38  S. MANTU of creating statelessness remains intact, the new provisions would have affected primarily French citizens who hold another nationality, thus alluding to their or their parents’ immigrant background. The initiators of the citizenship deprivation reform and the Council of State stressed the limited and primarily symbolic effect of the proposed changes. Moreover, since France is bound by several human rights conventions, concerns were expressed that citizenship deprivation may lead to the creation of de facto stateless persons: persons deprived of French citizenship who cannot be expelled because their country of nationality does not recognize them as nationals or refuses to take them back. In the end, the Constitutional Bill was withdrawn on 30 March 2016 by President Hollande after the failure of the two houses of Parliament to agree on a similar text (Finchelstein 2017, 105). Politically, citizenship deprivation seems to have reached a dead end. Concluding remarks Usually, citizenship deprivation powers are presented as administrative measures, part of counter-terrorism strategies allowing the state to effectively fight terrorist threats (Van Ginkel and Entenmann 2016, 5; 58). At the international and EU levels, there is a trend toward inscribing citizenship deprivation powers within frameworks designed to counter terrorism, including preventing the movement of foreign fighters who pose threats to their home states upon return (Kraehenmann 2014, 55). The two national cases examined in this article suggest that the depiction of citizenship deprivation as a deterrent measure undertaken by states to stop terrorist citizens is to a certain extent reductionist, as it obscures the fact that the transformation of state power to deprive of citizenship started before 9/11 and can be inscribed within a nationality–immigration–security nexus. Terrorism has been credited with starting a process of renegotiation of the social pact that led to the transformation of the very model of citizenry (Salerno 2017, 82). The remaking of the citizenry is not only a social and political process, but also a legal one as it relies on law to impose ideas of how citizens should behave and what happens to them when they misbehave. In line with Salerno’s (2017, 89) observation that ‘the politics of identity and belonging are preliminary to any security action’, it is not so surprising that nationality law due to its strong links with identity (Volpp 2002, 580) becomes one of the sites in which the citizenry is remodeled by making it possible to oust out of its midst ‘terrorist’ citizens. The two cases examined illustrate how citizenship deprivation powers have been amended to this end, as political considerations concerning national security have taken center stage in this process rather than human rights and international nationality obligations. Generally, we can speak of the convergence of legal standards that states must take into account when trying to deprive of citizenship due to the anchoring of nationality issues to human rights. Arbitrary deprivation of nationality is prohibited and understood to include cases where the person is deprived with a view to make expulsion or deportation possible. The prohibition of statelessness should function as a pillar of protection but the existence of divergent legal standards concerning citizenship deprivation on terrorism grounds leading to statelessness (UN v. ECN) complicates matters. It also leads to a variable geometry of protection linked to the different international agreements to which states are bound. The French and the British cases show that, even within Europe, states have not ratified the exact same instruments and that national preferences and national expressions of sovereignty continue to play a role in shaping the protection that citizens can expect

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