2019 Statelessness & Citizenship Review 1(2) majority admitted that the applicant was stateless at the time of the proceedings.38 When the applicant obtained Maltese citizenship, he renounced his Egyptian citizenship. 39 The Court seemed to suggest that the applicant’s statelessness does not constitute a problem because he is not threatened with expulsion from Malta and that, ‘to date he has been able to pursue his business and continues to reside in Malta’. 40 In other words, the effects on the applicant’s private and family life were not deemed serious enough to justify a violation because he was not expelled from Malta, even though he was rendered stateless. 41 As pointed out by Judge Pinto De Albuquerque in his dissenting opinion, citizenship is a core element of a person’s identity … any decision pertaining to the acquisition, change, denial, or revocation of citizenship should not depend on the degree of the risk of expulsion … The identity of an individual is determined by much more than his or her place of work or residence. The quintessential question of a person’s identity should not be decided on the basis of a prediction of uncertain, future risks, but on the past and present-day relationship that he or she maintains with the State and its people. 42 In its most recent decision of 22 January 2019, Said Abdul Salam Mubarak v Denmark (‘Said Abdul Salam Mubarak’), 43 the ECtHR was confronted with an expulsion decision that followed the deprivation decision. Therefore, unlike in Ramadan, the Court was obliged to consider the consequence of expulsion in its evaluation of art 8. 44 The Consolidated Act on Danish Nationality required weighing the deprivation decision against the severity of the offence and the impact on the person concerned. 45 The Danish Courts took into account: [T]he fact that he had been born and raised in Morocco, where he spent all of his school years and that he came to Denmark when he was 24. He had lived in Denmark for 32 years. Furthermore, he spoke Arabic and some Danish. He had not achieved a permanent attachment to the Danish labour market and had received social benefits since 1994. 46 From 1988 to 1999, the applicant was married to a woman in Denmark with whom he had four children. 47 They all have Danish nationality. 48 In 2013, under Islamic law, the applicant married a Danish national of Moroccan origin. 49 They had a daughter in 2015. 50 Having considered the impact of the deprivation decision, ‘including his ties with Denmark and Morocco, his current family situation and 38 39 40 41 42 43 44 45 46 47 48 49 50 ibid 1120 [92]. ibid 1101 [10]. ibid 1119 [90]. Marie-Bénédicte Dembour, ‘Ramadan v Malta: When Will the Strasbourg Court Understand that Nationality is a Core Human Rights Issue?’ Strasbourg Observers (Blog, 22 July 2016) <https://strasbourgobservers.com/2016/07/22/ramadan-v-malta-when-will-the-strasbourgcourt-understand-that-nationality-is-a-core-human-rights-issue/>, citing Ramadan (n 11). Ramadan (n 11) 1133 [OI-22]. Said Abdul Salam Mubarak (n 15). ibid 18–23 [61]–[73]. ibid 8 [31]–[32], citing Indfødsretloven [Consolidated Act on Danish Nationality] (Denmark) No 422 of 7 June 2004. Said Abdul Salam Mubarak (n 15) 70. ibid 2 [7]. ibid. ibid 2 [9]. ibid 2 [9], 20 [70]. 268