2017] Citizenship Stripping Laws in the UK, Canada and Australia 35 would leave ‘no doubt whatsoever’ as to the government’s power to exclude a person from Australian territory.182 As a number of constitutional lawyers have noted, however, there are doubts about the scope of the Commonwealth’s constitutional power to revoke citizenship.183 Within Australia, terror-related offences carry high criminal penalties.184 Moreover, in addition to the offence of engaging in a terrorist act, of which a person can only be convicted after an act of terrorism has been carried out, there are a wide range of offences that are designed to mitigate the risk of terrorism eventuating. For instance, there are offences that criminalise conduct preparatory to a terrorist act, including: ‘[p]roviding or receiving training connected with terrorist acts’;185 ‘[p]ossessing things connected with terrorist acts’;186 ‘[c]ollecting or making documents likely to facilitate terrorist acts’;187 and doing any ‘[o]ther acts … in preparation for, or planning, terrorist acts’.188 These offences carry lengthy maximum penalties, ranging from 10 years’ imprisonment to life imprisonment. In addition, it is a crime, punishable by life imprisonment, to ‘engage[] in a hostile activity in a foreign country’,189 to make preparations for such activity,190 or to ‘enter[] a foreign country with the intention of engaging in [such] activity’.191 It is also an offence, with a maximum penalty of 10 years’ imprisonment, for a person to enter or remain in particular areas that are designated by the executive as no-go zones, on the basis that they are hotbeds for terrorist training and activity.192 Such offences are designed to 182 Commonwealth, Parliamentary Debates, Parliamentary Joint Committee on Intelligence and Security, 4 August 2015, 23. 183 See, eg, Sangeetha Pillai, ‘The Allegiance to Australia Bill and the Constitution: Legislative Power and Membership of the Constitutional Community’, AUSPUBLAW (Blog Post, 21 July 2015) <https://auspublaw.org/2015/07/the-allegiance-to-australia-bill-and-theconstitution/>, archived at <https://perma.cc/8TSY-2XCU>; Irving and Thwaites (n 12); Sangeetha Pillai, ‘Citizenship-Stripping Reforms Open to Challenge in Spite of Safeguards’ (2016) 3(19) LSJ: Law Society of NSW Journal 74, 75. 184 See, eg, Criminal Code Act 1995 (Cth) divs 101–3, 119. 185 Ibid s 101.2. 186 Ibid s 101.4. 187 Ibid s 101.5. 188 Ibid s 101.6. See generally George Williams, ‘A Decade of Australian Anti-Terror Laws’ (2011) 35 Melbourne University Law Review 1136. 189 Criminal Code Act 1995 (Cth) s 119.1(2)(a). 190 Ibid s 119.4. 191 Ibid s 119.1(1)(a). 192 Ibid s 119.2(1). Advance Copy