Illegal Migration Act 2023 enacted, at sections 30 to 37, a permanent bar on entry, settlement and citizenship for those who had met the conditions for removal. Those sections were repealed by the Border Security, Asylum and Immigration Act 2025 with effect from 2 December 2025. In committee, the Minister described them as unenforced and unworkable.[5]
The bar did not disappear. It migrated. On 10 February 2025 the Home Office issued version 6 of its caseworker guidance on the good character requirement, providing that a person who had previously entered the United Kingdom illegally would normally be refused citizenship regardless of how long ago the entry occurred, and that a person who had arrived without the required entry clearance having made a dangerous journey — by small boat, or concealed in a vehicle — would normally be refused. The previous position had been that an illegal entry more than ten years old could be disregarded.[6]
What followed is instructive. In pre-action correspondence, the Secretary of State indicated that the guidance would be amended to accommodate those with a defence under section 31 of the Immigration and Asylum Act 1999, which gives domestic effect to Article 31 of the Refugee Convention. The amendment did not appear within the indicated period. The Department then argued that Article 31 has no application, because refusal of naturalisation is not a “penalty” within that article and because naturalisation falls under Article 34 instead. Version 7 was published on 30 April 2026 and described its own amendments as technical clarifications. Four lead claims were listed before the Divisional Court for 9 to 11 June 2026; shortly before the hearing, the Home Office withdrew the refusal decisions under challenge, and the lead claims were withdrawn. A linked claim proceeded, and on 30 June 2026 the court upheld the policy: there is no entitlement to citizenship, refusal leaves the claimant’s protection as a refugee intact, and the balance struck was a fair one. But that claim did not carry the Refugee Convention or Article 8 grounds. The hardest questions about the policy have not been decided; they have been avoided.[7]
On deprivation, the Deprivation of Citizenship Orders (Effect during Appeal) Act 2025 received Royal Assent on 27 October 2025. It is worth stating precisely what it does and does not do, because it is already being cited loosely on both sides. It creates no new ground of deprivation. It answers the Supreme Court’s decision in N3 (ZA), which had held that a successful appellant is treated as never having lost citizenship, by postponing that restoration until all onward appeal rights are exhausted. It also prevents a person from renouncing another nationality while the appeal is pending — a provision aimed squarely at the manufacture of statelessness as a litigation tactic, and one which any argument about statelessness ought to notice.[8]
Meanwhile the extension of deprivation beyond terrorism is no longer hypothetical. The Special Immigration Appeals Commission has upheld deprivation and deportation in cases of serious organised crime — the facilitation of illegal entry by lorry — where the individuals concerned had never been prosecuted. Whatever one makes of that, it is the step the restrictionist proposes, taken already, and it should be argued for or against on those terms rather than as a proposal.
From all of this a single observation follows, and it is the one I would ask a reader to carry away from this section, whatever he concludes about the merits. The most restrictive rule now operating in British nationality law is not in an Act of Parliament. It sits in a caseworker guidance document, presently in its seventh version, alterable by a minister without a vote, applied retrospectively to conduct decades old, and defended in court on the footing that a policy which merely says “normally” leaves discretion intact. A Christian who favours a harder membership rule and a Christian who deplores it have the same reason to be uneasy about that. Romans 13 speaks of the Magistrate/State’s office; it does not commend the evasion of the ordinary means by which a people governs itself.
III
Where a Further Tightening Would Bite
These are the levers that exist in the architecture of the Act, not slogans:
Birth on the territory. The largest remaining automatic grant is section 1(1)(b): the child of a settled non-citizen. A tighter statute could require at least one British citizen parent, cumulatively with at least one British citizen grandparent and one British citizen great-grandparent… Or a defined period of settlement plus an integration condition, before a birth confers citizenship. That would finish the move from jus soli toward jus sanguinis, which the 1981 Nationality Act began. Abandoned-infant provisions and the statelessness safeguards in Schedule 2 would still be required; and of course, international law on the reduction of statelessness is not decorative.
Registration of children not British at birth. Sections 1(3) and 1(4) are entitlements, not discretions. A tighter Act could convert them into discretions, raise the residence threshold, impose a statutory good character and integration test, or close the ten-year route where the child’s presence began in breach of immigration law. That last is the live fight: whether unlawful entry should stain a citizenship claim permanently. It is worth noting that the current guidance itself accepts that illegal entry is normally outside a child’s control and so is not normally held against the child — a concession which cuts against the harder version of the restrictionist case, and which came from the Department rather than from its critics.
Naturalisation. Schedule 1 already demands residence, good character, language and knowledge of life in the United Kingdom. Parliament could define good character in statute instead of leaving it to guidance that shifts with ministers and litigation; it could treat illegal entry, identity fraud and specified serious offences as near-automatic bars; it could lengthen the qualifying period and make earlier grant depend on measured contribution rather than calendar time, as the earned-settlement proposals of 2025 envisage. Dual nationality on grant could be conditioned, as many states condition it, though Britain has not historically treated dual nationality as a problem in itself. If any of this is wanted, the honest course is to legislate for it.
Deprivation. Further tightening would mean applying the conducive-to-the-public-good logic more widely to serious organised crime and people-smuggling rather than terrorism alone; making the notice rules harder to game; and, most controversially, narrowing the distinction between the dual national and the sole British national. That last step collides with the 1961 Convention and with the intuition that a state should not manufacture people belonging nowhere. The restrictionist answer is that a citizenship which cannot be lost after grave betrayal of the political community is not membership but a one-way subsidy. The answer to the answer is that a power which by construction can only ever fall on those with a second passport is not impartial justice, whatever its stated ground.
Transmission abroad. The single-generation rule already exists. It could be narrowed further, Crown service and similar exceptions aside, if the aim is a citizen body whose primary life is here.
None of this requires pretending that 1981 was an open door. It was not. The claim is narrower: that the Act still converts presence into membership more readily than a thick account of political community would allow.
IV
Romans 13 Without the Usual Softening
St. Paul writes:
Πᾶσα ψυχὴ ἐξουσίαις ὑπερεχούσαις ὑποτασσέσθω. οὐ γὰρ ἔστιν ἐξουσία εἰ μὴ ὑπὸ θεοῦ,
αἱ δὲ οὖσαι ὑπὸ θεοῦ τεταγμέναι εἰσίν· ὥστε ὁ ἀντιτασσόμενος τῇ ἐξουσίᾳ τῇ τοῦ θεοῦ διαταγῇ ἀνθέστηκεν …
οὐ γὰρ εἰκῇ τὴν μάχαιραν φορεῖ· θεοῦ γὰρ διάκονός ἐστιν ἔκδικος εἰς ὀργὴν τῷ τὸ κακὸν πράσσοντι.
Let everyone be subject to the governing authorities, for there is no authority except that which God has established.
The authorities that exist have been established by God.
Consequently, whoever rebels against the authority is rebelling against what God has instituted,
and those who do so will bring judgment on themselves.
For the one in authority is God’s servant for your good. But if you do wrong, be afraid,
for rulers do not bear the sword for no reason. They are God’s servants, agents of wrath
to bring punishment on the wrongdoer.
Rom. 13: 1–2, 4 (NA28)
The passage is not an immigration statute. It does not define a citizen. It says nothing of passports or of registration by entitlement. Anyone who claims that it requires a particular amendment to Schedule 1 is proof-texting.[9]
The restrictionist inference is nonetheless straightforward, and should be stated without embarrassment. St. Paul assigns the Magistrate/State a real office:
to restrain wrongdoing,
to protect those who do good,
to collect what is owed,
to keep a public order in which ordinary life is possible.
A bounded people is the unit upon which that office is exercised. If everyone who arrives, and everyone born after an arrival, is already on the way to equal membership, the Magistrate/State no longer governs a people; he administers a territory. Defining who belongs, and enforcing the difference between belonging and not belonging, then falls within the same office as the sword and the tax.
On that reading, illegal entry is not a paperwork inconvenience. It is a refusal of the authority St. Paul calls instituted by God. Fraud in a nationality application is the same species of act. A naturalisation system which treats years of presence as nearly decisive, whatever the manner of arrival, teaches that the law is optional if one waits. A deprivation power which cannot reach a sole British national after grave public crime teaches that membership is indelible even where the member has treated the commonwealth as an enemy.
The Fathers can be pressed into this service, and some of it holds. Irenaeus, commenting on earthly rule, says that “the kingdom was established so that men, fearing the human kingdom, should not devour one another as the fish do, but by the establishment of laws should strike down the manifold injustice of the nations”.[10] Augustine, who knew both the sack of cities and the limits of politics, treated the earthly city’s peace as a real if temporary good.[11]
St. Thomas Aquinas supplies what the Fathers do not: an explicit argument for graduated admission. Expounding the judicial precepts of the old law, he observes that certain peoples were admitted to the assembly only in the third generation, others sooner, and that this staging was ordered to the security of a community which could not safely absorb the hostile at once. It is the closest thing in the tradition to a case for a long qualifying period, and a restrictionist who does not cite it is not arguing at full strength. He must, however, state the cost of citing it. St. Thomas is expounding a judicial law which he holds to be abrogated; the admission in question is admission to the assembly of a covenant people, not to a modern nationality; and in the same article he insists that the stranger passing through or dwelling among them was to be received in affabilitate. The passage will bear a graduated naturalisation. It will not bear a closed door.[12]
That is the strongest form of the case. It treats nationality law as an instrument of the office described in Romans 13, and not as a sacrament of welcome.
V
The Passage in Its Frame
The restrictionist reading is weakest where it is usually thought strongest: in the exegesis. Romans 13:1–7 is not a free-standing treatise on the Nation-State. It sits between two passages which govern how it is read, and both are habitually cut away.
Immediately before it, St. Paul forbids private/personal vengeance:
μὴ ἑαυτοὺς ἐκδικοῦντες, ἀγαπητοί, ἀλλὰ δότε τόπον τῇ ὀργῇ·
γέγραπται γάρ· ἐμοὶ ἐκδίκησις, ἐγὼ ἀνταποδώσω, λέγει κύριος.
"Do not take revenge, my dear friends,
but leave room for God's wrath, for it is written:
'It is mine to avenge; I will repay,' says the Lord."
Rom. 12:19 (NA28)
The vocabulary is the hinge. The ὀργή which the Christian must leave to God in 12:19 is the ὀργή which the Magistrate/State executes in 13:4, and the ἔκδικος of 13:4 answers the ἐκδικοῦντες forbidden in 12:19. St. Paul is not changing subject. He is explaining where the vengeance he has just taken out of the believer’s hands has been placed. This is why the passage will not do the work either party wants. It dignifies the Magistrate/State’s office by making him the instrument of a wrath that is God’s; and it removes that office from the Christian’s own hands in the same movement. In other words… A Christian may legitimately argue for a hard nationality law; that would not be unchristian. But he may not treat the enforcement of it as an expression of his own indignation, because the passage he is quoting has just forbidden him that.[13]
Immediately after it, St. Paul returns to love as the fulfilment of the law, and the debts of 13:7 give way to the one debt that is never discharged in 13:8. The framing is deliberate. Whatever the passage authorises, it authorises within that enclosure.
The occasion sharpens the point further. Verses 6 and 7 turn on taxes and revenues, and the great Roman historian and politician Tacitus records agitation over indirect taxation at Rome in the same period.[14] More to the present purpose: St. Paul is writing to a congregation which included Jewish Christians recently returned from an imperial expulsion. Claudius had expelled the Jews from Rome; Aquila and Priscilla are in Corinth precisely because of it.[15] The locus classicus of Christian submission to civil authority is addressed, in part, to people whom the civil authority had recently ordered out of the city on account of their origin. Neither side of this argument has made much of that. The restrictionist should notice that St. Paul commends submission to a Magistrate/State whose immigration policy had fallen on the very people he is addressing. The critic should notice that St. Paul commends it anyway.
VI
The Other Half of the File
The canon which contains Romans 13 contains commands which cut the other way, and the Fathers are not a single brief for the Home Office.
Israel’s law distinguished the ger, the resident sojourner, from the nokri, the foreigner who remained outside, and forbade the oppression of the sojourner on the ground that Israel had been sojourners in Egypt. This distinction is now the contested hinge of the whole debate, and honesty requires saying so rather than leaning on it. One line of argument holds that the ger was a foreigner who had entered with the community’s permission and had accepted its law, so that the protections attaching to him do not transfer to a person who enters unlawfully today. The opposing line holds that ancient Israel possessed no apparatus of border control or immigration status, that the analogy therefore cannot be run in either direction, and that the texts address vulnerability rather than legal category. I do not think either side has carried the point, and I do not think it can be carried by lexicography alone. What can be said is that a restrictionist who cites the ger/nokri distinction as settled is borrowing an authority the scholarship does not give him.[16]
Hospitality to the stranger is not a modern invention: Abraham at Mamre, the widow of Zarephath, the φιλοξενία (hospitality) of Hebrews 13:2, the judgment scene of Matthew 25 in which the stranger received is Christ received. St. Paul himself relativises ethnic boundaries within the Church at Galatians 3:28. St. Ambrose and St. Basil press the rich with the claim that the earth was given for common use, and twentieth-century papal teaching built upon that theme.[17]
Here a correction to a common shorthand, my own included. Exsul familia is an apostolic constitution concerning the pastoral care of migrants; it is not a charter of a right to migrate, and citing it as though it were overstates the case on the generous side exactly as proof-texting Romans 13 overstates it on the other. The right to migrate is more securely located in Pacem in terris and in the conciliar treatment of migrant labour.[18]
And here the text which a restrictionist writing in the Catholic tradition has least excuse for omitting, since it does both halves of the work in a single paragraph. The Roman Catholic Catechism teaches that:
the more prosperous nations are obliged to welcome the foreigner in search of security and the means of livelihood which he cannot find in his own country,
but, in the same breath, that political authorities may, for the sake of the common good, make the exercise of the right to immigrate subject to juridical, political and demographic conditions and policies,
and that the immigrant is bound to respect with gratitude the material and spiritual heritage of the country that receives him, to obey its laws, and to assist in carrying civic burdens.
This is not a compromise between two positions. It is the position: a duty of welcome which is real and a regulatory authority which is also real, each limiting the other.[19]
Augustine’s ordo amoris has been used to argue that nearer neighbours have a priority claim. It has also been used to argue that the neighbour is whoever is in need in front of you. The reader should know that this is not a dormant scholastic dispute but a live one: in February 2025 the ordering of loves was invoked in defence of a restrictionist immigration policy, and Pope Francis replied in a letter to the bishops of the United States that the true ordo amoris is the one disclosed by meditation on the parable of the Good Samaritan, which is to say a fraternity open to all without exception. One may think that reply too quick — the parable answers the question who is my neighbour, not the question how a polity allocates finite goods among competing claims — but one may not write as though the phrase were still available for unopposed use.[20]
One further correction, and this one runs against the side I have just been strengthening. The Letter to Diognetus is routinely enlisted for the proposition that Christians are aliens everywhere and so should sit lightly to national membership. The text says something more careful:
πατρίδας οἰκοῦσιν ἰδίας, ἀλλ’ ὡς πάροικοι· μετέχουσι πάντων ὡς πολῖται,
καὶ πάνθ’ ὑπομένουσιν ὡς ξένοι· πᾶσα ξένη πατρίς ἐστιν αὐτῶν, καὶ πᾶσα πατρὶς ξένη.
"They reside in their own fatherlands, but as if they were non-citizens;
they take part in all things as if they were citizens and suffer all things as
if they were strangers; every foreign country is a fatherland to them, and
every fatherland is to them a foreign country."
Ad Diognetum 5.5
They dwell in fatherlands of their own — πατρίδας ἰδίας — and share in all things as citizens, ὡς πολῖται. The alienage the author describes is eschatological, not civic. He presupposes that Christians have a native country and live in it in the ordinary way, bearing its burdens. The text will not carry the weight of an argument that political membership is a matter of indifference to the baptised, and I have myself used it too loosely in the past.[21]
Nor does Augustine baptise any earthly empire. The line the restrictionists never tire of quoting — “remove justice, and what are kingdoms but great robberies” — is not a defence of state authority but an indictment of imperial power that has lost its title to be called just; the pirate’s answer to Alexander is the point of the passage, and it is a rebuke to the emperor, not to the pirate.[22] Revelation 13 stands beside Romans 13 in the same Testament: the authority can become a beast. Acts 5:29 remains the escape clause.
So the honest position is this. Romans 13 authorises government, including coercive government. It does not dictate the membership rule of a modern nation-state. The Torah constitutes a distinct people with borders of covenant and land, and binds that people to the resident alien living under its roof. The Fathers defend order and almsgiving at once, and they do not answer the question whether section 1(1)(b) should survive. Patristic quotations assembled to bless a clause in an Act of Parliament are doing advocacy. So are quotations assembled to dissolve the difference between citizen and guest.
A restrictionist who wishes to remain inside the tradition must make a narrower claim than is usually made on his behalf: that the Church’s duty of hospitality is not identical with the Magistrate/State’s duty to keep a people; that a charity which abolishes the distinction between member and non-member is not charity but an abdication of the office St. Paul describes; and that a nationality law which cannot say no, or cannot revoke a status obtained by fraud or forfeited by treason, has ceased to be law in the sense Romans 13 assumes. That claim is defensible. It is also, in substance, section 2241 of the Catechism, which is why it needs no proof-texting to sustain it.
A critic inside the same tradition answers: a people which uses Romans 13 to harden itself against the vulnerable has forgotten Egypt, the manger, and the sheep and the goats; a deprivation power that in practice can only fall upon those with a second nationality is not impartial justice whatever its stated ground; and children born here to settled parents are not wrongdoers under Romans 13:4. Both readings use real texts. Neither is the plain sense of St. Paul on a first-century Roman road.
VII
What “Justified” Can and Cannot Mean
If justified means that the New Testament requires a particular amendment, the claim is false. Scripture does not know the British Nationality Act.
If justified means that a Christian account of the Magistrate/State can support a harder membership rule than 1981 left in place, the claim is available. It runs through the office of the sword, the reality of particular peoples, the moral difference between guest-friendship and political equality, and the refusal to treat unlawful presence as a ripening entitlement. It has to live with its costs, which are not rhetorical: the risk of statelessness, a tiered citizenship, family rupture, and the standing Christian suspicion of any state that acquires too much power over the name of a person.
But the argument of this article is not finally about how tight the rule should be. It is about where the rule should live. The most consequential restriction now operating on access to British citizenship was not enacted; it was published. It was applied retrospectively to conduct decades old, defended on the footing that the word normally preserves discretion, revised twice under litigation pressure, and upheld in a case which did not reach its hardest grounds. The statutory bar which preceded it was repealed as unworkable, but its substance survived in a document any minister may rewrite on a Tuesday.
That is the point at which Romans 13 becomes genuinely relevant, and not as a slogan. St. Paul commends an authority which is ordered, which is answerable, whose burdens are known and whose demands can be met — taxes to whom taxes are due, revenue to whom revenue, honour to whom honour. What he describes is a magistracy exercising a public office by public means. Government by guidance is not that. It is the exercise of a real power by an instrument designed to be unaccountable to the ordinary process, and it is no more attractive when it produces a rule I favour than when it produces one I do not.
So the constructive position is this. Let Parliament decide what the United Kingdom is willing to be, and let it decide in statute. If the settled-parent route at section 1(1)(b) should go, repeal it. If illegal entry should bar naturalisation permanently, enact that bar and defend it in the division lobby and at the next election, where the people whose membership is at stake can at least see who has done it. If deprivation should extend to serious organised crime, say so in the Act, with the safeguards written in. And if none of that can command a majority, then it should not be achieved by other means. A Christian may in conscience want the harder rule. He should not want it smuggled.
If Parliament tightened the Act along these lines, it would not be applying Romans 13. It would be making a political judgment about the size and character of the people this country is willing to be, and some Christians would recognise that judgment as congruent with the Magistrate/State’s task while others would call it a failure of hospitality dressed as order. The texts will not break the tie. They forbid only the sentimental pretence that membership is meaningless, and the opposite pretence that the stranger has no claim upon the conscience of those who govern.🟥
[1] British Nationality Act 1981 (c. 61), s. 1(1) and s. 50(2)–(4) (definition of “settled”). The Act came into force on 1 January 1983.
[2] BNA 1981, ss. 1(1)(b), 1(3), 1(4), 2(1)(a), and Sch. 1 paras 1–2. Section 1(4) requires that the child have been in the United Kingdom for the first ten years of life with no more than ninety days’ absence in each year, subject to discretion.
[3] BNA 1981, s. 40, as substituted by the Nationality, Immigration and Asylum Act 2002 (c. 41), s. 4, and amended by the Immigration, Asylum and Nationality Act 2006 (c. 13), s. 56; the Immigration Act 2014 (c. 22), s. 66; and the Nationality and Borders Act 2022 (c. 36), s. 10 (notice).
[4] BNA 1981, s. 40(2), (4), (4A); Immigration Act 2014, s. 66. The statelessness prohibition tracks the Convention on the Reduction of Statelessness (New York, 30 August 1961), Art. 8, to which the United Kingdom made a declaration under Art. 8(3).
[5] Illegal Migration Act 2023 (c. 37), ss. 30–37; Border Security, Asylum and Immigration Act 2025, s. 38, repealing ss. 30–37 with effect from 2 December 2025. For the ministerial characterisation see Public Bill Committee, Border Security, Asylum and Immigration Bill, 11 March 2025.
[6] Home Office, Nationality: good character requirement, version 6.0 (published 10 February 2025), p. 50. Applications submitted on or before 10 February 2025 continued to be assessed under the earlier ten-year rule.
[7] R (Alibiari) v Secretary of State for the Home Department [2026] EWHC 1623 (Admin) (30 June 2026); Home Office, Nationality: good character requirement, version 7.0 (30 April 2026); Immigration and Asylum Act 1999 (c. 33), s. 31; Convention Relating to the Status of Refugees (Geneva, 28 July 1951), Arts 31 and 34.
[8] Deprivation of Citizenship Orders (Effect during Appeal) Act 2025 (c. 25), s. 1, inserting BNA 1981, s. 40A(2B); in force 27 October 2025. See N3 (ZA) v Secretary of State for the Home Department [2025] UKSC 6.
[9 ]Novum Testamentum Graece, ed. Barbara and Kurt Aland et al., 28th rev. ed. (Stuttgart: Deutsche Bibelgesellschaft, 2012), ad loc. English renderings in what follows are my own unless noted.
[10] Irenaeus, Adversus haereses V.24.2, in Sources Chrétiennes 153, ed. A. Rousseau, L. Doutreleau and C. Mercier (Paris: Cerf, 1969).
[11] Augustine, De civitate Dei XIX.13, 17, in CCSL 48, ed. B. Dombart and A. Kalb (Turnhout: Brepols, 1955). See also Ep. 138 to Marcellinus, in CSEL 44, ed. A. Goldbacher (Vienna: Tempsky, 1904), answering the charge that Christian teaching is incompatible with the duties of the commonwealth.
[12] Thomas Aquinas, Summa theologiae I-II, q. 105, a. 3, resp. and ad 1, in Opera omnia iussu Leonis XIII P. M. edita, vol. 7 (Rome, 1892).
[13] C. E. B. Cranfield, A Critical and Exegetical Commentary on the Epistle to the Romans, ICC, 2 vols (Edinburgh: T. & T. Clark, 1975–79), 2:651–66; E. Käsemann, Commentary on Romans, trans. G. W. Bromiley (Grand Rapids: Eerdmans, 1980), 350–59.
[14] Tacitus, Annales XIII.50–51.
[15] Suetonius, Divus Claudius 25.4; Acts 18:2.
[16] For the first position, J. K. Hoffmeier, The Immigration Crisis: Immigrants, Aliens, and the Bible (Wheaton, IL: Crossway, 2009); for the second, M. D. Carroll R., Christians at the Border: Immigration, the Church, and the Bible, 2nd ed. (Grand Rapids: Brazos, 2013).
[17] Ambrose, De Nabuthae, in CSEL 32/2, ed. C. Schenkl (Vienna: Tempsky, 1897); Basil, Homilia in illud Lucae, Destruam horrea mea, PG 31, 261–277.
[18] Pius XII, Exsul familia nazarethana (1 August 1952), AAS 44 (1952); John XXIII, Pacem in terris (11 April 1963), §§ 25, 106, AAS 55 (1963); Second Vatican Council, Gaudium et spes (7 December 1965), § 66.
[19] Catechismus Catholicae Ecclesiae, § 2241. Cf. § 2242 on the limits of obedience where the civil authority commands what is contrary to the moral order.
[20] Augustine, De doctrina christiana I.27.28, in CCSL 32, ed. J. Martin (Turnhout: Brepols, 1962); Francis, Letter to the Bishops of the United States of America, 10 February 2025.
[21] Ad Diognetum 5.5, in Sources Chrétiennes 33bis, ed. H.-I. Marrou (Paris: Cerf, 1965).
[22] Augustine, De civitate Dei IV.4, in CCSL 47, ed. B. Dombart and A. Kalb (Turnhout: Brepols, 1955).

