34  S. MANTU Basra until 2007. He was released after a successful ECHR challenge to his detention but the SSHD issued almost concomitantly a citizenship deprivation order on conducive to the public good grounds linked to his involvement with terrorist groups. SIAC confirmed that it had the power to review the decision of the executive to deprive of citizenship, even if it had to give great weight to the SSHD’s assessment of conduciveness to the public good arguments. Suspicion of involvement in terrorism or acts threatening national security is not enough to justify a citizenship deprivation order, but past events could be taken into consideration to assess the threat posed by the citizen, which signals a departure from the Hicks case. The standard of review is that of ‘balance of probabilities’, which is lower than in criminal cases. Relying on this test, SIAC found the deprivation order conducive and based on the openly accessible part of the judgment, the applicant’s (lack of ) credibility played an important role in its decision (Al-Jedda v.SSHD, SC/66/2008). Although a threat to national security, Mr. Al-Jedda could not be deprived of citizenship since he would have been made stateless (Al-Jedda v. SSHD [2010] EWCA Civ 358) prompting the executive to seek new amendments to its powers to deprive. While defending the introduction of the 2014 Act in Parliament, the SSHD cited Al-Jedda as a reason for removing protection against statelessness (HC 2014, col 1040). The Immigration Act 2014 removed partly the guarantees introduced in 2002 concerning the prohibition of statelessness, making it clear that the UK was not going to ratify the ECN. Where a person acts in a manner seriously prejudicial to the vital interests of the UK, the SSHD can deprive of citizenship even if the person becomes stateless, provided that nationality was obtained through naturalization. The Home Secretary must have reasonable grounds to believe that the person can acquire a new nationality when making the order but there is no guidance on what such grounds entail. There is no guarantee that the person will not remain stateless (Harvey 2014) since the UK Government does not have the power to interfere with the nationality decisions of other states, and international standards do not guarantee reacquisition of a previously held nationality. Similar to the 2002 and 2006 amendments, the 2014 powers have been questioned in relation to equality of treatment between naturalized citizens and citizens by birth, procedural aspects, and the ineffectiveness of citizenship deprivation in countering terrorism and fundamentalism (House of Commons Debates 30 January 2014, cols 1039-1052 and 1104). A recurrent concern is that the executive prefers to use its administrative power to deprive suspected terrorists of their citizenship, which makes it easier to expel them, rather than subject them to the purview of criminal law with its higher procedural standards, a practice that is problematic in light of UK’s human rights obligations. These arguments were overshadowed by the executive’s claim that citizenship deprivation was necessary in relation to national security, and the threat posed by radicalized UK citizens travelling to join the civil war in Syria. After three changes to citizenship deprivation powers, the number of persons deprived remains low. In 2015, the Bureau of Investigative Journalism stated that since 2010, when the Conservatives came to power, 33 dual nationals have been deprived of their UK citizenship, and most of them were abroad when the order was made (Parson 2016). The 2014 powers have never been used in respect of naturalized citizens, which can be seen as encouraging, but also highlighting their symbolic nature. Despite assurances to the contrary (Home Office 2014), the UK executive relies on deprivation powers against citizens who are outside of the UK and against who return orders are issued preventing them from returning to the UK to launch appeal procedures in person (Woods, Ross, and Wright 2013). Appeals to