All Citizens are Created Equal, but Some are More Equal Than… 427 naturalised citizens are equal to birth-right citizens and should be indistinguishable from them, able to participate in the democratic life of the state on the same terms. If their continuing-to-belong is contingent on behaviour, naturalisation serves little purpose and becomes indistinguishable from a form of conditional residence status. Where the naturalised citizen is mistrusted, citizenship stripping is put to work as a weapon which turns badly-behaved citizens into foreigners again, allowing them to be deported, or prevented from re-entering the country and thereby severing the link that has been so painstakingly built up and had received the highest form of legal recognition through the conferral of nationality.67 In respect of the distinction between mono and dual nationals, states have staked their case that this form of inequality is not just allowable under international law, it is mandated by international norms. It is true that it is in the interest of both states and individuals that statelessness be avoided and that this is affirmed by the human right to a nationality. But, as this article has discussed, just as nationality deprivation policies must be understood in their wider societal context, so must the duty on states to prevent statelessness be understood as part of a wider web of international standards and principles. The prohibition of arbitrary deprivation of nationality and the principles of non-discrimination and of proportionality must also be satisfied in any case in which a state seeks to strip one of its citizens of his/her citizenship. How a truly rights-based approach to nationality might prevail where once a more technical approach was taken to the avoidance of nationality ‘problems’ can be illustrated by the evolution of women’s nationality rights under international law (an area of law already referred to in Sect. 2). In 1930, the Convention on certain questions relating to the conflict of nationality laws provided that a woman could only lose her nationality on the basis of marriage with a foreigner if she acquires the nationality of her husband—a measure specifically aimed at preventing statelessness.68 By 1957, the norm had evolved and the Convention on the Nationality of Married Women provided that ‘neither the celebration nor the dissolution of a marriage between one of its nationals and an alien, nor the change of nationality by the husband during marriage, shall automatically affect the nationality of the wife’. This marked an early stage in the recognition of women’s independent nationality rights to men. Today, however, both approaches—while not unhelpful in addressing the nationality problems that women have historically faced—are superseded by the human rights standard contained in Article 9(1) of the Convention on the Elimination of All Forms of Discrimination against Women which states: ‘States Parties shall grant women equal rights with men to acquire, change or retain their nationality’. By analogy then, while it remains of utmost importance to take measures to protect people from being rendered stateless, this norm cannot be invoked in a way that excuses from closer scrutiny policies that withdraw nationality from dual nationals only. As this article set out, it is unclear how nationality revocation as a counter-terrorism measure would ever pass the non-discrimination and proportionality tests prescribed by 67 Brandvoll (2014), p. 213. League of Nations, Convention on Certain Questions Relating to the Conflict of Nationality Law, 13 April 1930, League of Nations, Treaty Series, Vol. 179, p. 89, no. 4137, Art. 7. 68 123