in Britain was still pending, Pham was extradited to the United States to face terrorism charges.144 As researcher Nisha Kapoor points out in her 2018 book on the erosion of civil liberties under the “war on terror,” Pham’s case reflects the “ideological and legal-technical progression” of denationalization in the UK.145 In Pham’s case, ultimately, his statelessness was “legitimated” through a series of steps,146 beginning with the expansion of citizenship deprivation in practice from 2001, continuing with the narrative reformulation of citizenship as a privilege rather than a right, and finally bolstered by the 2014 BNA amendments, which countenance the creation of statelessness in the name of national security. As the Pham and Al-Jedda cases suggest, appeal from a deprivation order is available, however the right may be eviscerated if the Home Secretary certifies the decision was based on information that should not be made public. In such cases, appeal is available to the Special Immigration Appeals Commission, a regime of special courts affording limited review of national security cases in which secret evidence is withheld from litigants and their counsel. An individual can appeal on the grounds of both the legality of the action and the merits of the Home Secretary’s decision. Although an appeal is technically possible while the individual is abroad, there are significant challenges preventing appeals from being lodged, including lack of access to consular services and a 28-day deadline for lodging appeals.147 The Home Secretary also has the power to issue temporary exclusion orders while British citizens are abroad, in instances where such an order may be “reasonably necessary” to protect the public from terrorism. This determination can be made by the Home Secretary without any advance notice to the citizen concerned.148 In May 2013, then Home Secretary Theresa May issued a Written Ministerial Statement invigorating her Royal Prerogative power to remove passports from British citizens by affirming that there is “no entitlement to a passport and no statutory right to have access to a passport.”149 The statement also asserted that the discretionary criteria for making passport revocation decisions included “proposed” activities, in other words, the Home Secretary reserved the right to revoke passports from British citizens preemptively.150 Canada In Canada in 2015, the Conservative government of Prime Minister Stephen Harper passed Bill C-24 to expand citizenship-stripping powers under the Strengthening Canadian Citizenship Act (SCCA). The law, which came into force in June 2015, permitted denationalization of Canadian dual citizens “born abroad” for acts against “the national interests of Canada.” 151 The law was challenged in the courts, and Justin Trudeau made the security of citizenship as a right (not a privilege) a central component in his 2015 election campaign. In 2016, Canada reconsidered and repealed Bill C-24. Trudeau’s government introduced Bill C-6, which I. History and Context 39