Cancellation of citizenship and national security
: a comparison between France and the UK

  • Rachel Pougnet

Student thesis: Doctoral ThesisDoctor of Philosophy (PhD)


In recent years a number of states have rolled back on citizenship rights by allowing for the deprivation of citizenship in respect of persons suspected of involvement in terrorist activities. My research uses a comparative, socio-legal approach to examine the contemporary re-tooling of citizenship deprivation as a counter-terrorism measure in the context of France and the UK. It asks, (i) what it might say about contemporary understandings of citizenship, and (ii) what surrounding constitutional structures might do to enable or restrict the methods and frequency of citizenship deprivation in such cases. As the first comparative study of its kind, my doctoral thesis advanced existing knowledge on citizenship deprivation by highlighting how complexity, history, and constitutional structures shape the use of the practice.

While citizenship deprivation has been part of legal frameworks since at least the aftermath of the First World War, France and the UK have recently taken steps to expand the use and breadth of the measure for national security purposes. In 2014, in the context of increasing numbers of citizens acting as ‘foreign terrorist fighters’, the UK introduced a critical amendment that allowed for citizenship to be deprived from naturalized citizens even if this resulted in statelessness. Since the aftermath of 9/11 birthright citizens are not immune from citizenship deprivation, either, although they are better safeguarded from statelessness. Different kinds of citizens, such as birthright and naturalised citizens, single and multiple nationality holders, are thus treated differently for the purposes of citizenship deprivation. A similar distinction and expansive practice exist in France. In November 2015, the country experienced terrorist attacks which propelled citizenship deprivation to the forefront of public debates. Once reserved to naturalised citizens, multiple nationality holders, the powers of citizenship deprivation were to be expanded to birthright citizens, even if this would leave individuals at risk of statelessness. However, the proposal failed, and France has a more limited practice and legal framework for citizenship deprivation than the UK.

These different experiences and approaches prompt three questions, which underpin the broad enquiries of my thesis: (1) What might explain states turning on their own minority citizens in the context of heightened national security threat? (2) Why is the practice of citizenship deprivation more expansive in the UK than in France? (3) What do this practice and the differences between French and UK approaches tell us about the content of citizenship and belonging in both countries?

By responding to these questions, this thesis reveals the presence of a deep insecurity in western, liberal states as to how citizenship is understood with respect to migrants who may become or have become citizens. I found that there are heightened duties to conform for minority citizens, naturalized citizens or citizens with foreign heritage such as ancestry from another country, who have their citizenship reframed as a “privilege” and contingent on “good” conduct. Citizenship as a legal status that gives access to rights is also left less secured, as statelessness is considered a legitimate consequence of purported involvement in terrorism activities. The extent to which this takes hold, however, is mitigated by the broader constitutional structures of the state; the thesis shows that the rigidity of the French constitutional structure limited expansion of citizenship deprivation, while the relative flexibility of the UK’s constitution enabled it.
Date of Award24 Mar 2020
Original languageEnglish
Awarding Institution
  • The University of Bristol
SupervisorDevyani Prabhat (Supervisor) & Paula Giliker (Supervisor)


  • Citizenship deprivation
  • Citizenship
  • National security
  • Comparative public law
  • Socio-legal studies
  • France
  • UK

Cite this