502 Melbourne University Law Review [Vol 40:456 The scope of ‘his own country’ is broader than the concept ‘country of his nationality’. It is not limited to nationality in a formal sense, that is, nationality acquired at birth or by conferral; it embraces, at the very least, an individual who, because of his or her special ties to or claims in relation to a given country, cannot be considered to be a mere alien. This would be the case, for example, of nationals of a country who have there been stripped of their nationality in violation of international law, and of individuals whose country of nationality has been incorporated in or transferred to another national entity, whose nationality is being denied them … A State party must not, by stripping a person of nationality or by expelling an individual to a third country, arbitrarily prevent this person from returning to his or her own country.283 The right to return to one’s own country applies regardless of whether a person has another nationality.284 Indeed, in practice, the second nationality may be ineffective285 or even unknown to a person,286 or even at risk itself as a result of the application of citizenship-stripping laws in that jurisdiction.287 It may be that a person has never visited, let alone lived in, the other country. For instance, in Nystrom v Australia, the UN Human Rights Committee found that notwithstanding Nystrom’s possession of Swedish nationality, the Australian government breached art 12(4) by deporting him to Sweden ‘in the light of the strong ties connecting him to Australia, the presence of his family in Australia, the language he speaks, the duration of his stay in the country and the lack of any other ties than nationality with Sweden.’288 There are also consequences in international law beyond the human rights context, particularly with regard to relationships with other states. Since ‘the consequences of the act of rendering an individual stateless are very likely to 283 Human Rights Committee, General Comment No 27: Article 12 (Freedom of Movement), 67th sess, UN Doc CCPR/C/21/Rev.1/Add.9 (2 November 1999) [20]--[21] (emphasis added). See also Human Rights Committee, Views: Communication No 1557/2007, 102nd sess, UN Doc CCPR/C/102/D/1557/2007 (1 September 2011) (‘Nystrom v Australia’). 284 See, eg, Nystrom v Australia, UN Doc CCPR/C/102/D/1557/2007, 18 [7.4]. 285 As observed by the Refugee Council of Australia in its evidence to the Parliamentary Joint Committee on Intelligence and Security, there is a risk of persons becoming ‘de facto stateless if they do not enjoy effective citizenship in their other countries of nationality’: Evidence to Parliamentary Joint Committee on Intelligence and Security, Parliament of Australia, Canberra, 5 August 2015, 20 (Lucy Morgan, Refugee Council of Australia). 286 Parliamentary Joint Committee on Intelligence and Security, above n 188, 38 [4.13]--[4.16]. 287 Audrey Macklin, ‘Kick-Off Contribution’ in Audrey Macklin and Rainer Bauböck (eds), ‘The Return of Banishment: Do the New Denationalisation Policies Weaken Citizenship?’ (Working Paper No RSCAS 2015/14, European University Institute, February 2015) 1, 5--6. 288 Nystrom v Australia, UN Doc CCPR/C/102/D/1557/2007, 18 [7.5].