K2 v. THE UNITED KINGDOM DECISION 13 applicant of his citizenship. While it is not known exactly when the United Kingdom authorities became aware of his activities, the open evidence before SIAC indicated that he left the United Kingdom in October 2009 and engaged in terrorist-related activities in Somalia from that date until April or May 2010, when he went to Sudan (see paragraph 22 above). The Secretary of State notified him of her intention to make an order depriving him of his citizenship by letter dated 11 June 2010 and on 14 June 2010 she signed the order (see paragraph 6 above). iii. Procedural safeguards 54. Therefore, the principal issue for the Court to address in the present case is whether the applicant was afforded the procedural safeguards required by Article 8 of the Convention. 55. In this regard, the Court notes that the applicant had a statutory right of appeal to SIAC against the decision to deprive him of citizenship (see paragraph 37 above). Although he contends that there was very limited disclosure of the nature of the national security case against him, the Court notes that in advance of the substantive hearing he was provided with a National Security Statement setting out clearly – in open evidence – details of the Secretary of State’s national security case against him (see paragraph 22 above). As a consequence, SIAC was in no doubt that “the nature of the case was broadly known to the applicant” (see paragraph 30 above). Furthermore, he was represented in this appeal by counsel and Special Advocates were appointed in order to address the evidence contained in the closed material. Indeed, the Court recalls that in I.R. and G.T. (cited above, §§ 63-65), a case which concerned the revocation of the applicants’ leave to remain and their exclusion from the United Kingdom, the Court was satisfied that there were sufficient guarantees in the SIAC proceedings as required by Article 8 (see also Abdul Wahab Khan v. the United Kingdom (dec.), no. 11987/11, § 33, 28 January 2014). 56. Nevertheless, the applicant contends that on the facts of the present case his exclusion from the United Kingdom prevented him from participating effectively in his appeal against the decision to deprive him of citizenship, because the very act of communicating with his lawyers from Sudan would have put him at risk of great harm from the Sudanese authorities. However, for the reasons set out below the Court does not consider that the applicant’s exclusion from the United Kingdom rendered nugatory his procedural safeguards. 57. First of all, the Court does not accept that an out-of-country appeal necessarily renders a decision to revoke citizenship “arbitrary” within the meaning of Article 8 of the Convention. It would not exclude the possibility that an Article 8 issue might arise where there exists clear and objective evidence that the person was unable to instruct lawyers or give evidence while outside the jurisdiction; however, Article 8 cannot be interpreted so as