72 SECTION I.B.2 see Section I.B.1 (Chapter I), pg 66 deprivation of his Indian citizenship under Section 10 of the Act. The Court held that the statute contained several implied limits upon the State’s power to deprive citizenship. The first is that the authority must satisfy that the ‘continuation of citizenship of that person is “not conducive to the public good”’.112 Secondly, this deprivation must be preceded by a fair administrative hearing in consonance with the principles of natural justice, which was also denied to the petitioner. Since ‘public good’ has not been defined in any statute anywhere, the Court used this opportunity to compare this Act with analogous nationality statutes in common law jurisdictions and arrive at common juridical principles underlying all of them. The Court then explicitly read the avoidance of statelessness as an additional implied curtailment on the government under Section 10 of the Act. It held that although statelessness is not explicitly mentioned in the statute and though India is not a signatory to the statelessness conventions, the status of these treaties and widespread international state practice clarify the scope of the sovereign prerogative. Although the Court does not explicitly recognise the emerging customary international law obligation on the states to prevent and reduce statelessness [↘] here, it seems to be suggesting exactly that. Hence, the threshold for deprivation of nationality for ‘public good’ is very high, and it is even higher when such deprivation would result in statelessness for the individual. Since deprivation would render the petitioner stateless in this scenario, the committee’s decision was set aside. These cases demonstrate the Indian judiciary’s efforts to prevent and reduce statelessness by liberally interpreting citizenship laws and recognising international law obligations. 112 ibid. SECURING CITIZENSHIP