All Citizens are Created Equal, but Some are More Equal Than… 417 International Law Commission (ILC) published a memorandum that gives an overview of the common nationality deprivation grounds that existed around the world at that time.18 While some grounds applied to all citizens, the study also pointed out countries that only apply nationality deprivation grounds to naturalised citizens.19 Loss of nationality could, for instance, occur if a naturalised citizen lives abroad for a specified period of time or if a naturalised citizen fraudulently acquired the nationality. Naturalised citizens could also lose their citizenship if they were convicted of a serious crime within a specified number of years after naturalisation. In some states, ‘denaturalisation’ could take place at any time if a citizen was convicted of treason or for a crime against the security of the state or could be invoked if a naturalised citizen ‘indicated oneself to be disloyal, disaffected or of a mentality contrary to the national spirit’.20 Denaturalisation was the first form of unequal citizenship stripping, causing a divide between naturalised citizens and native-born citizens. Another phenomenon of unequal nationality deprivation apparent at that time was the inequality between men and women. In the early to mid-twentieth century it was deemed in the general interest of the international community to ensure that everyone had a nationality, but one nationality only.21 The prohibition of dual nationality contributed to gender discrimination in nationality revocation measures.22 Women would lose their original nationality upon marriage with a foreign national—a policy justified by states’ desire to prevent dual nationality and avoid mixed nationality marriages that could act as disruptors of social cohesion and blur nationalistic ideals. At the time, the majority of states also provided more generally for nationality revocation in response to the ‘voluntary act of acquiring another nationality’.23 Later, views on dual nationality as well as women’s nationality rights changed and this picture changed with it. Many states no longer prohibit dual nationality, nor does international law seek its eradication, and women’s equal and independent nationality rights are now nearly universally recognised. However, another form of unequal nationality deprivation has meanwhile grown in prominence. The duty to avoid statelessness became an international norm with an increasingly strong influence on nationality deprivation rules.24 In aid of this goal, states have come to limit the application of many denationalisation measures to citizens with more than one nationality, creating inequality in nationality deprivation measures between mono nationals and dual nationals. For instance, in a number of countries, 18 International Law Commission (1953), pp. 1–17. States were listed per denationalisation ground they have in their national legislation. Some grounds specifically applied to naturalised citizens. Other times asterisks were placed behind countries listed under more general deprivation grounds to point out that these states have such a denationalisation ground in their legislation but only applicable to naturalised citizens. 20 International Law Commission (1953). 21 Convention on certain questions relating to the conflict of nationality laws (1930), Preamble. 22 De Hart (2015), p. 171. 23 International Law Commission (1953). 24 Art. 1(1) of the 1954 Convention on the Status of Stateless Persons defines a stateless person as a person who is not considered as a national by any state under the operation of its law. 19 123