CChapter 3: Comparative analysis of nationality laws that it will not take action in a particular case and the person will retain nationality. In practice, establishing a power of deprivation appears to be more common in this region that providing for automatic loss of nationality. Yet, it is not always easy to distinguish from the language of the law whether a particular article provides for loss or deprivation of nationality and therefore how it will operate in practice. In this chapter, the focus is not on whether a particular clause provides for loss or for deprivation, but on what the criteria are under which a person may be stripped of their nationality – since this offers a picture of how varied the circumstances are under which a person’s nationality may be threatened. As already mentioned, the grounds for both loss and deprivation of nationality tend to relate broadly to the (presumed) lapse or change of allegiance and/ or to behaviour that is considered unbefitting of a national. In the MENA region, the three most common grounds are where the person commits an act/ crime that threatens the security of the state, renders services to a foreign state or is discovered to have acquired the nationality through fraud. For instance, with respect to withdrawal of a nationality which has been fraudulently obtained, all MENA states with the exception of Algeria, Lebanon and Tunisia have legislated for this possibility. Thereafter, the withdrawal of nationality in response to a demonstration of 117