K2 v. THE UNITED KINGDOM DECISION 9 appeal, finding, inter alia, that the applicant had failed to discharge the burden on him to establish that he had been unable to have a fair procedure. B. Domestic law and practice 1. Deprivation of citizenship 36. Pursuant to section 40(2) of the British Nationality Act 1981 (“the 1981 Act”), the Secretary of State has a power to make an order depriving a person of his British citizenship on the ground that deprivation is “conducive to the public good”. 37. The Secretary of State must first take a decision to deprive the person of citizenship, and notice of this decision must be served on him. There is a right of appeal against this decision, either to the First Tier Tribunal (Immigration and Asylum Chamber) (by virtue of section 40A(1) of the 1981 Act), or, where the Secretary of State has certified that the decision was made wholly or partly on reliance on information which should not be made public in the interests of national security, foreign relations or the public interest, to SIAC (by virtue of section 40A(2) of the 1981 Act and section 2B of the Special Immigration Appeals Commission Act 1997). 2. SIAC 38. SIAC has a special procedure which enables it to consider not only material which can be made public (“open material”) but also other material which cannot (“closed material”). Neither the appellant nor his legal advisor can see the closed material. Accordingly, one or more security-cleared, independent counsel, referred to as “special advocates”, is appointed by the Solicitor General to act on behalf of the appellant. 39. Rule 4 (3) of Special Immigration Appeals Commission (Procedure) Rules 2003 (“the 2003 Rules”) requires SIAC to satisfy itself that the material available to it enables it properly to determine proceedings. 40. Section 7 of the Special Immigration Appeals Commission Act 1997 confers a right of appeal to the Court of Appeal against a final determination of an appeal made by SIAC in England and Wales “on any question of law material to that determination”. 41. A fuller explanation of the SIAC procedure is set out in I.R. and G.T. v. the United Kingdom (dec.), nos. 14876/12 and 63339/12, §§ 28-35, 28 January 2014. 3. The Crown prerogative 42. The Crown (or “royal”) prerogative refers to those powers left over from when the monarch was directly involved in government. Prerogative powers are today exercised by government ministers or by the monarch