32 Kristy A. Belton and Jamie Chai Yun Liew Another prominent but more problematic example is that of Shamima Begum, a twenty-year-old woman who at age fifteen left the United Kingdom to join the Islamic state.37 In February 2019, the United Kingdom revoked her citizenship. The Special Immigration Appeals Commission, a tribunal that hears national security cases, reasoned that Begum could be stripped of her citizenship because she would not be left stateless despite the fact that Bangladesh had stated that it did not recognize her as a citizen.38 The Commission held that Begum was “a citizen of Bangladesh by descent.”39 Begum’s lawyer has appealed the decision. This practice reinforces the normative move to legitimize citizenship deprivation where national security concerns exist, but, troublingly, it also shows how the legal definition of statelessness may be eroding. In particular, the legal finding that Begum was a national of another state was not based on any evidence, but on speculation that she could be granted citizenship by another state (in this case, Bangladesh) by an examination of its laws. Criminal Behavior Aside from national security or terrorism concerns, citizenship withdrawal may be premised upon individuals’ criminal behavior. Take for example the case of Canada v. Budlakoti.40 Budlakoti was born and raised in Canada. Due to his criminal convictions, Budlakoti was found inadmissible under Canada’s Immigration and Refugee Protection Act. Budlakoti challenged this finding by asserting he was a Canadian citizen. The Immigration Division of the Immigration and Refugee Board (IRB), however, held that he was not a citizen as per the Citizenship Act since he fell into the exception that children born of parents under the employment of a foreign government do not enjoy birthright citizenship. The Immigration Division determined that Budlakoti’s parents were working for officials of the Indian Consulate in Canada at the time he was born, therefore making him ineligible for citizenship by birth. Budlakoti unsuccessfully challenged this decision. In asserting he would be stateless as a result of the Immigration Division’s findings, the Federal Court of Appeal held that “[h]e is not yet stateless” since Budlakoti “can take steps to apply for citizenship in India and in Canada.”41 This finding is particularly troubling given that the Court acknowledged that the Indian Consulate had refused to recognize Budlakoti as a citizen and that the Canadian government was involved in litigation to make him removable from Canada. “Shamima Begum Loses First Stage of Appeal over Citizenship,” BBC, February 7, 2019. Ibid. 39 Ibid. 40 Budlakoti v. Canada (Citizenship and Immigration), 2015 FCA 139. 41 Ibid. 23. 37 38 https://doi.org/10.1017/9781108914994 Published online by Cambridge University Press