29. Article 14 bis paragraph 2 has the potential to be applied in an overbroad manner, consistent with the UAE’s recent practice of citizenship stripping discussed above.45 It is notable that the acts punishable with denationalisation under Article 14 bis resemble those previously used in the provision describing conditions under which only naturalised citizens could be stripped of nationality. 46 The deprivation of citizenship under Article 14 bis of the Nationality Law is an automatic “accessory penalty” incurred upon conviction of certain crimes deemed to threaten the state’s “external security” that may not be contested, though the underlying criminal conviction may be appealed to the Federal Supreme Court.47 30. Under the 2017 Amendment, naturalised citizens can have their citizenship withdrawn in four additional circumstances, resulting into unequal treatment between birth right citizens and naturalised citizens: 1. “If he has been repeatedly convicted for offences involving moral turpitude or dishonesty. 2. Should there be any forgery, fraud or adulteration in substantial information used as proof for acquisition of nationality. 3. If he has exercised citizenship rights at any other country. 4. Should he reside outside the State without excuse for a continuous period exceeding two years.”48 31. Such denaturalisation carries with it the denaturalisation of family members who derived Emirati nationality through their denaturalised parent or spouse. 32. Finally, citizenship may be withdrawn from any citizen if “he is convicted, by a final judgment, for an offense prejudicing the internal security of the State and which is punishable in accordance with the Federal Penal Code, or other offenses which are considered to be a threat to the internal security of the State as per the laws in force in the State.”49 33. At least one individual whose citizenship had been stripped appealed the withdrawal to the Federal Supreme Court.50 The Court dismissed the appeal on procedural grounds without addressing the merits of the allegation that Articles 15 and 16 of the 1972 Nationality Law (as they were prior to the 2017 amendment) are unconstitutional and that the Government’s act of withdrawing the appellant’s family book and passport were unlawful. The justification used by the Court in reaching its decision was the absence of a Federal Decree stripping the appellant’s nationality, which would give the appellant standing to question the constitutionality of the provisions. 34. The amendments introduced in 2017, notably the insertion of Article 14 bis, run counter 45 Amnesty International, “”There is no freedom here”: Silencing dissent in the United Arab Emirates (UAE)”, (17 November 2014), https://www.amnesty.org/en/documents/mde25/0018/2014/en/. 46 Before 2017, Article 16 stated, in relevant part that “[n]ationality shall be withdrawn from a person who has acquired the nationality by naturalisation … If he commits or attempts to commit an action which is deemed dangerous for the security or safety of the country.” 47 Federal Law No. (17) of 1972, Concerning Nationality and Passports with its amendments, Federal Decree-Law No. (16) Of 2017 concerning the amendment of some provisions of Federal Law No. (17) of 1972 regarding Nationality and Passports, Art. 14 bis (3), (4). 48 Ibid. Art. 16. 49 Ibid. Art. 15 bis. 50 UAE Federal Supreme Court, Case No 3 of 2013 decided on November 6, 2013, available at: https://www.moj.gov.ae/ar/about-moj/union-supreme-court/e-services/latest-court-interpretations.aspx#page=1. 8