JOURNAL OF CONTEMPORARY EUROPEAN STUDIES  33 The British executive was dissatisfied with its 2002 powers due to failures to deprive in certain cases. The Muslim cleric Abu Hamza was issued with a citizenship deprivation order in 2003 due to radical preaching but SIAC decided that Hamza could be not deprived of citizenship since he would be made stateless as Egypt, his country of original nationality, had probably withdrawn it (Abu Hamza v. SSHD, SIAC, SC/23/2003). Another case concerns David Hicks, an Australian national converted to Islam who was held in Guantanamo. In 2005, he applied for registration as an UK national with the hope that the UK Government would negotiate his release from prison, as it had done with other British citizens held there. The SSHD announced the intention to deprive Hicks of citizenship since he had engaged in behavior seriously prejudicial to the interests of the UK while receiving terrorist training. The order was blocked in court on grounds that conduct prior to the acquisition of citizenship was not enough to show current disaffection or disloyalty (SSHD v. David Hicks [2006] EWCA Civ 400). These failures led to procedural changes that removed the suspensive effects of appeals: as of 2004, citizenship deprivation orders have immediate effects, the deprived citizen becomes a foreigner subject to immigration control and expulsion from the moment the order is made (Mantu 2015, 220–224). If outside the UK when deprived of citizenship (G1 v. SSHD [2010] EWCA Civ 867), an exclusion order can be made preventing the person from entering the UK, leading to an out of country appeal. In those cases where the aim is to remove citizenship to be able to expel the person concerned or prevent him from returning to the UK, such practices can be seen as violating the prohibition of arbitrary deprivation of nationality and the right to enter one’s own country. Wider citizenship deprivation powers were introduced by the Immigration, Asylum and Nationality Act 2006. The Act was proposed prior to the 2005 London attacks perpetrated by ‘home grown’ terrorists but its negotiation in Parliament was influenced by these events and the need to deal with ‘terrorist’ citizens. The 2006 Act allowed the SSHD to issue a citizenship deprivation order if satisfied that the measure was ‘conducive to the public good’. Parliamentary debates portray citizenship deprivation as a counter-terrorism measure linked to national security, which in itself was broadly constructed to include also ‘threats to individual citizens and to our way of life’ (Mantu 2015, 196). The Secretary of State explained that ‘the whole point of the measure is to be able to remove certain people from the United Kingdom, which currently we are unable to do’ (HC 2014, col 1043), as it would contravene legal standards that prevent states from expelling own nationals. Conduciveness to the public good is a test applicable to the expulsion of foreigners, which points toward a process of legal fuzziness whereby protections generally associated with the legal status of citizenship are reformulated, while citizens and foreigners are seen as part of the same security continuum (Bigo 2002). By relying on conduciveness to the public good to deprive of citizenship British dual nationals, the UK Government effectively equates them with foreigners in as far as protection against deprivation is concerned. For the purposes of citizenship deprivation, ‘conducive to the public good’ is not defined by law but the executive explained its reach as including ‘involvement in terrorism, espionage, serious organized crime, war crimes or unacceptable behaviors’ (Gower 2015). When tested in court, ‘conducive to the public good’ was clarified only to the extent that it involves cases where deprivation is deemed to be in the interests of national security. Al-Jedda is one of the few cases in which British courts reviewed the limits of the SSHD to deprive on conducive to the public good grounds. Mr. Al-Jedda entered the UK as an asylum seeker and later acquired UK citizenship. In 2004, he was retained by coalition forces in Baghdad and detained without charges in

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