Meijers Committee standing committee of experts on international immigration, refugee and criminal law would be justified at least in situations where the dual national has strong ties to the respondent state and is, in that respect, in a comparable position to the majority of single nationals. Moreover, in Bah v. the United Kingdom, the ECtHR explained that a difference in treatment requires a stronger justification if it is based on a characteristic over which the person involved had no choice.77 This suggests that differential treatment of dual nationals would be subject to strict scrutiny, at least where the person concerned is unable to renounce his or her second nationality. The ECtHR’s acknowledgment that the denial or loss of a nationality can affect a person’s private and/or family life also means that it may not be proportionate to expect dual nationals to give up one of their nationalities (if at all possible) to avoid differential treatment. The ECtHR has accepted that the prohibition of discrimination in Articles 14 and 1 Twelfth Protocol ECHR also covers indirect discrimination.78 In the case of Biao v. Denmark, the ECtHR Grand Chamber found that the Danish legislation on family reunification indirectly discriminated against Danish citizens of foreign ethnic origin.79 This judgment confirms that (indirect) discrimination against citizens of migrant origin is considered by the Court as a form of ethnic discrimination, which can only be justified by very weighty reasons.80 In the case of K2 v. United Kingdom, concerning a British/Sudanese dual national who was deprived of his British citizenship, the applicant complained under Article 14 ECHR that he was treated differently from British citizens who did not hold a second nationality. This complaint was dismissed on procedural grounds.81 In the recent judgment in Ghoumid and others v. France, the ECtHR decided complaints concerning violations of Article 8 ECHR and Article 4 of Protocol 7 (ne bis in idem) brought by five former French citizens, whose nationality was withdrawn in 2015 following convictions for terrorist offences.82 Although all applicants had been treated differently as dual nationals (four also held Moroccan and one Turkish nationality) and as French citizens by naturalisation, their complaints did not concern Article 14 ECHR. Still, the reasoning of the ECtHR regarding the right to private life contains several elements that may also be relevant in relation to the prohibition of discrimination. The ECtHR found that the deprivation of citizenship did not have disproportionate consequences for the private life of the applicants. In reaching this conclusion, it took into account that the applicants were allowed to remain in France – at least for the time being - and that they would have appropriate remedies against an eventual deportation order. It also took into account that some of the applicants had recently acquired French nationality when they committed the offences, whereas others acquired French nationality while involved in a criminal conspiracy to commit terrorist violence. The Court confirmed its standing case law that terrorist violence constitutes in itself a serious threat to 77 Bah/United Kingdom, ECtHR 27 September 2011, app.no. 56328/07, para 47. D.H. and others/Czech Republic, ECtHR (GC) 13 November 2007, app.no. 57325/00, para 175. 79 Biao/Denmark, ECtHR (GC) 24 May 2016, app.no. 38590/10. 80 Biao/Denmark, para 114. 81 K2/United Kingdom, ECtHR (dec.) 7 February 2017, app.no. 42387/13, paras 68-70. 82 Ghoumid and others/France, ECtHR 25 June 2020, app.no. 52273/16. 78 15