2017] Citizenship Stripping Laws in the UK, Canada and Australia 41 in a broad and ill-defined range of circumstances. This is highlighted by the use of vague criteria such as ‘conducive to the public good’ in the UK. Such criteria can often be applied without the person affected having the opportunity to put their case in court or otherwise having a right to natural justice. In Australia, citizenship can be revoked in a way that even bypasses the need for a ministerial decision. These features erode fundamental tenets of the rule of law209 in a manner that is not proportionate to the achievement of national security or any other practical objective. This is not an outcome that should be accepted to achieve purely symbolic ends. Secondly, not all citizens are equally vulnerable to citizenship loss. In the denationalisation laws in each of the three countries surveyed, disloyal behaviour has rendered dual citizens (and, in the UK, naturalised sole citizens) vulnerable to the prospect of denationalisation, while other citizens are subject to lesser penalties for identical conduct. This creates an unequal, two-tiered citizenship. Moreover, it dilutes any symbolic statement that citizenship is a privilege conditional upon allegiant behaviour, because this conditionality only applies to select citizens. In his April 2016 report on the UK’s denationalisation laws, the Independent Reviewer of Terrorism Legislation, David Anderson, noted that citizenship deprivation powers ‘are said to make law-abiding immigrants feel unwelcome because they encourage the notion that naturalised citizens who have retained their citizenship of origin do not enjoy the same security as those who have always been citizens’.210 In a similar vein, it has been argued that singling out dual citizens for citizenship revocation is ‘counter-productive’ to domestic national security objectives because it ‘reinforces the identity issues that drive radicalisation’.211 This undermines key counter-radicalisation measures aimed at building community cohesion and social harmony, which have been implemented in all three of the countries surveyed as a critical component of counter-radicalisation policy.212 209 Martin Krygier, ‘On the Rule of Law: What It Is, Why It Matters, and What Threatens It’, The Monthly (Blog Post, 20 August 2015) <www.themonthly.com.au/blog/martin-krygier/ 2015/20/2015/1440049152/rule-law>, archived at <https://perma.cc/2AZ3-TLUS>. 210 Anderson, Citizenship Removal Resulting in Statelessness (n 35) 12 [3.5] (emphasis omitted). 211 Rachel Olding, ‘Stripping Dual Citizenship “Completely Counter-Productive” to Fighting Terrorism: UK Expert’, The Sydney Morning Herald (Sydney, 21 July 2015) <www.smh.com.au/nsw/stripping-dual-citizenship-completely-counterproductive-tofighting-terrorism-uk-expert-20150721-giha2k.html>, archived at <https://perma.cc/S6A6NLZY>. See also Williams, ‘A Decade of Australian Anti-Terror Laws’ (n 188) 1172–5. 212 In the UK, this is dealt with via the Prevent counter-radicalisation strategy: Secretary of State for the Home Department, Prevent Strategy (Cm 8092, 2011). This was supplemented in 2015 Advance Copy