JOURNAL OF CONTEMPORARY EUROPEAN STUDIES  37 deprivation before the Committee supervising the implementation of the UN Convention against Torture. The Committee found the applicant to have been deprived of nationality with a view to make him an irregular immigrant liable to expulsion. It is worth stressing that French courts have refused to acknowledge any links between citizenship deprivation orders and expulsion (Mantu 2015, 277). Arguments that a citizenship deprivation order leading to expulsion violates Article 8 ECHR were dismissed on the argumentation that the citizenship deprivation order does not force one to leave France; it is rather the separate expulsion order that has that effect. In light of how the French executive has justified the need to amend citizenship deprivation powers, politically (at least) the link between deprivation and expulsion is clearly there. Despite the change operated in 2006, the French executive has not used citizenship deprivation extensively: since 1973 there are 13 reported cases of citizenship deprivation for acts of terrorism and acts against the fundamental interest of the nation. Yet, several proposals were made to make it easier to deprive of citizenship, not all connected with the fight against terrorism per se. 2010 saw two failed proposals aimed at amending the rules to allow citizenship deprivation as sanction for polygamy, and to punish citizens of foreign origin condemned for the murder of a person holding public authority if they had been citizens for less than 10 years. The second proposal was linked to violent clashes between the police and inhabitants of the ‘banlieues’ and was eventually abandoned in order to reach cross-party support for the adoption of a new security law (Mantu 2015, 267). Since 2012, France experienced terrorist attacks committed by French citizens and their timeline coincides with proposals put forward to amend the citizenship deprivation provisions and the French Constitution. These proposals aimed to make it easier to deprive of citizenship French citizens who have committed attacks in France or travelled abroad to fight in Syria or Mali. Most of them are French-born dual nationals whose citizenship cannot be taken away since it was acquired at birth. Historically, French citizens by birth have never been covered by the scope of legal provisions on citizenship deprivation and there is an ongoing discussion as to whether one can speak of a constitutional and Republican principle preventing such Frenchmen from losing their nationality (Finchelstein 2017, 106–108). In 2014, the UMP made fresh proposals to deprive of citizenship all French dual nationals if arrested, caught, or identified fighting against the French armed forced, their allies, or the French police forces. The proposal aimed to remove the time limit within which citizenship deprivation can occur and allow the executive to deprive of citizenship in the absence of the approval of the Council of State. It was rejected by the Constitutional Law Commission of the French Parliament and failed to reach enough votes during the debates in the National Assembly. After the November 2015 Paris attacks, French President Hollande announced his intention to change the law in order to allow French citizens irrespective of how they had acquired it to be deprived of their status where they had been condemned for a crime or offence that constitutes a serious violation of the Nation’s life or an act of terrorism. Citizenship deprivation was intended to operate as a complementary sanction and applicable in cases of direct financing of terrorism, individual acts of terrorism, and participation in a criminal group or constitution of a criminal group that intends to commit terrorist acts. After much trepidation on whether such changes could be introduced via ordinary legislation (Finchelstein 2017, 102), the Council of State recommended that they be operated via an amendment to the French Constitution. The changes were included in a bill aiming to introduce new emergency powers in the French Constitution as a result of the 2015 attacks. Because the prohibition