PHAM v SSHD [2018] EWCA Civ 2064

The issue in this case was whether the decision to deprive Pham (convicted of terrorism offences and currently incarcerated in the United States) of his British citizenship was justified or should be subject to a Lumsdon (R (Lumsdon & Ors) v Legal Services Board [2015] UKSC 41) least restrictive measure criteria when assessing the proportionality of the decision to withdraw citizenship. The Court, whilst recognising the importance of nationality and citizenship, held that a British citizen can be deprived of his citizenship if he shows disloyalty to the state.

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