Part II. European Law on Nationality and Statelessness of the revocation and it took into account the situation of the applicant involved. As such, it demonstrated the importance of looking at the consequences and situation of the person affected by loss of citizenship, which is important in nationality matters and can help to address statelessness. More hope can perhaps be seen when turning to the dissenting opinion of Judge Pinto de Albuquerque, who recalls the right to nationality in international human rights law, criticizes the procedures and measures of the Maltese government and emphasizes that “creation and perpetuation of situations of statelessness should be avoided at any cost in a civilised Europe”. He concludes: “It is high time for the Court to recognise explicitly that State citizenship belongs to the core of someone’s identity, which is protected by Article 8 of the Convention.”730 Even though this represents only the opinion of one of the judges, it might be the direction in which the ECHR and its interpretations by the ECtHR could develop and/or could be encouraged to develop using strategic litigation.731 In 2017, the Court decided on a matter regarding deprivation of nationality in the case of K2 v. the United Kingdom.732 Born in Sudan, K2 became a naturalized citizen of the UK in 2000. After being arrested for an offence, he left the UK and travelled to Somalia. Here, he took part in terrorism-related activities. In 2010, he was therefore deprived of his British nationality and excluded from the country. K2 complained under Article 8 that the decisions to deprive him of his UK citizenship and bar him from re-entering the country breached his right to respect for his family and private life and amounted to an attack on his reputation. He further complained that there were inadequate procedural safeguards to ensure effective respect for his Article 8 rights as there was very limited disclosure of the national security case against him and he was unable to participate effectively in the legal proceedings.733 In its assessment of the case, the Court recalled that arbitrary denial or revocation of citizenship could in certain circumstances raise an issue under Article 8 of the ECHR, because of its impact on the private life of a person. The ECtHR therefore has to examine whether the revocation was arbitrary and what the consequences thereof were for the applicant.734 In doing so, the Court clearly sets out (again) the important standards to be taken into account when considering deprivation of nationality: 730 731 732 733 734 138 Ibid, Dissenting Opinion of Judge Pinto de Albuquerque. Cf efforts to litigate strategically as regards statelessness, and more specific related issues such as statelessness determination and childhood statelessness, eg Maxim Ferschtman, ‘Litigating for the stateless – a bumpy, but steady road upwards (ENS Blog, 13 July 2013) <https://www.statelessness.eu/ updates/blog/litigating-stateless-bumpy-steady-road-upwards> accessed 4 July 2021; ENS, ‘Strategic Litigation: An Obligation for Statelessness Determination under the European Convention on Human Rights?’ (2014) ENS Discusssion Paper 09/14 <https://www.statelessness.eu/updates/publication/ obligation-statelessness-determination-under-european-convention-human-rights> accessed 17 October 2021; ISI, World’s Stateless: Children (Wolf Legal Publishers 2017) ch 12. K2 v the United Kingdom App No 42387/13 (ECHR, 9 March 2017) ECLI:CE:ECHR:2017:0207 DEC004238713. Ibid, para 46. Ibid, para 49. Intersentia