2017] Citizenship Stripping Laws in the UK, Canada and Australia 27 What this bill would do, in my view, is reduce the value of citizenship by allowing someone to be involved in terrorism, which completely goes against Canadian values … This potentially toxic combination would reduce the value of our citizenship.129 Bill C-6 was passed on 13 June 2017,130 and received Royal Assent on 19 June. As a result of its passage, s 20 of the Canadian Citizenship Act now provides that Zakaria Amara, the sole person to lose his citizenship pursuant to the Strengthening Canadian Citizenship Act, is deemed never to have lost his citizenship. Like the UK law, the Canadian law was underpinned by a clear symbolic rationale — one that was reversed with the passage of Bill C-6, but a weak security rationale. The implications of this are explored in Part III. C Australia 1 Laws Enacted In December 2015, the Australian federal Parliament passed the Australian Citizenship Amendment (Allegiance to Australia) Act 2015 (Cth) (‘Allegiance to Australia Act’). This introduced new avenues for citizenship loss into the Australian Citizenship Act 2007 (Cth), and made Australia the most recent common law country to enact legislation enabling citizenship stripping on national security grounds. Prior to these changes, the grounds for citizenship loss in Australia were limited. A citizen by naturalisation could have their citizenship revoked if they committed certain offences in relation to their application for citizenship,131 or where their citizenship was obtained by fraud.132 Additionally, those who obtained their citizenship by application and ‘conferral’ could have it revoked if they were convicted of a ‘serious offence’ in the window between lodging an application for citizenship and having citizenship conferred, provided this would not render them stateless.133 In all these cases, revocation took place via the exercise of ministerial discretion, which required the Minister to be satisfied that it would be ‘contrary to the public interest for the person to remain an 129 Canada, Parliamentary Debates, House of Commons, 9 March 2016, 1653. 130 Canada, Parliamentary Debates, House of Commons, 13 June 2017, 12600–1. 131 Australian Citizenship Act 2007 (Cth) s 34(1)(b)(i). 132 Ibid s 34(2)(b)(iv). 133 Ibid ss 34(2)(b)(ii), (3)(b). Advance Copy