Citizenship Deprivation under the European Convention-System simulated. 26 According to the authorities, the only reason he married his first wife was in order to stay in Malta and acquire citizenship there. 27 In its consideration of the alleged breach of the applicant’s right to private and family life, the ECtHR took into account the arbitrariness of the decision and its consequences. 28 With regard to the arbitrariness test, the Court noted that Maltese legislation was sufficiently clear and thus in accordance with the law. 29 In general, states are quite precise in determining who, and under which circumstances, a citizen can be deprived of their nationality. 30 Moreover, the Court was satisfied that Maltese law provided the possibility to challenge the deprivation decision before a court. 31 However, as noted in the dissenting opinion of Judge Paulo Pinto De Albuquerque, even though an appeal procedure was in place, the Minister’s original deprivation lacked procedural safeguards. 32 First of all, the Minister failed to take into account the necessity of the decision for the public good, which is required by art 14(3) of the Maltese Citizenship Act. 33 The Minister mechanically and automatically applied the relevant provision in Maltese law, without considering the public good necessity, since, paradoxically, Maltese law does not require the Minister’s decision to be motivated by any particular reason. 34 Further, the committee’s final recommendations to the Minister were not made available to the applicant, despite multiple requests in that respect. 35 The Court’s satisfaction with regard to the procedural safeguards of deprivation decisions might have to be nuanced, given these elements. Concerning the consequences of the decision, the Court took into account two elements: the consequence of statelessness, which was a direct result of the deprivation decision, and the potential expulsion of the applicant. 36 Even though the Court itself was not entirely consistent in its judgement, 37 it seems that the 26 27 28 29 30 31 32 33 34 35 36 37 ibid. ibid 1099 [H8]. ibid 1118 [85];. ibid 1118–19 [86]. The United Kingdom is a bit of an exception here, considering that a UK citizen can be deprived of their nationality if this is ‘conducive to the public good’, a rather vague and undefined term. However, this falls outside of the topic of contribution: Immigration Act 2014 (UK) s 66. Ramadan (n 11) 1119 [87]. ibid 1134 (OI-25). ibid 1131–2 (OI-19), citing Maltese Citizenship Act (Malta) (1965) Ch 188 of the Laws of Malta (‘Maltese Citizenship Act’). ibid; see Maltese Citizenship Act (n 33) arts 14(3), 19. Article 19 provides that ‘the Minister shall not be required to assign any reason for the grant or refusal of any application under this Act’. Ramadan (n 11) 1131–2 (OI-19). ibid 1119–20 [89]–[92]. See ibid 1113 [56], 1120 [92]: on the one hand, the Court seems to acknowledge the applicant’s statelessness, stating that ‘it appears that the applicant is currently stateless’: at [56]. On the other hand, the Court argues that: although, according to a letter by the Consul of the Embassy of the Arab Republic of Egypt, the applicant’s request to renounce his Egyptian nationality was approved and his Egyptian passport withdrawn, he has not provided the Court with any official document (such as a presidential decree, which appears to be issued in such circumstances) confirming such renunciation. Nor has the applicant provided any information as to the possibilities of reacquiring Egyptian nationality … at [92] (citations omitted). 267