2017] Citizenship Stripping Laws in the UK, Canada and Australia 19 limit to its effectiveness.89 However, whether citizenship stripping actually avoids this prospect is not clear. Guy Goodwin-Gill, for instance, has argued that, under international law, ‘[a]ny State which admitted an individual on the basis of his or her British passport would be fully entitled to ignore any purported deprivation of citizenship and, as a matter of right, to return that person to the United Kingdom’.90 Where a citizen is within the UK, citizenship stripping facilitates their permanent removal, an outcome which is not achievable via other mechanisms. However, the very small number of revocations in this context suggests that this is not generally seen as critical to maintaining national security. Moreover, there can be practical challenges to removing a denationalised person from the UK, as this depends upon finding a country willing to take them. This is likely to be particularly challenging where revocation results in statelessness. Even where this is not the case, deportation can prove practically difficult. For instance, in Pham v Secretary of State for the Home Department, the applicant was a naturalised British citizen who had not renounced his prior Vietnamese citizenship.91 The Home Secretary ordered that he be stripped of his British citizenship and deported to Vietnam. Deportation was frustrated when the Vietnamese government responded that it did not recognise the applicant as a Vietnamese citizen.92 Cases such as this demonstrate the problematic nature of citizenship revocation as an effective counterterrorism tool and why such a power may be of limited utility compared to other measures. The analysis above illustrates that, through each of its recent iterations, UK denationalisation law has made a powerful statement about what citizenship entails and which citizens should lose the privilege to hold it, but that it has been of questionable utility as a national security device. This raises the question of whether a strong symbolic rationale is sufficient justification for the laws in light of their expansive nature and the weakness of the security rationale that underpins them. This question is discussed further in Part III. 89 Ibid 851–2. 90 Guy S Goodwin-Gill, ‘Deprivation of Citizenship Resulting in Statelessness and Its Implications in International Law’ (Opinion, 12 March 2014) 12 [24] (emphasis omitted) <https://assets.documentcloud.org/documents/1086878/guy-s-goodwin-gill-legal-opinionon-deprivation.pdf>, archived at <https://perma.cc/3T8Z-TYTD>. 91 [2015] 1 WLR 1591. 92 Ibid 1595–6 [3]. Advance Copy