All Citizens are Created Equal, but Some are More Equal Than… 425 What evidence is there, in fact, that citizenship withdrawal has any impact on the threat of terrorist attacks? It imposes barriers to lawful return to the country, but terrorism is a global security threat that reaches beyond national borders. Terrorist attacks can be orchestrated from abroad and carried out by others in terrorist networks. Also, being denationalised does not keep a person out of a country: he or she may travel on false papers and continue to pose a threat to society. By taking away the bond of citizenship, governments may actually have less means at their disposal to track or take action against the person and so by turning citizens suspected of terrorism into foreigners, governments are exporting a security threat to the international community. It is therefore difficult to see how, in Barak’s typology, this measure is ‘rationally connected to the fulfilment’ of the purpose increasing security. Indeed, as Esbrook summarised: Expansion of citizenship-stripping proposals fractures international cooperation, provides tacit encouragement to States who use citizenship-stripping as a political tool to consolidate power, normatively sets the international community backwards in its evolution towards rights promotion and individual empowerment, and requires implementation of a new and extreme policy where existing law enforcement tools already exist.60 Finally, to assess the measure’s proportionality, it is also necessary to ask whether less intrusive measures exist to counter terrorism and to protect national security and/or punish a citizen for his/her wrongdoings. Here, it is important to point out that mono nationals and native-born citizens are subject to a plethora of other measures set out in criminal law such as (preventive) detention, passport revocation, monitoring etc.61 In other words, states have found ways to address security threats posed by mono nationals without denationalising them. Why are these measures not simply applied in the same way to all nationals, without the state reaching for the added and far-reaching instrument of citizenship revocation for some? Doing so would prevent the discriminatory application of nationality deprivation measures and its concomitant effect on social cohesion. As Macklin puts it: ‘A man who attacks his mother may be a terrible son who deserves to be prosecuted for his crime, but it is not the job of family law to disclaim him as the son of his mother. Citizenship law is not criminal law. Nor is it national security law. Nor should it be rigged to operate as a trap door that shunts citizens to immigration law’.62 On the contrary, taking seriously the protection of the right to a nationality and (re)asserting the equality of citizenship for all citizens is, in fact, a way for states to bolster the security and integrity of their society—one which accords with the ideals of liberal democracies. As Hirsch Ballin explains: The methods of international terrorism are effectively directed against the foundations of societies based on trust in the rule of law […] Once trust in 60 Esbrook (2016), p. 1305. Paulussen (2016), p. 13. 62 Macklin (2015b), p. 55. 61 123