18 Melbourne University Law Review [Vol 41(2):Adv citizen after their return to the UK, such as reporting to police and attending a deradicalisation program.83 Where a citizen subject to a TEO is deported from a foreign country to the UK, the TEO scheme does not authorise their exclusion.84 Moreover, where ‘the Secretary of State considers that [such an] individual is to be deported to the United Kingdom’, a permit to return must be issued.85 It is not clear that the Home Secretary’s citizenship deprivation powers add significantly to the protection against security threats that is already achievable via these other broad exclusionary controls. This is especially so because the majority of citizenship revocations are issued while a citizen is overseas,86 such that a TEO could be used to prevent or manage their return to the UK. Notably, citizenship revocation seems to be employed more frequently than the TEO scheme, which Prime Minister Theresa May and Home Secretary Amber Rudd recently admitted had only been used once since its enactment.87 This may be because denationalisation provides a more straightforward means to permanently exile a high-risk citizen from the UK. However, it is not clear that exile serves the UK’s security needs better than the conditional managed return scheme implemented via the CTSA. For instance, as Jessie Blackbourn and Clive Walker have suggested, discouraging the voluntary return of citizens deemed to be security risks carries with it the danger of such individuals adopting terrorism as a way of life, which opens up further risks that they may contribute to the escalation of foreign conflicts or seek to instigate terrorist attacks in the UK from overseas.88 Certainly, in the lead-up to each expansion of the UK’s denationalisation powers, no considered justification for prioritising permanent removal as an anti-terror tool was articulated. It might also be argued that citizenship stripping avoids the problem of having to admit an excluded citizen who is deported to the UK by a foreign country — a feature of the TEO scheme that some commentators have described as a 83 Ibid s 9. 84 Ibid s 2(1)(b). 85 Ibid s 7(1). 86 Ross and Galey (n 41). 87 Peter Walker, ‘Rudd Admits Anti-Terror Exclusion Powers Used Only Once since 2015’, The Guardian (London, 29 May 2017) <www.theguardian.com/uk-news/2017/may/29/uk-usedanti-terror-exclusion-powers-once-since-2015-amber-rudd-admits>, archived at <https:// perma.cc/V3CR-FCS8>; Fiona Hamilton and Lucy Fisher, ‘Jihadist Ban: Theresa May Says Use of Temporary Exclusion Orders Is “a Matter for Police”’, The Times (London, 30 May 2017) <www.thetimes.co.uk/article/may-defends-single-use-of-jihadist-ban-dnxnqr6p3>, archived at <https://perma.cc/F48Z-CCC9>. 88 Blackbourn and Walker (n 80) 852. Advance Copy