2017] Citizenship Stripping Laws in the UK, Canada and Australia 25 The lack of any clear security benefit in Canada’s denationalisation laws was underlined by the sole instance of revocation under the now-repealed legislation. In late September 2015, the Harper government revoked the citizenship of Zakaria Amara, the ringleader of the unsuccessful Toronto 18 bomb plot. Amara is currently serving a sentence of life imprisonment, so poses no foreseeable threat to Canadian security.121 The Harper government also issued notices to nine other citizens, signalling an intention to deprive them of their citizenship. Most were, like Amara, members of the Toronto 18 group.122 However, no further deprivation orders were ultimately issued due to a change in government and a policy shift with respect to citizenship. In October 2015, a new government was elected in Canada, under the leadership of Justin Trudeau. In the lead-up to the election, Trudeau voiced his opposition to the Strengthening Canadian Citizenship Act, arguing that ‘as soon as you make citizenship for some Canadians conditional on good behaviour, you devalue citizenship for everyone’.123 Like the justifications for the Act, Trudeau’s opposition was anchored around a symbolic point about the value of citizenship: one that reiterated the security and equality elements of common law citizenship that were minimised by proponents of the Act. Shortly after its election, the Trudeau government took steps to undo key elements of the Strengthening Canadian Citizenship Act. In February 2016, Bill C-6 was introduced into Parliament. The Bill purported to repeal all the new national security grounds for citizenship revocation,124 as well as to restore the citizenship of any person denationalised under those grounds.125 Consequently, the nine further citizens flagged for denationalisation by the previous Harper government were not subject to deprivation orders. As was the case with the Strengthening Canadian Citizenship Act, parliamentary debate over the Bill focused overwhelmingly on the value of citizenship. 121 See, eg, ‘Canada Revokes Citizenship of Toronto 18 Plotter’ (n 3). 122 Stewart Bell, ‘Canada Working to Revoke the Citizenship of Nine More Convicted Terrorists’, National Post (Toronto, 30 September 2015) <http://news.nationalpost.com/news/canada/ government-working-to-revoke-citizenship-of-nine-more-canadians-convicted-of-terroristoffences>. However, there are some exceptions, including a citizen serving a sentence for a conviction in the US courts. 123 Ryan Maloney, ‘Bill C-24: Trudeau Says Terrorists Shouldn’t Be Stripped of Citizenship in Leaked Audio’, HuffPost Canada (Online, 28 September 2015) <www.huffingtonpost.ca/2015/ 09/28/bill-c-24-trudeau-audio-conservatives_n_8206798.html>, archived at <https://perma.cc/3VZ9-9U9J>. 124 Bill C-6 (n 8) cls 3–5. 125 Ibid cl 20. Fraud-based revocation, which predates the Harper government’s changes, was retained. Advance Copy