34 Melbourne University Law Review [Vol 41(2):Adv that he had died.177 This was later reported to perhaps be incorrect,178 however fresh reports that Sharrouf had died in an airstrike surfaced in January 2017.179 The fact that Sharrouf’s case is the only known example of the Allegiance to Australia Act being used reflects the fact that it is not clear that this new measure is actually useful in protecting the community from national security threats. In part, this is because other measures already provide such protection. Australia’s new denationalisation law operates alongside a wide range of other national security legislation, which already achieves many of the security objectives towards which the Allegiance to Australia Act is directed. As in the UK and Canada, broad passport suspension and cancellation powers provide the government with a considerable practical capacity to prevent Australians abroad from returning home when they are considered to pose a security risk.180 There is an open question as to whether a citizen who presents at the Australian border has a right of entry into Australia, irrespective of whether they have a valid passport.181 There is evidence to suggest that this was a point of concern for the Australian government when the Allegiance to Australia Act was drafted. For instance, Dan Tehan, chair of the Parliamentary Joint Committee on Intelligence and Security inquiry into the legislation, remarked during proceedings that citizenship revocation, in contrast to passport revocation, 177 See, eg, Dylan Welch, ‘Khaled Sharrouf and Mohamed Elomar Killed Fighting with Islamic State in Mosul, Reports Say’, ABC News (Online, 23 June 2015) <www.abc.net.au/news/201506-22/khaled-sharrouf-and-mohammed-elomar-killed-in-iraq-reports-say/6565162>, archived at <https://perma.cc/E7XT-ZU7P>. 178 See, eg, Paul Bibby, ‘Australian Terrorist Khaled Sharrouf May Be Alive, His Family’s Barrister Says’, The Sydney Morning Herald (Sydney, 15 February 2016) <www.smh.com.au/nsw/australian-islamic-state-fighter-may-be-alive-his-familys-barristersays-20160213-gmtkii.html>, archived at <https://perma.cc/TU46-LMVC>. 179 See, eg, Paul Toohey, ‘Australian ISIL Brigade and Notorious Executioner, Khaled Sharrouf, Killed in Mosul Air Strike’, Herald Sun (Melbourne, 13 January 2017) <www.heraldsun.com.au/news/world/australian-isil-brigade-and-notorious-executionerkhaled-sharrouf-killed-in-mosul-air-strike/newsstory/c2a2f945e29a81cd2e269f3d66897953>. This article notes that at the time, Australian government departments said that they were unable to ‘verify the [fresh] report[s]’ of Sharrouf’s death, as they had ‘limited capacity to confirm deaths in the war zone’. 180 Australian Passports Act 2005 (Cth) ss 22, 22A. 181 For an academic argument advancing this position, see Helen Irving, ‘Still Call Australia Home: The Constitution and the Citizen’s Right of Abode’ (2008) 30 Sydney Law Review 133. Cf Sangeetha Pillai, ‘Non-Immigrants, Non-Aliens and People of the Commonwealth: Australian Constitutional Citizenship Revisited’ (2013) 39 Monash University Law Review 568, 597; Sangeetha Pillai, ‘The Rights and Responsibilities of Australian Citizenship: A Legislative Analysis’ (2014) 37 Melbourne University Law Review 736, 759–61. To date, there has not been a case in which a court has been required to directly confront this question. Advance Copy