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AHK & Others

These cases are part of the AHK, AM, AS and FM (often referred to as AHK and Others) versus Secretary of State for the Home Department. Each of the four appellants (AHK, AM, AS and FM) brought a claim for judicial review to challenge the refusal of their application for naturalisation. Their claims came to be joined and numerous other claims of a similar nature being stayed behind them.

Each of the appellants (AHK, AM, AS, FM) applied for naturalisation to become British citizens but had their application refused by the Secretary of State on the ground that they did not meet the “good character” requirement. In each case, the Secretary of State declined to give detailed reasons for the refusal, adopting the position that disclosure of the reasons would be contrary to the public interest.


AHK is a political figure who has been actively working against Saddam Hussein’s government in Iraq, in collaboration with the US State. In 2007, he was refused naturalisation on the grounds of ‘good character’. The decision was based on closed evidence and his appeal was deemed unsuccessful in 2015.

For an elaborated profile on AHK please see the separate case study profile


AS was refused naturalisation in a letter dated January 2012, because the Home Secretary believed he has made statements that were of an ‘Islamist extremist nature and that he had been involved in activities of an ‘Islamist extremist agenda’. AS argues that the reasons provided were flawed and not adequate.


On 12 May 2010 the Secretary of State refused AM’s application for British citizenship on the grounds that AM could not show he was of good character. AM was told nothing beyond that naturalisation had been refused on the grounds of character and that it would be contrary to the public interest to give further reasons. AM challenged the decision arguing that the decision is contrary to public law and Article 8 of the European Convention of Human Rights. Furthermore, AM made reference to the Equality Act 2010 arguing that the decision is discriminatory in light of the fact that all or the vast majority of refusals of naturalisation were taken against persons who were both Muslim and members of ethnic minorities.

FM was refused British citizenship in July 2006 on the ground of ‘good character’. With time, the Secretary of State provided a more expanded explanation than in the case of AM, stating that FM was involved in ‘preaching extreme Muslim views’. Specifically, there was accusation that FM “openly preached anti-western views and voiced sympathy with Usama Bin Laden at the Hatherley Street Mosque in Liverpool”. FM maintained that he had never voiced any kind of sympathy with Usama Bin Laden, nor mentioned him during his sermons at the mosque. FM argued that his rights under the European Convention of Human Rights (ECHR) were breached and that the refusal of naturalisation constituted unlawful racial discrimination.

Both FM and AM argued that the decision to refuse their naturalisation went against the Equality Act 2010 and the Race Relations Act 1976. Neither were judged as relevant in the citizenship refusal cases and the individuals were asked to prepare their cases without taking into consideration either of the acts.