2016] The Prevention and Reduction of Statelessness in Australia 495 tionality laws in an individual’s case in practice and any review/appeal decisions that may have had an impact on the individual’s status.236 Such an assessment is particularly vital in the context of ‘foreign fighters’ where it is possible that, even if a person is a dual national, the other country of nationality may also invoke similar denationalisation provisions on the same grounds.237 A vivid illustration of the potential problems with deemed renunciation provisions and a failure to adequately assess whether a person in fact holds the nationality of another state is provided by the Pham v Secretary of State for the Home Department litigation in the UK.238 In that case, the UK and Vietnam effectively engaged in a race to denationalize the applicant.239 Mr Pham was born in Vietnam but lived in the UK from the age of six, during which time he acquired British nationality. Neither he nor his family ever held Vietnamese passports.240 He converted to Islam at the age of 21 and, following suspected (but denied) terrorist training in Yemen, the UK Secretary of State served notice on Mr Pham of her decision to deprive him of his UK citizenship because to do so would be ‘conducive to the public good’.241 She considered that her order would not make him stateless because he would retain his Vietnamese citizenship.242 Yet, although Mr Pham remained a Vietnamese citizen ‘on the basis of the legislative texts alone’,243 the Vietnamese govern- 236 Ibid 12 [23] (citations omitted). The Handbook continues at 13 [24]: Applying this approach of examining an individual’s position in practice may lead to a different conclusion than one derived from a purely formalistic analysis of the application of nationality laws of a country to an individual’s case. A State may not in practice follow the letter of the law, even going so far as to ignore its substance. The reference to ‘law’ in the definition of statelessness in Article 1(1) therefore covers situations where the written law is substantially modified when it comes to its implementation in practice. 237 This point was made in several submissions to the Parliamentary Joint Committee on Intelligence and Security’s inquiry into the Bill: see, eg, Law Council of Australia, Submission No 26 to Parliamentary Joint Committee on Intelligence and Security, Inquiry into the Australian Citizenship Amendment (Allegiance to Australia) Bill 2015, 17 July 2015, 26 [110]. For the final report, see Parliamentary Joint Committee on Intelligence and Security, above n 188. 238 [2015] 1 WLR 1591. 239 Ibid 1595--6 [3] (Lord Carnwath JSC for Lords Neuberger PSC, Wilson JSC, Carnwath JSC and Baroness Hale DPSC). 240 Ibid 1595 [2]. 241 Ibid 1596 [3]. 242 Ibid 1595--6 [3]. 243 Ibid 1598 [14].