Patrícia Jerónimo services to the country (Article 13 of the Nationality Act). The first recipient of this honour was Portuguese President Jorge Sampaio, in 2006, for his role in the process that led to the 1999 referendum and to the independence of Timor-Leste (Jerónimo 2011b: 37). The decision by the Parliament is entirely free. However, it is necessary that the high and relevant services be already rendered by the time the Timorese citizenship is granted, given the use of the past tense in the text of the law. Article 13 may not be used to naturalise individuals as Timorese citizens with a view to their prospective services to Timor-Leste as members of the national football team, for instance. 3.2. Modes of loss of Timorese citizenship Loss of Timorese citizenship is governed by Articles 2 (1) and 14 of the Nationality Act and Articles 16 and 17 of the Nationality Regulation. Article 2 (1) of the Nationality Act sets the basic principle that no citizen may be arbitrarily deprived of his or her citizenship nor denied the right to change citizenship. Article 14 lists separately grounds for voluntary loss (renunciation), applicable to citizens by birth and to citizens with acquired citizenship, and grounds for involuntary loss (withdrawal), which are applicable only to citizens who acquired Timorese citizenship by naturalisation. The division in Article 14 of the Nationality Act is mirrored in the separate treatment of voluntary and involuntary loss in Articles 16 and 17 of the Nationality Regulation. There is a measure of consideration for individual will in the regulation of loss of citizenship, but just up to a point. Renunciation is only accepted by Timorese authorities if the Timorese citizen has another citizenship, a requirement designed to prevent statelessness. Furthermore, under Article 14 (2), Timorese citizenship acquired by naturalisation may be withdrawn by the Timorese authorities irrespective of the individual’s will and of whether he or she will become stateless as a consequence of the withdrawal. Citizenship acquired by naturalisation is therefore less secure than citizenship by birth and also than citizenship acquired by means other than naturalisation (i.e. filiation, adoption and marriage), which can only be lost by renunciation.131 A stronger protection for citizenship acquired on the basis of filiation, adoption or marriage may be explained by the National Parliament’s wish to safeguard the interests of the Timorese citizens who are family members with the persons concerned. It can be argued, however, that there is at least one ground for loss, among those listed in Article 14 (2) of the Nationality Act, which could also be applicable to cases of acquisition by means other than naturalisation, that of acquisition of Timorese citizenship by forging documents or using another type of fraud [Article 14 (2) (d)]. There is, after all, no apparent reason why Timorese authorities would not want to withdraw Timorese citizenship from persons who acquired it by forging a marriage certificate, for instance. In any case, under the current wording of the law, only individuals who became Timorese citizens by naturalisation may be deprived of their Timorese citizenship under Article 14 (2) of the Nationality Act. 131 This lesser status of citizenship acquired by naturalisation gives support to the claim that the National Parliament may have had only naturalisation in mind when it listed grounds for opposing the acquisition of Timorese citizenship in Article 16 of the Nationality Act. However, as pointed out earlier, if that was indeed the legislator’s intention, the phrasing of Article 16 should have been narrowed down to cover only cases of acquisition by naturalisation and not refer broadly to acquisition of Timorese citizenship. 34 RSCAS/GLOBALCIT-CR 2017/7 - © 2017 Author