RAMADAN v. MALTA JUDGMENT 21 positive obligation to regularise the applicant’s status when revoking his Maltese citizenship. 2. The Court’s assessment 84. The Court observes that old cases concerning loss of citizenship, whether already acquired or born into, were consistently rejected by the Convention organs as incompatible ratione materiae with the provisions of the Convention, in the absence of such a right being guaranteed by the Convention (see, for example, X v. Austria, no. 5212/71, Commission decision of 5 October 1972). However, as noted above, in recent years the Court has held that although the right to citizenship is not as such guaranteed by the Convention or its Protocols, it cannot be ruled out that an arbitrary denial of citizenship might in certain circumstances raise an issue under Article 8 of the Convention because of the impact of such a denial on the private life of the individual (see references mentioned at paragraph 62 above). 85. Indeed, most of the cases concerning citizenship brought before the Court since the above-mentioned development in the case-law have concerned applicants claiming the right to acquire citizenship and the denial of recognition of such citizenship (see, for example, Karassev (dec.), cited above), as opposed to a loss of citizenship already acquired or born into. Nevertheless, the Court considers that the loss of citizenship already acquired or born into can have the same (and possibly a bigger) impact on a person’s private and family life. It follows that there is no reason to distinguish between the two situations and the same test should therefore apply. Thus, an arbitrary revocation of citizenship might in certain circumstances raise an issue under Article 8 of the Convention because of its impact on the private life of the individual. Therefore, in the present case it is necessary to examine whether the decisions of the Maltese authorities disclose such arbitrariness and have such consequences as might raise issues under Article 8 of the Convention. 86. The Court notes that the decision to deprive the applicant of his citizenship was in accordance with the law, namely Article 14 (previously Article 9) of the Maltese Citizenship Act (hereinafter “the Act”), which provides that “the Minister may deprive of his Maltese citizenship any citizen of Malta who is such by registration or naturalisation if he is satisfied that the registration or certificate of naturalisation was obtained by means of fraud, false representation or the concealment of any material fact”. The Court notes that Article 27(1) only states that the amendments to the Act would not affect the granting or retention of citizenship obtained prior to the enactment of such amendments, and thus it has no bearing on the application of Article 14 (former Article 9), which has not undergone any amendments. The Court further accepts the Government’s argument that the transitory provision in Article 27(2) of the Act (see paragraph 32