Meijers Committee standing committee of experts on international immigration, refugee and criminal law abstract level citizenship deprivation is also seen as cutting the links between the political community and those who are considered to lack the loyalty presumed by citizenship through their involvement in terrorist activities.117 There is no doubt that the prevention and combating of terrorist violence is a legitimate aim, as has been recognized by the ECtHR since its 1961 judgment in the Lawless case.118 However, the objective of combating terrorism as such does not require the making of a distinction between single and dual nationals. Instead, the reason why most citizenship deprivation laws only target persons with dual or multiple nationality is because states may not withdraw the nationality of their citizens if those citizens would thereby become stateless. This follows from Article 7(3) ECN and the 1961 UN Convention on the Reduction of Statelessness.119 For most of the states concerned, this has been the reason to provide that citizenship deprivation can only be applied to dual nationals. The prevention of statelessness obviously constitutes a legitimate aim as well. What the focus on preventing statelessness tends to obscure, however, is that states have a choice of whether or not to use citizenship deprivation as a means to combat terrorism and that they must exercise this choice in conformity with the prohibition of discrimination.120 Although states tend to present the differential treatment of dual nationals as a necessary consequence of the fact that single nationals cannot be deprived of their nationality, such differential treatment could be avoided if states would refrain from citizenship deprivation altogether and instead would adopt anti-terrorism measures that can be equally applied to all citizens. Examples of such measures, which are already applied in case of single nationals, would be criminal prosecution or administrative measures such as area bans or the confiscation of passports.121 It follows that the difference in treatment between single and dual nationals is not justified because other, non-discriminatory measures are available that serve both the aim of combating terrorism and of preventing statelessness. In this situation it must be concluded that the ‘very weighty reasons’ test is not met. In addition, several other arguments cast doubts on the effectiveness and proportionality of citizenship deprivation regimes that apply only to dual nationals: - first, the risk that single and dual nationals are confronted with different sanctions following the same behaviour is not merely theoretical. Empirical evidence shows that perpetrators of 117 As argued by the French government in Ghoumid and others/France, para 39. Lawless v. Ireland (no. 3), 1 July 1961, paras 28–30, Series A no. 3; ECtHR 17 January 2012, app.no. 8139/09, Othman (Abu Qatada)/ the United Kingdom, para 83 and the case-law cited in Ghoumid and others v. France, para 50. 119 UNTS vol. 989, p. 175. See also the Report of the UN Secretary-General on Human rights and arbitrary deprivation of nationality of 19 December 2013, UN Doc. A/HRC/25/28 (2013), para 6. 120 As stressed also by the UNHCR, Guidelines on Statelessness No. 5, ‘Loss and Deprivation of Nationality under Articles 5-9 of the 1961 Convention on the Reduction of Statelessness’, UN Doc. HCR/GS/20/05 of May 2020, paras 109-111. 121 See also C. Paulussen and M. Scheinin, ‘Deprivation of nationality as a counter-terrorism measure. A human rights and security perspective’, in: Institute on Statelessness and Inclusion, The World’s Stateless. Deprivation of Nationality, March 2020, available at www.institutesi.org, p. 224. 118 24