2016] The Prevention and Reduction of Statelessness in Australia 487 children born in Nauru may be able to acquire Nauruan nationality. However, this is by no means clear and remains an issue of ongoing concern. B Challenges to the Prevention of Statelessness: Withdrawal and Loss of Nationality Under Australian law there are several ways in which a person may cease to be a citizen.174 These include renunciation of citizenship;175 revocation on the grounds of offences or fraud;176 failure to comply with special residency requirements for those whose citizenship was not automatic;177 serving in the armed forces of a country at war with Australia or a declared terrorist organisation;178 or through other conduct that ‘demonstrates that the person has repudiated their allegiance to Australia’.179 It is noteworthy that many of these categories apply to all Australian citizens, regardless of whether citizenship was acquired automatically by birth or through naturalisation. The last of these was introduced in 2015 by the Australian Citizenship Amendment (Allegiance to Australia) Act 2015 (Cth) (‘Allegiance to Australia Act’) and is considered separately in Part V(C) below. While the Citizenship Act safeguards against statelessness in some of these instances,180 it does not provide complete protection. Pursuant to s 34(1) of the Citizenship Act, the Minister may revoke Australian citizenship acquired by descent (or adoption) if a person has been convicted of an offence in relation to his or her application to become an Australian citizen, or obtained Australian citizenship as a result of third-party fraud. In both cases, the Minister must be ‘satisfied that it would be contrary his birth he would not, but for the provisions of this Article, have the nationality of any country.’ 174 Citizenship Act pt 2 div 3. For a detailed analysis see Sangeetha Pillai, ‘The Rights and Responsibilities of Australian Citizenship: A Legislative Analysis’ (2014) 37 Melbourne University Law Review 736, 753--8. 175 Citizenship Act ss 33, 33AA. 176 Ibid s 34. 177 Ibid s 34A. 178 Ibid s 35. 179 Ibid s 35A(1)(d), as inserted by Australian Citizenship Amendment (Allegiance to Australia) Act 2015 (Cth) sch 1 item 5. 180 The Citizenship Act provides some protection in relation to: renunciation by application (s 33(7)); offences or fraud (s 34(3)(b)); special residency requirements (s 34A(2)); a responsible parent’s cessation of citizenship (s 36(3)).