500 Melbourne University Law Review [Vol 40:456 difficulty, however, again lies in a person subject to such an assessment being able to effectively exercise a right to judicial review, given they will likely be outside the country and potentially unaware of the revocation (if, for example, the Minister’s ‘reasonable attempts’ to provide the relevant notice fail). This reliance on a closed, opaque, internal administrative procedure rather than a judicial determination is at odds with the procedural safeguards adopted in many comparable jurisdictions. For example, in Belgium,268 Israel269 and the United States,270 denationalisation connected to disloyalty and terrorism can only result from a decision of a court. In Canada, the Minister has discretion solely in relation to deprivation following a conviction, but must seek a declaration from the Federal Court of Canada where revocation is based on foreign service.271 The UK appears to countenance very broad ministerial discretion, but as Pillai observes, such broad powers ‘have attracted substantial criticism.’272 As she notes, ‘while a person may lodge an appeal against a citizenship deprivation order, this does not prevent them from being deported from the UK. This can make it very difficult to initiate appeal proceedings.’273 These concerns are a fortiori in Australia where a person may have their citizenship revoked while they are overseas. In sum, we have serious concerns that the recent amendments to Australia’s Citizenship Act fail to provide adequate safeguards to ensure compliance with Australia’s obligations under art 8 of the 1961 Convention: namely, to ensure that Australia ‘shall not deprive a person of its nationality if such deprivation would render him stateless.’274 While it is beyond the scope of this article to assess in-depth the numerous additional international law obligations invoked by a state’s decision to denationalise its citizens, it is important to note that there is a range of other human rights considerations that may be implicated in such practices. The many relevant human rights treaties to which Australia is a party have been examined comprehensively by the Australian Parliamentary Joint Committee Agenda Item 2. Nonetheless, the findings of the Board may be very influential in the exercise of ministerial discretion. 268 Wautelet, above n 190, [2.3]. 269 Lavi, above n 189, 422. 270 Parliamentary Joint Committee on Intelligence and Security, above n 188, 20 [2.48]--[2.49]. 271 Ibid 19 [2.41]. 272 Pillai, ‘Proposals to Strip Citizenship Take Australia a Step Further Than Most’, above n 192, 23. 273 Ibid. 274 1961 Convention art 8(1).