For the following reasons, Liberty Victoria recommends the Bill not be passed, and the current automatic citizenship loss provisions be repealed. a. Citizenship loss provisions, both discretionary and automatic, are not an effective response to the threat of terrorism and also risk undermining efforts to combat radicalisation.  b. The citizenship loss current and proposed provisions and the operation of the Citizenship Loss Board represent a threat to the rule of law and basic civil liberties.  c. The legal threshold for Ministerial decision risks manifestly disproportionate consequences.