of including all the files of naturalization applications to put them under discussion or the request to the competent administration to make room for perusal by the parties and who will be included. This is difficult and almost physically impossible given the number of persons covered by the Decree.47 Moreover, the principle of stability of administrative work must be observed as quickly as possible. For the Council to complete all the preceding tasks, which is in fact not entirely financially impossible, it does take a long time to carry out and prepare the revocation review. On the one hand, this matter is inconsistent with the need to ensure the proper functioning of justice, provide stability and close this file as required by public interest. And on the other hand, this is incompatible with the urgent need to adjudicate this review in light of the effects resulting from the acquisition of nationality by the persons concerned and the rights associated with such acquisition, and the rights that accompany this acquisition, either directly or at a later date. The State Consultative Council considered that all the files of administrative naturalization applications are available at the competent administration that received them through its bodies and studied them. This would make it easier for these bodies to review them and reconsider the contested decree regarding nationality applications that were obtained unjustly or through fraud and forgery or deemed contrary to the Constitution or a grave violation of the law. However, it was not possible for this Council to play its role in monitoring a large number of administrative files of the current review within a reasonable time frame. The time it would take to bring in the beneficiaries associated with the disputed decree to defend their rights so that the legitimacy of this decree and the resulting rights of persons are not suspended for an extended period of time was found to be explicitly contrary to the principles of justice and stability of administrative work, as described above. The State Consultative Council decided to refer the case under current review to the competent Administration (Ministry of Interior) to re-examine its administrative files — i.e., the files of individuals who were naturalized by virtue of this Decree — review the contested Decree and annul the citizenship of all applicants found unworthy or fraudulent or those persons whose naturalization was flagrantly contrary to the Constitution or the law.48 It should be noted that the Council has not given any specific directive to the Ministry of Interior on the principles of due process to be followed or on the deadlines that it must adhere to in its review of the files. As a result of this Decision, the nationality of the naturalized persons under Decree 5247 of 1994 remained unsettled even after the court judgment was delivered, primarily since an administrative decision was issued to form a supreme committee to review the files of naturalized persons. Nonetheless, this committee was not permanent, and its work was suspended more than once; accordingly, the decision on this file has not been concluded to date, that is, seventeen years after the decision of the State Consultative Council. Consequently, since 2009, owing 12 to the fact that the Committee has not met, the Administration does not spontaneously review these files to conclude this review but exclusively provide answers whenever a naturalized person submits a personal or administrative claim. In 2011 a new committee was formed to re-examine the files of naturalized persons. Decrees 6690 and 6691 were issued on 28 October 2011, withdrawing the citizenship of approximately 200 naturalization files. They were divided into four basic categories: Maktoumi al Qaid, who were found to have non-Lebanese lineage, Palestinians registered in the records of the Palestinian Refugee Affairs Directorate in Lebanon, two persons who submitted incorrect personal statements and one person who was convicted of a criminal offence upon applying for naturalization. Obviously, a number of those appealed the denationalization Decree and resorted again to the State Consultative Council. As part of its review of appeals against the denationalization Decrees, the State Consultative Council declared that the Administration was entitled to withdraw nationality at any time in the event that it was found to have been granted contrary to the law or as a result of fraud and forgery since the law did not restrict it to any time limit contrary to the laws of other States. This argument justified that the judiciary had authorized the Administration to reverse naturalization decisions through a ruling that was issued in 2003 without restricting it to any time limit and by the legal principle that says fraud vitiates everything. Judicial advisor, Tarek Al-Majzoub, opposed the State Consultative Council’s decision, arguing that Lebanese law does not provide for fraud and forgery as one of the grounds for withdrawing acquired nationality. He also considered the fact that the law was silent on the time limit does not mean that it is open to the Administration to withdraw nationality at any time, in support of the principle of protection of rights and legal stability and the principle of protection of legitimate expectations — Principe de Confiance Legitime —, drawn from the French administrative jurisprudence. Judge-advisor Majzoub also regarded that the Administration has been aware of the fraud for several years without correcting it and that the conditions for fraud and forgery are not feasible in the case of a naturalized person who is found to have a record in the Directorate of Palestinian Refugee Affairs because the administration has not adequately scrutinized and vetted the files of naturalized persons.49 Moreover, in cases in which the State Consultative Council recognized the illegality of granting nationality in 1994, the Council dismissed the appeal against the denationalisation decree, which led to the withdrawal of nationality from the naturalized person and from anyone who acquired it by affiliation, whatever the method of this acquisition (marriage, birth, legal or administrative decisions ...). It should be noted here that the dissenting opinion of Counsellor Tarek Al-Majzoub considered that the denationalisation was a personal and individual punishment (as a result of fraud and forgery) and did not apply to family members of the naturalized. Its effects must not extend to persons who have not committed any act to justify punishment pursuant to the rule of individual punishment and to ensure legal stability.50