All Citizens are Created Equal, but Some are More Equal Than… 423 and practice on withdrawal of nationality leads to a rather different outcome if these standards are taken as the point of departure. As set out in Sect. 3, where states target only naturalised citizens and/or dual citizens for denationalisation, this unequal treatment grounded on differences in citizenship status can bleed into indirect discrimination on the basis of ethnicity, race or religion—and therefore be considered ‘arbitrary’ under international law. As the UN Special Rapporteur on contemporary forms of racism, racial discrimination, xenophobia and related intolerance wrote: Rarely do States explicitly discriminate on the basis of race, ethnicity or national origin in their citizenship stripping process. However, overbroad policies ostensibly rooted in national security concerns permit arbitrary enforcement—including arbitrary deprivation of citizenship—which in practice have a disproportionate effect on marginalised racial, national and religious groups. 51 The statelessness-specific rules contained in the 1961 Convention must be interpreted in light of the broader principle of equality and non-discrimination that has been extensively codified in all core human rights treaties that were adopted after the 1961 Convention.52 According to the Human Rights Council (HRC), arbitrary deprivation of nationality, especially on discriminatory grounds such as ‘race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth, or other status, including disability’ is a violation of human rights and fundamental freedoms.53 Law, policies and practices that disproportionately exclude or have a negative impact on a particular racial, ethnic or national group should also be considered as a breach of the prohibition of racial discrimination. This is true even in the absence of de jure or intentional discrimination.54 In fact, understood in this light, even the 1961 Convention itself can be read differently. Often overlooked in discussions of this topic, Article 9 of the 1961 Convention reads: ‘A Contracting State may not deprive any person or group of persons of their nationality on racial, ethnic, religious or political grounds’. So, while the primary purpose of the 1961 Convention is to reduce the incidence of statelessness, the treaty itself recognises that there is a broader international principle at stake that must be applied as a blanket rule—separate from and regardless of the question of whether the result of denationalisation is statelessness. The ECN is also concerned 51 UN Human Rights Council (2018), pp. 17–18. Among others in: the International Covenant on Civil and Political Rights, Art. 2; the International Covenant on Economic, Social and Cultural Rights, Art. 2; the Convention on the Elimination of Racial Discrimination, Art. 5; the Convention on the Rights of Persons with Disabilities, Art. 3; the Convention on the Rights of the Child, Art. 2; Convention on the Elimination of Discrimination against Women, Arts. 2 and 3. Please note that this is a non-exhaustive list of discriminatory grounds. 53 UN Human Rights Council (2016), para. 4. 54 UN Human Rights Council (2018), p. 9. 52 123