6 Melbourne University Law Review [Vol 41(2):Adv single jurisdiction.12 While our article touches on these themes, its primary contribution is to add to a smaller body of work that conducts cross-jurisdictional comparisons of approaches to citizenship stripping. To date, there are a few published comparisons of this nature examining the UK and Canadian denationalisation laws,13 but there is minimal analysis factoring in the recent Australian legislation.14 Further comparison of the legislative experiences of these three countries, including Canada’s move to repeal its laws, is worthwhile. The UK, Canada and Australia are the only common law countries to have recently reemployed citizenship stripping as a national security device. These countries are logical comparators because they share common foundations for their models of citizenship: Canada and Australia originated as UK colonies and imported the UK’s conceptualisation of citizenship upon their inception.15 Moreover, as this article reveals, there are a number of similarities between the justifications invoked in the three countries for expanding the grounds for denationalisation, while the justifications for repealing these expansions in Canada serve as a useful counterpoint. In light of the historical and contemporary parallels between the three countries, examining their recent experience with denationalisation laws enables the early anticipation of themes and patterns that may underpin security-based citizenship stripping in common law countries. That is the larger project of this article. 12 See, eg, Hina Majid ‘Protecting the Right to Have Rights: The Case of Section 56 of the Immigration, Asylum and Nationality Act 2006’ (2008) 22 Journal of Immigration Asylum and Nationality Law 27; Alice Ross, ‘Deprivation of Citizenship: What Do We Know?’ (2014) 28 Immigration, Asylum and Nationality Law 316; Matthew J Gibney, ‘The Deprivation of Citizenship in the United Kingdom: A Brief History’ (2014) 28 Immigration, Asylum and Nationality Law 326; Eric Fripp, Rowena Moffatt and Ellis Wilford (eds), The Law and Practice of Expulsion and Exclusion from the United Kingdom: Deportation, Removal, Exclusion and Deprivation of Citizenship (Hart Publishing, 2015); Craig Forcese and Ani Mamikon, ‘Neutrality Law, Anti-Terrorism, and Foreign Fighters: Legal Solutions to the Recruitment of Canadians to Foreign Insurgencies’ (2015) 48 UBC Law Review 305; Helen Irving and Rayner Thwaites, ‘Australian Citizenship Amendment (Allegiance to Australia) Bill 2015 (Cth)’ (2015) 26 Public Law Review 143; Lucia Zedner, ‘Citizenship Deprivation, Security and Human Rights’ (2016) 18 European Journal of Migration and Law 222; Kim Rubenstein and Jacqueline Field, Australian Citizenship Law (Lawbook, 2nd ed, 2017) 260–77. 13 See, eg, Craig Forcese, ‘A Tale of Two Citizenships: Citizenship Revocation for “Traitors and Terrorists”’ (2014) 39 Queen’s Law Journal 551; Audrey Macklin, ‘Citizenship Revocation, the Privilege to Have Rights and the Production of the Alien’ (2014) 40 Queen’s Law Journal 1. 14 But see Pillai and Williams (n 9). 15 See ibid 523–5. Advance Copy