GHOUMID AND OTHERS v. FRANCE JUDGMENT nationality should be issued to those same children, in your decision Association juristes pour l’enfance et autres (CE, 12 December 2014, no. 365779, A). In my view it is both necessary and appropriate to recognise the operation of Article 8 in relation to the measure depriving a person of nationality. It is simply a matter of recognising the reality that a person’s nationality is a constituent element of his or her identity, not only legally, but also at a personal level. This will lead you to carry out a more in-depth review, which could, for example, take into account the circumstances in which the nationality was originally acquired by the person who has been deprived of it. However, my proposition is that you should recognise, exactly as the Court does in its case-law, that Article 8 can only be invoked with regard to the private life of the persons concerned, i.e. their personal identity, and not to any interference with their family life, because as the Court ... itself has pointed out, the consequences of deprivation of nationality for one’s right of abode or place of abode are not automatic. It is noteworthy that in the opinion given by the Conseil d’État on 11 December 2015 on the constitutional bill for the ‘protection of the nation’, family life was also mentioned, but it is my opinion that on this matter you should remain as closely as possible to the Court’s findings ... This twofold development that I am proposing to you, namely full review and applicability of Article 8, is probably more of jurisprudential than of practical interest in the current state of the legislation and administrative practice: not only are the conditions laid down by law for deprivation of nationality exceptional and confined, in practice one can see that such measures are rarely adopted. Thus, since the grounds for deprivation of nationality have to be criminal convictions for very serious offences, only in cases where the overall sanction imposed is light would it be possible to consider that such a measure may not be justified by the weight in the balance. But this development is nevertheless proposed with the firm conviction that it is not insignificant, in such matters, be it for the administrative authorities today, or for those, whether a legislator or the European court, who may be called upon to consider whether Articles 25 and 25-1 of the Civil Code provide a balanced response, for you to clearly set out the framework of your review. ... [As regards the criticism relating to] proportionality, [which can be expressed] both: in the field of EU law in line with the Rottmann case-law, which you have already engaged with, as has been said; under Article 8 of the Convention ...; and in the context of the full review in which you are now invited to engage. In this connection, it must first be stressed that the acts for which the individuals concerned were convicted are serious ... With regard to the consequences of the measure for those concerned, it is important to emphasise that the loss of nationality does not in itself have a definite impact on the right of abode of the persons concerned. It is not certain that the applicants, or at least not all of them, can be expelled or deported to their country of origin, especially if they are able to show that they would be exposed to a risk of treatment in breach of Article 3 of the Convention. The Court has been willing to enter into such an examination and has recognised the existence of a violation in certain cases (see the judgment of 3 December 2009, no. 19576/08, Daoudi v. France). In your office, you do yourselves ensure compliance with the Convention, as interpreted by the Court, of course, and regardless of the criticisms that may be made of it and which may affect 4