9. In any event, the provisions of the Law identify the mechanism for withdrawal and forfeiture of citizenship, when the relevant conditions are satisfied. The Law provides that it should be made pursuant to a decree based on a proposal by the Minister of Interior and the Cabinet’s approval. Before amendment, the said Law did not permit the withdrawal or forfeiture of citizenship, except by order of His Majesty King, as the head of state, its higher representative and protector of the rights and freedoms in it, because this procedure directly prejudices the rights and freedoms of individuals. 10. In the same context, NIHR has referred its advisory opinion to the House of Representatives in the course of deliberation of the draft law amending some provisions of the Bahraini Nationality Act of 1963, accompanying Decree No. (46) of 2014. It stressed that while the state has the power to organize and identify all issues relevant to the acquisition, loss, withdrawal, and forfeiture of nationality in order to protect the security and integrity of its national, regional and international interests, such organization should not in any way affect the public rights and freedoms set out in the Constitution or international conventions ratified by the State or to which the State acceded. 11. In its advisory opinion, NIHR commended the sound approach adopted by the draft law, Article 8 in particular, which exclusively identifies the cases in which it is legally permitted to withdraw the Bahraini citizenship of a naturalized person. It limits the effect of this procedure to the person alone, to the exclusion of the person through which it was acquired, except if the Bahraini citizenship was acquired by fraud or based on false statements, concealment of substantial information, or forged instruments. ‫اﻟﺘﻘﺮﻳﺮ اﻟﺴﻨﻮي اﻟﺜﺎﻟﺚ‬ ‫ﻟﻠﻤﺆﺳﺴﺔ اﻟﻮﻃﻨﻴﺔ ﻟﺤﻘﻮق اﻧﺴﻨﺎم‬ ‫ ـ ﻣﻤﻠﻜﺔ اﻟﺒﺤﺮﻳﻦ‬2015 ‫ﻟﻌﺎم‬ 12. Article 10, in particular Clause “c” thereof, of the draft law exclusively identifies the cases in which the Bahraini citizenship can be forfeited. It states that if the Bahraini national carries out any act contrary to the duty of loyalty to the Kingdom, nationality will be forfeited. Therefore, in order to restrain the arbitrary discretion of the administrative body to forfeit the Bahraini citizenship and its serious risks that directly affect fundamental human rights and freedoms, in view of the loose controls governing the cases of forfeiture of citizenship, the right of the state to forfeit the nationality of its citizens should be controlled by a firm legal framework in the form of court decisions of forfeiture and granting the person whose nationality is forfeited the right to effective appeal from the decision. 13. Accordingly, NIHR believes that the State’s right to forfeit nationality is a practice adopted in all legislation and legal systems. However, the exercise of such right must not lead to the emergence of statelessness phenomenon. According to the Bahraini legislation, people whose citizenship is forfeited may appeal from the citizenship forfeiture decision to the court. 14. In this regard, in its statement released on July 28, 2013, NIHR appreciated the recommendations made by the National Council in its extraordinary session based on its belief in the responsibility to maintain the capabilities, achievements and the future of this country. Nonetheless, NIHR stressed the need not to encroach upon the commitments of the Government of the Kingdom of Bahrain and its international obligations and to respect human rights. NIHR further asserted the need to observe the provisions of the law and to ensure its implementation in line with the constitutional and legal safeguards. 87