Factsheet – Deprivation of citizenship permit there, which could eventually also make him eligible for citizenship. Lastly, he had not sufficiently convinced the Court that he had relinquished his Egyptian nationality nor demonstrated that he would not be able to re-acquire it if he had done so. K2 v. the United Kingdom (application no. 42387/13) 7 February 2017 (decision on the admissibility) The applicant, a naturalised British citizen, left the United Kingdom in breach of his bail conditions. While he was out of the country, the Secretary of State for the Home Department ordered that the applicant be deprived of his citizenship on the ground that such measure was conducive to the public good. The applicant was also excluded from the United Kingdom on the ground that he was involved in terrorism-related activities and had links to a number of Islamic extremists. The applicant complained that the measures had breached his right to respect for his family and private life. He also argued that he could not properly make his case from abroad, because of fears that his communications could be intercepted by Sudanese counter-terrorism authorities that would then harm him. The Court declared the application inadmissible as being manifestly ill-founded. It firstly found that, although an arbitrary denial or revocation of citizenship might in some circumstances raise an issue under Article 8 of the Convention, because of its impact on the private life of an individual, no such issue arose in the present case. The Home Secretary at the time had acted swiftly and diligently, and in accordance with the law. The Court also noted that the applicant had had a statutory right to appeal and access to judicial review but the UK courts had rejected his claims after giving them a comprehensive and thorough examination. Lastly, though some of the case against the applicant had been kept secret for security reasons, his special advocate had had access to this information, and the nature of the case was broadly known to the applicant. Moreover, the Court held that Article 8 of the Convention could not be interpreted so as to impose an obligation on States to facilitate the return of every person deprived of citizenship in order for them to pursue an appeal against that decision. The UK court had rejected the applicant’s claims about not being able to argue his case from abroad, and the Court did not consider itself in a position to call into question that finding. Furthermore, the UK court had adopted a cautious approach to the case given the absence of instructions from the applicant, but still found conclusive evidence that he had been engaged in terrorism-related activities. In any case, it was the applicant who had originally chosen to leave the country. Finally, the Court noted that the applicant would not be left stateless by the loss of UK citizenship (as he had Sudanese citizenship), and the interference to his private and family life caused by the deprivation of citizenship was limited. Ghoumid and Others v. France 25 June 2020 This case concerned five individuals, formerly having dual nationality, who were convicted of participation in a criminal conspiracy to commit an act of terrorism. After serving their sentences they were released in 2009 and 2010, then stripped of their French nationality in October 2015. The applicants argued in particular that the revocation of their nationality had breached their right to respect for their private life. They added that their loss of nationality was a “disguised punishment” constituting a sanction for conduct in respect of which they had already been convicted and sentenced in 2007 by the Paris Criminal Court. The Court held that there had been no violation of Article 8 of the Convention, finding that the decision to deprive the applicants of French nationality had not had disproportionate consequences for their private life. It reiterated in particular the point, already made in a number of judgments, that terrorist violence constituted in itself a serious threat to human rights. As the applicants already had another nationality, the decision to deprive them of French nationality had not had the effect of making them stateless. In addition, loss of French nationality did not automatically entail deportation from France, but if such a measure were to be decided against them they would have the appropriate remedies by which to assert their rights. The Court further observed that deprivation of nationality under Article 25 of the French Civil Code was not a criminal 2