They're much wider. I've mentioned some of the countries that we've looked at. In Australia, for example, the minister may revoke citizenship if it would be contrary to the public interest for the person to remain an Australian citizen. That's based on the minister's opinion. It's a very broad discretion. In the United States they can pursue revocation for a conviction of high treason, or for being a member of an armed force at war with the United States.
In the United Kingdom an individual may be deprived of citizenship if it is “conducive to the public good”. There have been a number of recent cases where the Home Secretary of the United Kingdom, based on an amendment that had been adopted by Parliament under the previous Labour government, revoked citizenship because it was conducive to the public good. They did this to people who had been advocating violent extremism in the United Kingdom but who had not been convicted of the kind of serious terrorist defences that we are proposing.
New Zealand may deprive an individual of citizenship if the person has acted in a manner contrary to the interests of New Zealand.
These are just some examples of our closest peer countries, common law countries, that like Canada are great champions of human rights. All of them have in their respective citizenship laws much broader grounds for deprivation of citizenship than what we are proposing.