and, retroactively from 1 June 1951, no male national of France under the age of 50 would be subject to the automatic loss provision (section 87) of the 1945 Nationality Code without the specific permission from the French government. This limited the automatic loss of nationality to men over 50 and women, as the permissions to lose French nationality were automatically given to them upon their naturalizations. In 2013, a woman who lost her French nationality under section 87 appealed to the Constitutional Council, which found the provision to be unconstitutional under the 1946 Constitution and the 1789 Declaration and ordered the reinstatement of her nationality. As a result of this decision, all women who lost their nationality between 1951 and 1973 solely under section 87 may voluntarily request for the reinstatement of their nationality by invoking this decision, and their descendents would also be able to invoke this decision if their female ancestors have done so. Since 1973, dual nationality has been legalized for all French nationals, although a person might still be deprived of their French nationality under bilateral or multilateral treaties or agreements France concluded with other countries. In 2007, the Ministry of Justice concluded that a French male residing in the Netherlands and naturalized as a Dutch national in 2006 based on his marriage to a Dutch man lost his French nationality upon naturalization, because a 1985 agreement between France and the Netherlands stipulated that any national of either country who acquired the other country's nationality would cease to be a national of their country of origin. A provision in the agreement provided exemptions for married couples, but as France did not recognize same-sex marriage in 2006, it was deemed to be not applicable to him as he was not considered to be married under French law. Due to the case which sparked national outrage, the Sarkozy administration announced that it would be taking steps to denounce some portions in the agreements with the Netherlands and other countries in 2009. France later denounced Chapter I of the Council of Europe's Convention on the Reduction of Cases of Multiple Nationality and on Military Obligations in Cases of Multiple Nationality of May 6, 1963. The denunciation took effect on March 5, 2009. Citizenship of the European Union Because France forms part of the European Union, French citizens are also citizens of the European Union under European Union law