77. A Study of Statelessness by the UN132 and the later absence of any language in the 1961 Convention permitting sanction or punishment to be used as a purpose for nationality deprivation indicate that this cannot constitute a legitimate purpose for deprivation of nationality of a citizen. 78. Furthermore, an established principle of human rights law is that restrictions on human rights (in this case, the right to a nationality) are only allowed in certain specified circumstances and/or need to meet certain criteria. Any grounds allowing for deprivation of nationality, as included in the 1961 Convention, must, additionally, be interpreted in light of subsequent developments of international law, which “have considerably narrowed the circumstances in which these exceptions may be applied .133 Indeed, “ n either the ECN nor the 1961 Convention allow States to deprive a person of nationality in response to ordinary crime. 134 The Explanatory Report to the ECN emphasizes that this prohibition applies however serious the offence may be.135 79. Deprivation of nationality of a suspected terrorist (or for any suspected criminal offence), without a criminal conviction and the accompanying procedural safeguards of criminal law, violates “basic elements of the rule of law . The Parliamentary Assembly of the Council of Europe has expressed concern about some of its member states that allow for deprivation of liberty by way of administrative decisions particularly because such decisions lack procedural safeguards and are mostly made without the knowledge and/or the presence of the person concerned.136 Deprivation of nationality as a punishment for terrorist acts (or any criminal acts), may also breach the legal principle to ensure that no one is prosecuted twice for the same acts (ne bis in idem), where it is imposed in addition to a criminal sentence.137 80. Furthermore, the IACtHR has held that nationality is an “inherent attribute of every person and should never be withdrawn as a punishment or reprisal.138 66. Arbitrary deprivation of nationality falls within the ambit of Article 8 of the ECHR. Interference with Article 8 rights are exceptionally permitted in a narrow range of circumstances that are strictly applied. Any interference which is too broad would be unjustified and interference which has an ulterior motive to that provided for by Article 8 may violate Article 18 of the ECHR. Article 18 prohibits States from using restrictions permitted under the ECHR rights and freedoms for any purpose other than those for which they have been prescribed. Therefore, if a person is deprived of their nationality for a purpose not permitted by Article 8 it could violate Article 18. Similarly, such an interference may violate Article 5 of the ECHR in conjunction with Article 18. The ECtHR is current considering applications which engage Article 18, in conjunction with Article 8, due to 132 UN Economic and Social Council, A Study of Statelessness August UN Docs E ;E Add. , p. : “Deprivation of nationality should not be applied as a punishment . 133 UNHCR, ’Tunis Conclusions‘ , para . 134 UN Human Rights Council, ’Human rights and arbitrary deprivation of nationality: Report of the Secretary-General’, A HRC , para 20. 135 Explanatory Report to the ECN, para 67. 136 CoE Committee on Legal Affairs and Human Rights AS Jur , ‘Withdrawing nationality as a measure to combat terrorism: a human rightscompatible approach? Report’, AS Jur , available at: http://website-pace.net/documents/19838/4246196/20181213-PRESSCITIZENSHIP-EN.pdf, para 5. 137 UN Human Rights Council, ‘Human rights and arbitrary deprivation of nationality: Report of the Secretary-General’, A HRC para 20; CoE Committee on Legal Affairs and Human Rights AS Jur , ‘Withdrawing nationality as a measure to combat terrorism: a human rightscompatible approach? Report’, AS Jur , para 6. 138 Inter-American Commission on Human Rights, ‘Third Report on the Situation of Human Rights in Chile’ OEA Ser.L/V/II.40, Chapter 9, para. 10. 48