2017] Citizenship Stripping Laws in the UK, Canada and Australia 23 lead to the same consequences for all citizens, as only dual citizens were vulnerable to citizenship revocation. By contrast, the revocation provisions did not seem particularly welladapted to any security purpose. A major reason for this was the requirement of a criminal conviction before most grounds for citizenship revocation could take effect.110 While this was an important safeguard in the Canadian law, it arguably weakened any security justifications for citizenship stripping as any security threat posed could be neutralised by criminal sanction. Each of the conviction-based grounds for denationalisation had a minimum sentence threshold that had to be met before a person became a candidate for citizenship revocation. For most offences a sentence of life imprisonment was required, with the result that the additional consequence of citizenship stripping was likely to be of minimal practical utility.111 However, for some offences, a minimum sentence of five years’ imprisonment sufficed to trigger the possibility of denationalisation.112 Additionally, as is the case in the UK, Canada’s citizenship stripping laws overlapped with other powers that can be used to exclude Canadian citizens from Canadian territory on national security grounds. The Canadian government holds a prerogative power over passports.113 The Canadian Passport Order, SI/81-86 clarifies that this includes a ministerial power to revoke a passport where the Minister ‘has reasonable grounds to believe that [this] is necessary to prevent the commission of a terrorism offence … or for the national security of Canada or a foreign country or state’.114 Though details of Canadian passport revocation decisions are not publicly available, the Canadian government stated 110 Strengthening Canadian Citizenship Act (n 95) s 8, amending Canadian Citizenship Act (n 8) s 10(2), the latter as repealed by Canadian Citizenship Amendment Act (n 95) s 3(1). See also Forcese and Mamikon (n 12) 334–5. 111 Strengthening Canadian Citizenship Act (n 95) s 8, amending Canadian Citizenship Act (n 8) ss 10(2)(a), (c)–(e), (g)–(h), the latter as repealed by Canadian Citizenship Amendment Act (n 95) s 3(1). 112 This lower threshold applied to terrorism offences under s 2 of the Criminal Code, RSC 1985, c C-46 (or offences committed overseas that, if committed in Canada would qualify as such) (Strengthening Canadian Citizenship Act (n 95) s 8, amending Canadian Citizenship Act (n 8) s 10(2)(b), the latter as repealed by Canadian Citizenship Amendment Act (n 95) s 3(1)) and to terrorism offences as defined in s 2(1) of the National Defence Act, RSC 1985, c N-5 (Strengthening Canadian Citizenship Act (n 95) s 8, amending Canadian Citizenship Act (n 8) s 10(2)(f), the latter as repealed by Canadian Citizenship Amendment Act (n 95) s 3(1)). 113 See, eg, Canadian Passport Order, SI/81-86, s 4(3). 114 Ibid s 10.1. Advance Copy