transition “towards prioritising […] actively returning their citizens, and then domestically prosecuting or reintegrating them based on their newly developed criminal history”.73 As a result, these Central Asian governments have focused on taking responsibility for the repatriation, rehabilitation and de-radicalisation of their citizens, who have come to also be portrayed as 'victims' in need of support rather than uniquely as a security threat. Another avenue through which to further to better understand the use of deprivation powers in practice is to look more closely at who has been targeted and the circumstances of the case. Thanks to the media frenzy that surrounded her case, many are familiar with the story of Shamima Begum and what happened to her after she was stripped of her British nationality.74 But what happened to other denationalised citizens? Here are four examples of what followed after deprivation of nationality. When the wider global trend towards increased instrumentalisation of citizenship stripping as a national security measure is distilled down to the level of an individual case, the practicali- 30 ties of what is involved in and what follows after deprivation of nationality are laid bare. According to security experts that are critical of the use of nationality deprivation in the fight against terrorism, states that have embraced this measure are essentially “avoiding the tough, but necessary, responsibility of dealing with their own citizens”.88 As the case of Prakash demonstrates, this may result in “moving the problem around like a hot potato”,89 passing the responsibility of dealing with such individuals to another state – in his case Turkey, a country that has felt the brunt of other governments’ recourse to nationality deprivation of ‘foreign fighters’ who joined ISIS. The cases of Fatima H., Hisham R., and Kamel Daoudi show that even this outcome is not guaranteed, as the governments that served the deprivation decisions remain encumbered with the problem of what to do with these former-citizens, now in limbo on their territory. The killing by drone strike of Mohamed Sakr and Bilal al-Berjawi demonstrates what the withdrawal of their British citizenship – and with it, the protection of the state – can precipitate. In none of these cases is nationality deprivation an easy administrative 'fix' to the complex challenge of combating international terrorism. THE NETHERLANDS Fatima H. and Hisham R. FRANCE Kamel Daoudi Deported to the Netherlands after being stripped of Dutch nationality Stranded in limbo in France after being stripped of French nationality In 2019, Turkey deported Dutch-Moroccan Fatima H. and her two children back to the Netherlands, after her Dutch citizenship was revoked under Article 14(4) DNA. Turkey gave two reasons for deporting Fatima H. back to the Netherlands: Turkey does not have sufficient extradition agreements with Morocco, and it was the Netherlands’ own choice to revoke her nationality.75 After returning to the Netherlands, she was taken into custody as an undesirable foreigner and prosecuted for participating in terrorist activities. In 2021, a court in Rotterdam found Fatima guilty of actively participating in a terrorist organisation and sentenced her to four years of imprisonment.76 After serving her sentence, the Dutch government will seek to deport her to Morocco. In 2021, Hicham R. was similarly deported back to the Netherlands by Turkey, despite already being deprived of his Dutch nationality. He was arrested on arrival, and placed into custody, with the government seeking to prosecute him and then deport him to Morocco.77 Daoudi was a French-Algerian dual national. He was arrested in the UK in September 2001 on suspicion of having plotted a terrorist attack against the US Embassy in Paris. He was convicted of “criminal association in relation to a terrorist undertaking” and was stripped of his French nationality in May 2002. After serving a six-year prison sentence, he was released in April 2008 and immediately placed in a detention center pending deportation.78 In 2009, however, the European Court of Human Rights held that deporting him to Algeria would expose him to prohibited "inhuman and degrading treatment”,79 and therefore ordered France to suspend the deportation order.80 Daoudi was instead made the subject of compulsory and lifelong house arrest.81 In 2018, the French authorities declined to renew Daoudi’s provisional residence permit leaving him in an undocumented legal position.82 AUSTRALIA Neil Prakash UNITED KINGDOM Mohamed Sakr and Bilal al-Berjawi Stuck in immigration detention in Turkey after being stripped of Australian nationality Killed by drone strike after being stripped of British nationality After Melbourne-born Neil Prakash appeared in recruitment material for Islamic State and was linked to several Australiabased attack plans, the Australian government stripped him of his citizenship in December 2018.83 While the Australian government claims Prakash is a Fijian national, the authorities of Fiji do not, in fact, recognise him as a citizen.84 When Prakash completed a prison sentence for terrorismrelated charges in Turkey in February 2022, he was remanded into immigration detention while Turkey waits to see if any country will take him.85 In 2010, the UK government stripped Mohamed Sakr and Bilal al-Berjawi of their British citizenship while they were in Somalia, on the grounds that they were allegedly involved with al Shabaab.86 They were on the list of the British counterterrorism agencies for some years. In 2012, both of them were killed in a US drone strikes.87 Berjawi was survived by his wife and son, while Sakr was survived by his parents who blamed the British government for his death.

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