international law.2 The Claimant expressly invokes the prohibition against the arbitrary deprivation of nationality set out in Article 15(2) of the Universal Declaration of Human Rights (“UDHR”).3 The Secretary of State, for her part, contests both the extent of that prohibition and its relevance to SIAC’s preliminary determination.4 3. On that basis, the UN Special Rapporteur understands there to be a dispute as to the scope and relevance of Article 15(2) of the UDHR and the prohibition contained in that provision. She seeks to assist the Court in its examination of this important issue by addressing the genesis, status and content of the UK’s relevant public international law obligations. B. The Mandate’s interest in these proceedings 4. Professor Ní Aoláin was appointed as UN Special Rapporteur in 2017. The mandate of the UN Special Rapporteur is to gather, request, receive and exchange information on alleged violations of human rights and fundamental freedoms while countering terrorism, and to report regularly to the Human Rights Council and General Assembly about, among other things, identified good policies and practices, as well as existing and emerging challenges and present recommendations on ways and means to overcome them. The mandate was created by the Commission on Human Rights (the predecessor of the Human Rights Council) in Resolution 2005/80 and has been regularly renewed by State consensus since then. The role of the mandate is to give concrete recommendations to States and other stakeholders on the promotion and protection of human rights and fundamental freedoms while countering terrorism. The mandate also identifies, exchanges and promotes best practices on measures to counter terrorism that respect human rights and fundamental freedoms. In this context, the mandate holder has submitted amicus curiae briefs to national and regional courts on issues of human rights protection in the context of countering terrorism. 5. The UN Special Rapporteur has a direct interest, and specific expertise, in the issues raised in these proceedings. The mandate has consistently addressed the legal obligations that arise in respect of women and children associated with the Islamic State and other non-state groups operative in the northern Syrian Arab Republic and Iraq.5 A range of human rights issues concerning women and children have been raised in interactive dialogues with the General Assembly and the Human Rights Council (in 2017, 2018 and 2019). The Special Rapporteur is a member of the UN Global Counter-Terrorism Coordination Compact supported by the UN Office of Counter-Terrorism and was a member of the Working Group that produced “Guidance to States on Human Rights-Compliant Responses to the Threat Posed by Foreign Fighters” (2018). The UN Special Rapporteur has also taken a joint position with the SRSG-SVC, SRSG-CAC and SRSG-VAC on the rights of children and the 2 Statement of Facts and Grounds (“SFG”), paras. 7(1), 41, 48. 3 SFG, para. 48. 4 Summary Grounds of Defence of the Secretary of State (“SGD”), para. 24.7 (including footnote 4). 5These include in her country assessments concerning (A/HRC/40/52/Add.5) and Kazakhstan (A/HRC/43/46/Add.1). 2 France (A/HRC/40/52/Add.4), Belgium

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