2019 Statelessness & Citizenship Review 1(2) In Biao v Denmark, the ECtHR rephrased its holding in Abdulaziz, Cabales and Balkandali v United Kingdom (‘Abdulaziz’), stating that: [T]here are in general persuasive social reasons for giving special treatment to those who have strong ties with a country, whether stemming from birth within it or from being a national or long-term resident. 99 This demonstrates that the ECtHR does not attach much weight to the method of acquisition, but rather to the ties with the community one possesses. There is a discrepancy between the interpretation of community ties by the ECtHR in its art 8 case law on expulsion, and the Belgian authorities in the targeting of their deprivation powers. Although it concerns different acts, an expulsion and deprivation of citizenship, the former is almost always followed by expulsion, which in turn is taken into account as a consequence of citizenship deprivation in the ECtHR’s evaluation under art 8. It therefore does not make sense to interpret the same concept differently under measures so closely connected. On the other hand, the ECtHR’s current interpretation of art 8 in the context of citizenship deprivation seems problematic, because the Court only evaluates the impact on the individual’s community ties when considering the consequences of citizenship deprivation, as the case of Said Abdul Salam Mubarak demonstrated. 100 Instead, the Court should evaluate this in the step prior; the classification of persons eligible for citizenship deprivation. People with strong roots in the national community should not be subjected to citizenship deprivation in the first place. Firstly, because this enables situations like the Belgian example, where a ‘wrong’ group of people is subjected to the measure. Since ‘community ties’ are not considered at this level, a subsequent expulsion decision can easily be blocked because of the (previously improperly or not considered) individual’s art 8 ties. Having the ECtHR consider community ties in the measure potentially leading up to expulsion, might avoid such situations at the national level. The Court’s art 8 case law in expulsion cases demonstrates their realistic interpretation of community ties. 101 Provided that this interpretation extends to citizenship deprivation’s targeted group, such case law could provide redress for flawed situations at the national level. But more fundamentally, such a consideration would also indicate that the ECtHR acknowledges citizenship deprivation in all its consequences. Expulsion is only one such consequence. Citizenship status grants access to many other rights and benefits, such as the right to politically participate or to enjoy certain economic and social benefits. Losing citizenship status entails losing these rights and benefits. By disregarding these consequences, the ECtHR has not only reduced art 8 to a mere expulsion protection — something that this right was not intended for — but it has also disregarded the ‘private life’ in the ‘right to private and family life’. Expulsion will indeed put an individual’s family life in jeopardy (their private life as well), but it is wrong to assume one’s art 8 rights are not affected when expulsion is off the table: private life — as democratic agency, employment availability and public service — is disrupted and, ultimately, preserved only for the citizen. 99 Biao v Denmark (2017) 64 EHRR 1, 60 [OH-29] (‘Biao’); Abdulaziz v United Kingdom (1985) 7 EHRR 471 505–6 [88] (‘Abdulaziz’). 100 Abdulaziz (n 99) 495 [60]. 101 Benhebba (n 97) 11. 276