40 RAMADAN v. MALTA JUDGMENT – SEPARATE OPINION reasoned52. The lack of reasoning was further compounded by the secrecy of the decision-making procedure. The committee’s final recommendation to the Minister was not made available to the applicant, and the many requests by the applicant’s lawyers for a copy of the records of these proceedings remained unsatisfied53. What is worse, Article 14(3) only safeguards the position of the stateless person in the case of subarticle (2)(c), which is manifestly insufficient. One obvious conclusion is clear from the above: Maltese law provides for very poor procedural safeguards in respect of such ministerial orders in comparison with international standards for the protection of stateless persons54. In addition to calling for an urgent law reform, these serious shortcomings of the revocation procedure call into question the fairness and the proportionality of the measure taken in the present case55. 20. Not without hesitation, the majority concede that the applicant is currently stateless and that there is no guarantee that the Egyptian authorities would accept him, nor is it likely that he could be removed to another country56. This legal situation has already entailed many undisputed, negative, practical consequences for the applicant and his family, such as, among others, the loss of his right to unrestricted residence 52. The automatic character of the ministerial decision, without any weighing-up of the relevant factors, can be seen very clearly in paragraphs 23 and 24 of the judgment. 53. See paragraph 22 of the judgment. 54. Compare and contrast with the UNHCR “Guidelines on Statelessness No. 2: Procedures for Determining whether an Individual is a Stateless Person”, cited above, and the excellent European Network on Statelessness Guide of Good Practices “Statelessness, determination and the protection status of stateless persons”, 2013. 55. I cannot therefore follow the majority in their conclusion at the end of paragraph 87. It must be recalled that, according to Article 17 of the ILC’s Draft Articles on the Nationality of Natural Persons (cited above), decisions relating to the acquisition, retention or renunciation of nationality should be issued in writing and be open to effective administrative or judicial review. The ILC also stated in its commentary on the Draft Articles that the review process could be carried out by a competent jurisdiction of an administrative or judicial nature in conformity with the internal law of each State. The ILC clarified that the term “effective” was intended to stress the fact that an opportunity had to be provided to permit meaningful review of relevant substantive issues, which required giving reasons for any negative decisions concerning nationality. The European Convention on Nationality also contains important procedural standards on deprivation of nationality, such as the requirement that decisions contain reasons in writing (Article 11) and that decisions be open to an administrative or judicial review in conformity with internal law (Article 12). The right to a review against deprivation of nationality is also guaranteed by Article 8 (4) of the Convention on the Reduction of Statelessness and Article 8 (2) of the Convention on the Rights of the Child. 56. See paragraph 56 of the judgment. There is clear inconsistency between this paragraph and paragraph 92.