14 Melbourne University Law Review [Vol 41(2):Adv appeal, which was not concluded until 2010, almost eight years after the original deprivation order was made.53 During this time, Egypt had taken steps to divest him of his dual Egyptian citizenship.54 As a result, the Special Immigration Appeals Commission found that the Secretary of State lacked the power to revoke Abu Hamza’s UK citizenship as doing so would render him stateless.55 It was not until the introduction of the ‘conducive to the public good’ threshold for revocation in 2006 that denationalisation saw a resurgence. Even this power was sparingly used in its early years: between 2006 and 2009, only four people were stripped of their citizenship.56 In 2010, however, the election of the Cameron government signified a major shift in the exercise of citizenship deprivation powers. Within its first year, the government stripped five people of their citizenship.57 Since 2010, there have been 33 denationalisations on security grounds.58 It has been reported that the vast majority of denationalised persons were stripped of their UK citizenship while abroad.59 In 2013, The Bureau of Investigative Journalism reported that this had occurred ‘[i]n all but two known cases’.60 This creates considerable practical barriers for those who wish to appeal the revocation decision. Once an appeal is lodged, however, the process can be protracted and can be complicated by intervening events. For example, in 2007 the UK moved to revoke the citizenship of Hilal alJedda, an asylum seeker from Iraq, who had been granted British citizenship in 2000.61 Under Iraqi law at the time, al-Jedda automatically lost his Iraqi citizenship upon attaining a foreign citizenship. On this basis, he appealed against the revocation order on the ground that depriving him of his UK citizenship would leave him stateless. In 2013 the matter reached the Supreme Court, before 53 Hamza (n 51) [2]. 54 See especially ibid [11]–[14]. 55 See ibid [22]. In 2004, amendments were introduced to allow deprivation to take effect as soon as a notice to deprive was issued. While this gave greater flexibility to the government with respect to the use of citizenship deprivation powers, it did not lead to new uses of these powers. 56 Melanie Gower, Deprivation of British Citizenship and Withdrawal of Passport Facilities (Standard Note No SN/HA/6820, House of Commons Library, 30 January 2015) 5. 57 Ibid. 58 Victoria Parsons, ‘Theresa May Deprived 33 Individuals of British Citizenship in 2015’, The Bureau of Investigative Journalism (London, 21 June 2016) <www.thebureauinvestigates.com/ 2016/06/21/citizenship-stripping-new-figures-reveal-theresa-may-deprived-33-individualsbritish-citizenship/>, archived at <https://perma.cc/L44Y-AQLD>. 59 Ibid. See also Ross and Galey (n 41). 60 Ross and Galey (n 41). 61 Al-Jedda v Secretary of State for the Home Department [2014] AC 253. Advance Copy