Caroline Sawyer, Helena Wray was present in earlier deprivation of citizenship laws, where it acted as a restraint: deprivation on other grounds could only go ahead if it was also ‘conducive to the public good’. It is also used as a ground for deportation, where it has been expansively interpreted, and its use in this way in deprivation cases reflects the increasing tendency to treat naturalisation as an issue of immigration control and national security rather than of citizenship policy. Numbers of deprivation orders began to increase from 2010. For many years, no such orders were made. In 2009, two people were deprived of their citizenship and, in 2010, five (Fransman 2011: 609). A Freedom of Information request in July 2011 revealed that thirteen orders had been made under the ‘conducive to public good’ provision.38 By 2014, that number had increased to at least 25, and that may be an underestimate. At least five of those deprived under this law were born in the UK. The number of deprivations on fraud grounds also appears to be increasing: there was one case in 2012 and 12 in 2013 (Ross 2014). A recently adopted tactic is to issue the order while the individual is outside the UK; 15 of the 17 ‘conducive’ deprivation cases examined by the Bureau of Investigative Journalism were made in this way (Ross 2014). Notice of deprivation is sent to the home address in the UK and the individual may only discover their predicament when attempting to return to the UK by which time appeal rights may have expired. Enabling its (former) citizens to be exiled in this way means that the British state avoids the difficulties it has faced in expelling non-nationals, both legal obstacles, such as human rights-based objections, and practical ones, such as identifying a state willing to take the person, and which would apply to an even greater extent to those who had only just stopped being British citizens. The Court of Appeal has upheld the government’s refusal of admission for the purposes of attending an appeal, finding that deprivation of citizenship was an exercise of the Crown's prerogative powers and, in the absence of a statutory suspensive right of appeal, the common law did not require a person to be present in person at his own appeal.39 This makes it much more difficult for rights of appeal and for human and other legal rights (for example, in EU law) to be exercised. There is the difficulty involved in finding and instructing lawyers from remote regions with poor communications but it may also be a question of physical security; at least one person deprived of their citizenship was killed by a drone strike after using skype (not in connection with an appeal) and some of those affected by deprivation orders have decided against giving evidence in their appeal, citing reasons of personal safety (Ross 2014). UK consular assistance is not available to these individuals, who are treated as non-citizens from the moment of deprivation. Two individuals (including the instance mentioned above) have been killed in drone strikes and another has been rendered to the US, raising suspicions of collaboration between US and UK security services. One of those killed was misleadingly reported to be a ‘very senior Egyptian’ commander in Al Qaeda even though he was born in the UK and had never asserted his Egyptian citizenship (Ross 2014). The current provisions are, in practice, indistinguishable from a right of arbitrary deprivation, although they are in accordance with the law. The sole substantive bar is that the person must not be left stateless when an order is made on ‘conducive to public good’ grounds (there is no prohibition on leaving a person stateless if their British nationality is found to have been obtained by fraud). Given the breadth of discretion granted to the Secretary of State and the lack of clear (or any) rights in EU and human rights law, that an order will leave someone stateless is the only ground of appeal likely to succeed. However, establishing statelessness is often difficult and requires the British courts to decide on complex issues of foreign 38 http://www.ico.gov.uk/~/media/documents/decisionnotices/2012/fs_50411501.ashx 39 G1 v SSHD [2012] EWCA Civ 867. 16 RSCAS/EUDO-CIT-CR 2014/1 - © 2014 Authors