in each case by analysing all the factors involved, were to remain the criterion for citizenship. The diversity of circumstances encountered in applications is very wide. The judgements which have to be made in this area are essentially subjective, and matters of this kind are not easily justiciable. It is for consideration how far it would be an improvement to substitute the views of adjudicators for those of the Home Secretary and his advisers. Under the present system the standards applied in the generality of cases can be, and are, modified, and exceptions made to them, where this seems justified. But if good character was replaced by objective tests the scope of a right of appeal would be small. The only issues that would then come to an appeal would be the length of an applicant's residence in this country or his future intentions. Applicants who were refused on security and similar grounds could not in any case be given a right of appeal, because of the difficulty of disclosing in public the information that had led to the
refusal.
(e) Dual Nationality
63. United Kingdom law contains no bar on the holding of dual nationality. Of the citizens of the United Kingdom and Colonies who have other citizenships, some have obtained them by naturalisation in other countries, but the majority have them by reason of their descent. In particular, the close links between families in the United Kingdom and the Irish Republic have led to much dual citizenship. Most other countries place restrictions on the holding of other citizen- ships in addition to their own. Nearly all Commonwealth countries, for instance, withdraw citizenship from those who voluntarily acquire the citizenship of another country, taking the view that those who of their own free will acquire the citizenship of another country should lose their original citizenship since they have sought and obtained the protection of another State. Some of these countries made provision to