Part II. European Law on Nationality and Statelessness and effective link of these persons with the state concerned”.719 With these concrete pointers, the Recommendation thus explicates how statelessness should be avoided as much as possible. Loss and deprivation of nationality have been considered by the Court in its case law as well. Clearly relevant is the case of Ramadan v. Malta720, because it involves statelessness directly. The applicant in this case is Ramadan, who is stateless. He was an Egyptian citizen, but was allowed to renounce his Egyptian citizenship after he acquired Maltese nationality subsequent to his marriage to a Maltese citizen. After marital problems arose – of a severe nature: the applicant was convicted for assaulting his pregnant wife – a Maltese judge annulled the marriage and held that there had been simulation of marriage.721 Ramadan did not notify the authorities of the annulment. In 2003, he married a Russian citizen and it was only in that context that the authorities became aware of the annulment of the applicant’s fi rst marriage. After a notification and some proceedings, he was deprived of his Maltese nationality in 2007 with immediate effect because it had been obtained fraudulently and he became stateless.722 In the meantime, two children had been born from his second marriage. They are both Maltese nationals. After unsuccessfully instituting constitutional redress procedures, Ramadan complained to the ECtHR of a violation of Article 8 of the Convention. “The applicant complained that the decision to divest him of his Maltese citizenship had not been made in accordance with the law. It had interfered with his right to private and family life and exposed him to the risk of being separated from his family. The decision had not been accompanied by the relevant procedural safeguards as required under Article 8 of the Convention and the State had failed to fulfi l its positive obligation to protect his rights under that provision. Lastly, the applicant complained that the decision had left him stateless. He thus had to live in a state of uncertainty, where he could not even leave the country for fear of not being let back in.”723 From a perspective of the prevention of statelessness, in particular preventing deprivation of nationality, this case presents an opportunity for the Court to make a statement. The ECtHR, however, declares parts of the complaint inadmissible. According to the Court, the applicant could not claim to be a victim of a violation of his rights under Article 8 in relation to his potential removal from Malta, because a removal order had not been issued (yet) and because this order could still be challenged if it were issued. Interestingly, the ECtHR makes a specific observation regarding the statelessness of the applicant: 719 720 721 722 723 136 Ibid, para II (C)(c). Ramadan v Malta App No 76136/12 (ECHR, 21 June 2016) ECLI:CE:ECHR:2016:0621JUD007613612. Ibid, para 14. Ibid, paras 23–24. Ibid, para 49. Intersentia