Citizenship Deprivation under the European Convention-System person of their nationality, the person is typically expelled from Belgium — though this is a separate measure. 95 Because citizenship deprivation potentially leads to expulsion from the territory, putting ECHR art 8 under pressure, 96 it would be wise to provide protection for this fundamental right in the measures leading up to the expulsion. After all, it would not be coherent policy to denationalise an individual who has strong ties with the national community — a scenario which could happen in Belgium because of the rigid pre-set legislative categories — to then see the expulsion decision blocked exactly because of the individual’s strong community ties. Therefore, if the Belgian Government truly wants to implement a coherent counterterrorism policy, including a denationalisation policy, it would be wise to review the interpretation of the criterion ‘strong community ties’ and install a more realistic interpretation of community ties in the Belgian measure of deprivation, so as not to create a discrepancy between the interpretation of such ties under the measure of deprivation on the one hand, and expulsion as a consequence on the other. Because currently, this is the case. When looking at the ECtHR’s case law on art 8 in expulsion cases, we see that it takes into account: [T]he specific ties that these immigrants have forged with their host country, where they have spent the better part of their lives. They have received their education there, have established most of their social ties there and have developed their own identity there. Born or arrived in the host country because of the emigration of their parents, most often they have their main family ties there. Indeed, the only link some of these immigrants kept with their country of origin is that of nationality. 97 Or, in the case of Mehemi v France: The Court notes that the applicant was born in France, received all his schooling there and lived there until the age of 33, before the permanent exclusion order was enforced. His parents and his four brothers and sisters live there, as do his wife and his three minor children, who were born in France and have French nationality … Moreover, it has not been established that the applicant had links with Algeria other than his nationality. 98 95 96 97 98 The case of Malika El Aroud and the case of Fouad Belkacem. For Malika El Aroud, see: Cour d’Appel Bruxelles [Brussels Court of Appeal] Judgment App No 2014/AR/267, 30 November 2017 (‘El Aroud’); Judgment App No 217 248 (Immigration Appeal Court, 21 February 2019). Copies of these decisions are on hand with the author. For Fouad Belkacem, see: Belkacem Case (n 89). Concerning his expulsion, there has not yet been a judgment since he is currently still detained in Belgium. The State-Secretary for Immigration has nonetheless multiple times stressed that he would do everything in his power to arrange expulsion to Morocco. ECHR (n 7) art 8. The original text reads: S'ajoutent toutefois à ces différents critères, les liens particuliers que ces immigrés ont tissés avec leur pays d'accueil où ils ont passé l'essentiel de leur existence. Ils y ont reçu leur éducation, y ont noué la plupart de leurs attaches sociales et y ont donc développé leur identité propre. Nés ou arrivés dans le pays d'accueil du fait de l'émigration de leurs parents, ils y ont le plus souvent leurs principales attaches familiales. Certains de ces immigrés n'ont même conservé avec leurs pays natal que le seul lien de la nationalité. Benhebba v France (European Court of Human Rights, Third Section, Application No 53441/99, 10 July 2003) 33 (‘Benhebba’) [tr author]. Mehemi v France (European Court of Human Rights, Chamber, Application No 85/1996/704/896, 26 September 1997) 11 [36]. 275