2017] Citizenship Stripping Laws in the UK, Canada and Australia 21 any international human rights instrument regarding statelessness to which Canada is signatory’.99 However, the person affected bore the burden of proving, on the balance of probabilities, that they were ‘not a citizen of any country of which the Minister ha[d] reasonable grounds to believe the person [was] a citizen’.100 In most cases, the Strengthening Canadian Citizenship Act left the decision of whether or not a person’s citizenship was to be revoked with the Minister, rather than with a court. The judiciary only played a role in the process in the sense that revocation could not occur without a conviction (albeit not necessarily in a Canadian court) or by a judicial declaration that the citizen concerned had engaged in particular conduct. Unlike in the UK, the requirement of both an executive and a judicial decision served as a safeguard against abuses of power. Ministerial revocation decisions were also subject to judicial review, where leave of the court was obtained.101 However, as in the UK, the ability to access such review may have been limited where the citizen seeking review was outside national borders. 2 Justifications Justifications for the Canadian citizenship revocation provisions drew on a symbolic rationale much more heavily than on a security rationale. This is clear from the parliamentary discussion of the Strengthening Canadian Citizenship Act prior to its passage. The Act was presented as being directed towards ‘strengthen[ing] and protect[ing] the value of Canadian citizenship’.102 In his second reading speech, then-Citizenship and Immigration Minister Chris Alexander said that the legislation would help ‘maintain[] the integrity of citizenship … [by] deterring disloyalty’.103 At a press conference, Alexander said that ‘[c]itizenship is not a right; it is a privilege’.104 When introducing the legislation into the upper house, Senator Nicole Eaton said: 99 Strengthening Canadian Citizenship Act (n 95) s 8, amending Canadian Citizenship Act (n 8) s 10.4(1), the latter as repealed by Canadian Citizenship Amendment Act (n 95) s 5. 100 Strengthening Canadian Citizenship Act (n 95) s 8, amending Canadian Citizenship Act (n 8) s 10.4(2), the latter as repealed by Canadian Citizenship Amendment Act (n 95) s 5. 101 Canadian Citizenship Act (n 8) s 22.1(1). 102 Canada, Parliamentary Debates, House of Commons, 27 February 2014, 3310 (Chris Alexander). 103 Ibid 3311. 104 Susana Mas, ‘New Citizenship Rules Target Fraud, Foreign Terrorism’, CBC News (Online, 6 February 2014) <www.cbc.ca/news/politics/new-citizenship-rules-target-fraud-foreignterrorism-1.2525404>, archived at <https://perma.cc/YGJ7-5JHW>. Advance Copy