stateless.137 In light of this judgment new legislative provisions for the revocation of certificates of naturalisation will
have to be adopted.138 The Department of Justice when contacted as part of this study, indicated that the Minister
for Justice is considering the implications of the Supreme Court judgment.139
As outlined above, only some aspects of the 1956 Act as amended concerned with renunciation, loss and revocation
of citizenship are broadly in line with the relevant requirements of the 1961 Convention. There remains scope for
the introduction of greater safeguards, both legal and in practice, and UNHCR would advocate, in particular, for the
removal of the 1961 Convention reservation on loss of citizenship and for the introduction of a provision preventing,
as a general principle, the revocation of citizenship where this would render a person statelessness.
36
137
Supreme Court, Damache v Minister for Justice and Equality, Ireland and the Attorney General, 10 February 2021, available at:
https://bit.ly/3Hv9tMk p.86.
138
Irish Legal News, Legislation required before revocation of citizenship can take place again, 11 February 2021, available at:
https://bit.ly/3FTvS4N
139
Correspondence with the Citizenship Unit, ISD, Department of Justice, January 2022; ESRI, Research Series Number 116, Pathways to
Citizenship through Naturalisation in Ireland, December 2020, available at: https://www.esri.ie/system/files/publications/RS116_2.pdf
Mapping Statelessness in Ireland