Émilien Fargues safeguards that the case studies overall indicate leaves people at risk of statelessness and gross human rights violations, as the genocide perpetrated against the Rohingyas in Myanmar sadly illustrates, and as fears grow in India with the construction of mass detention centres. When citizenship revocation results from an individual procedural act based on a set of conditions defined by law (fraud, terrorism, etc.), as is most often the case in contemporary Western countries, the administration is sometimes forced to act within certain time limits and under the control of a court. This is notably the case in France, where the Minister of the Interior cannot make citizenship revocation orders past statutory time limits and without the approval of the Council of State. However, situations can vary significantly from one state to another. In the UK, for example, the British Home Office is not constrained by any time limits and does not need to obtain the approval of a court before issuing citizenship revocation orders.17 Keeping these variations in mind, we should be careful not to draw hasty conclusions that would present Western countries as paradigmatic examples of high levels of protection against arbitrary practices of citizenship revocation, and non-Western countries as prime instances of absence of control over such arbitrary practices. This is not to deny that, in Western states, judicial institutions protect a number of fundamental rights that limit the executive’s power to revoke citizenship – most notably preventing statelessness – and that this is less obvious in the countries in this symposium. Going back to France, the Council of State systematically rejects the executive’s decisions that would result in statelessness, even in cases of fraud-based citizenship revocation (where statelessness as a consequence of revocation is allowed by international law). This stands in stark contrast with the very loose control that the Indian Supreme Court has exercised over the implementation of the NRC in Assam, approving the arbitrary and discriminatory practices of the administration. This being said, one should not treat these national differences as evidence of a more general Western vs. non-Western division, for two fundamental reasons. First, there are examples of Western countries having crossed previously established red lines protecting fundamental rights in order to expand the executive’s power to revoke citizenship. Since the passing of the Immigration Act in 2014, the UK’s Home Secretary is now able to take citizenship away from naturalised citizens who pose a threat to the ‘public good’ even though the decision may leave them stateless. Secondly, as scholars working on the implementation of citizenship revocation in Western cases have noted, governmental authorities often consider procedural safeguards as nothing more than obstacles in the exercise of their power,18 obstacles that they sometimes take the liberty to circumvent in practice.19 Conclusion The case studies in this symposium allow us to identify a number of interesting convergences characterising the uses of citizenship revocation across time and space. In my contribution I have laid emphasis on three such convergences: (1) the legitimation of citizenship revocation as a security measure, (2) the promotion of ‘thick’ conceptions of national membership and (3) the threat that citizenship revocation places on fundamental rights. I have suggested that these convergences are 17 This applies to citizenship revocation based not only on national security concerns but also on grounds of fraud. For a comparison between France and the UK on those aspects, see Fargues, É. (2017), ‘The Revival of Citizenship Deprivation in France and the UK as an Instance of Citizenship Renationalisation’, Citizenship Studies 21(8): 984– 998, and (2020) ‘Simply a Matter of Compliance with the Rules? The Moralising and Responsibilising Function of Fraud- Based Citizenship Deprivation in France and the UK’, in É. Fargues, E. Winter & M. J. Gibney (eds.), When States Take Rights Back: Citizenship Revocation and Its Discontents, 77-92. Op. cit. 18 Boekestein, T. & G.-R. de Groot, ‘Discussing the Human Rights Limits on Loss of Citizenship: A Normative- Legal Perspective on Egalitarian Arguments Regarding Dutch Nationality Laws Targeting Dutch- Moroccans’, in É. Fargues, E. Winter & M. J. Gibney (eds.), When States Take Rights Back: Citizenship Revocation and Its Discontents, 26–43. Op. cit. 19 For examples of how the British and French governments manage to circumvent procedural safeguards in the exercise of citizenship revocation, see Fargues, É. (2017) ‘The Revival of Citizenship Deprivation in France and the UK as an Instance of Citizenship Renationalisation’, op. cit. 48 Robert Schuman Centre for Advanced Studies Working Papers