2017] Citizenship Stripping Laws in the UK, Canada and Australia 37 manner in which allegiance is central to the state–citizen relationship. Secondly, while many of the grounds for citizenship-loss hinge upon conduct that suggests a lack of allegiance to Australia, this is not true of all grounds. For instance, the ground that enables citizenship-revocation on the basis of a conviction for entering an area declared a no-go zone does not require any repudiation of allegiance. As in the other two jurisdictions examined in this article, Australia’s broad denationalisation laws make a clear symbolic statement about the nature of Australian citizenship, but are not tailored to serve any clear national security purpose. Part III below reflects on the implication of this combination of factors in all three countries. I II T H E M E S A N D O B S E RVAT I O N S While there are significant differences in the ways in which the UK, Canada and Australia considered in this article provided for denationalisation, the recent citizenship stripping expansions in the three countries are marked by a number of points of symmetry. All three countries made recent and dramatic expansions to the grounds for involuntary citizenship loss, resulting in very broad citizenship stripping regimes. The UK and Australian regimes, which remain in force, are amongst the broadest in the world. Moreover, the UK, Canada and Australia each justified their respective denationalisation expansions via a similar double-barrelled rationale. First, all three countries invoked a symbolic justification for the expanded laws. This justification cast citizenship as a ‘privilege’, the possession of which is conditional upon adherence to a particular code of behaviour. Citizens who do not adhere to this code — particularly in ways that threaten the state, or that indicate a lack of allegiance or loyalty on the citizen’s part — are regarded as unfit to retain citizenship. For instance, David Cameron described returning jihadists as ‘enemies of the state’.197 Tony Abbott was even more blunt. In addition to calling on all migrants to embrace ‘Team Australia’,198 he said: 197 Ben Farmer and Peter Dominiczak, ‘David Cameron: Returning Jihadists are “Enemies of the State”’, The Telegraph (London, 17 November 2014) <www.telegraph.co.uk/news/politics/ david-cameron/11237012/David-Cameron-Returning-jihadists-are-enemies-of-thestate.html>. 198 Jared Owens, ‘“Don’t Migrate unless You Want to Join Our Team”: Abbott Meets Islamic Community’, The Weekend Australian (Sydney, 18 August 2014) <www.theaustralian.com.au/national-affairs/dont-migrate-unless-you-want-to-join-ourteam-abbott-meets-islamic-community/news-story/d4046a301a9b65267801ae160331b404>. Advance Copy

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