Bücken and de Groot 47 A. Ireland and Jamaica38 The declarations made by Ireland and Jamaica generally comply with the limited scope that is outlined in Article 8(3). Minor criticism could be expressed regarding the overly vague phrasing of the declarations, making it difficult to draw conclusive observations with regard to their legality and compliance. Ireland’s declaration fails to specify which of the grounds listed in the Convention it intends to retain. Given the fact that Section 19(1)(b) of the Irish Nationality and Citizenship Act 1956, refers to lack of loyalty, the declaration seems to refer to retention on the ground set out in Article 8(3)(a) of the Convention. Consequently, this presumes that the ‘overt act’ has to be to ‘render services to, or received or continued to receive emoluments from another State’ or ‘conduct seriously prejudicial to the vital interests’ of Ireland. A different interpretation and application of Section 19(1)(b) with statelessness as a consequence would be inconsistent with the Convention. Section 19(1)(b) has not been amended since the declaration was made.39 Similarly, Jamaica’s declaration does not specify which national provisions Jamaica wants to retain. It appears that these would be Article 11b of the Jamaican Constitution and Article 8(2) (a)-(c) of the Nationality Act. These grounds for deprivation apply only to naturalized citizens and include assistance to the enemy in a war in which Jamaica was engaged, disloyalty (in act or speech) towards Her Majesty, or being sentenced within five years after acquisition of Jamaican nationality to imprisonment of at least 12 months. With the exception of the ground of assistance to the enemy, the declaration could hence be interpreted as broader than permitted by Article 8(3) of the Convention. Disloyalty may only be a ground for deprivation with statelessness as consequence under the circumstances listed under Article 8(3)(a)(i) or (ii) of the 1961 Convention. The same applies for sentencing to imprisonment of one year or more. It was noted above that Article 8(3)(a)(ii) may not be interpreted as including criminal offences of a general nature, no matter how serious they are, and that deprivation of nationality may not act to limit the freedom of expression or assembly, or any other rights, beyond what is permitted by international human rights law. B. Austria, Brazil, New Zealand The declarations made by Australia, Brazil and New Zealand under Article 8(3) are generally compliant with the conditions set by the Convention. A common deficiency of the three declarations, however, is the rather broad definition of what constitutes conducts seriously prejudicial to the vital interests of the state, as enshrined in Article 8(3). The Austrian declaration concerns Article 8(3)(a)(i) and (ii) and, among others, includes the ground of conduct ‘seriously prejudicial to the interests or to the prestige of the Republic of Austria’. In order to comply with the grounds set out in the Convention, the conduct would need to be against the vital interests of Austria. The Brazilian declaration made in accordance with Article 8(3)(a)(ii) retained ‘the right to deprive a person of his nationality when he conducts himself in a manner seriously prejudicial 38. The declarations submitted under Article 8(3) can be found at United Nations Treaty Collection, ‘Chapter V Refugees and Stateless Persons’, UNTS (2017). 39. Compare, the Irish Nationality and Citizenship Acts 1986, 1994, 2001 and 2004, amending the Irish Nationality and Citizenship Act 1956.