2017] Citizenship Stripping Laws in the UK, Canada and Australia 15 which the Home Secretary noted that, due to a change in Iraqi law after al-Jedda attained UK citizenship, he had the opportunity to reacquire Iraqi citizenship.62 The Home Secretary argued that, consequently, the deprivation order did not make al-Jedda stateless, as he was entitled to obtain another citizenship.63 The Court dismissed this submission, noting that it would ‘mire the application of the [provision] in deeper complexity’,64 and unanimously found in al-Jedda’s favour. The introduction in 2014 of a power to revoke citizenship in certain circumstances even if statelessness would ensue was a direct response to the government’s lack of success in this case. A number of inferences can be drawn from the way in which the UK’s denationalisation laws have been employed and expanded. First, the continued expansion of citizenship revocation powers, coupled with sparing, inefficient use of these powers between 2002 and 2009, suggests that the impetus for the changes made during this period was more symbolic than security based. Each revision to the law served as a symbolic statement that particular types of citizens did not deserve to retain their citizenship and remain members of the community. This was underlined by statements in Parliament and by the government describing citizenship as a ‘privilege’ rather than a right, and affirming that citizens owe a duty of allegiance to the state.65 At the same time, the modest use of the citizenship stripping powers, at least prior to 2009, suggests that in a practical sense, the powers were not critical to achieving the UK’s national security objectives.66 A question arises as to what factors precipitated the sharp increase in use of the revocation laws from 2010 onwards. In part, the higher number of revocations may be a response to the new security risk posed by increased numbers of foreign fighters. However, significant increases in foreign fighter activity only commenced in 2011.67 This suggests that, at least initially, the increase in use of 62 Ibid 266–7 [23], [25]. 63 See ibid 255. 64 Ibid 269 [32]. 65 See n 44. 66 A less obvious point is that the laws also mark a shift away from the idea that citizenship is tethered to allegiance. The current revocation threshold in UK law generally allows a person to be stripped of their citizenship whenever this would be ‘conducive to the public good’: British Nationality Act 1981 (UK) s 40(2). This does not require any non-allegiant conduct on the citizen’s part. Thus, attempts to justify the revocation laws as an affirmation of the fact that citizens owe a duty of allegiance to the state do not seem to provide an adequate explanation for their enactment. 67 See, eg, Institute for Economics and Peace, Global Terrorism Index: Measuring and Understanding the Impact of Terrorism (Report No 36, November 2015) 45. Advance Copy