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Stay the proceedings in the case and refer the following questions to the Court of Justice of the European Union for a preliminary ruling under the expedited procedure:

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Annul in part Council Decision (EU) 2020/135 of 30 January 2020 on the conclusion of the Agreement on the withdrawal of the United Kingdom of Great Britain and Northern Ireland from the European Union and the European Atomic Energy Community and the Agreement on the withdrawal of the United Kingdom of Great Britain and Northern Ireland from the European Union and the European Atomic Energy Community in so far as the withdrawal agreement does not fully protect the right to health of those nationals and in so far as those acts distinguish systematically and indiscriminately, without any review of proportionality, EU citizens from UK nationals from 1 February 2020 and annul, inter alia, the sixth paragraph of the preamble and Articles 9, 10 and 127 of the withdrawal agreement;

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Order the European Union to pay the costs of the proceedings, including legal fees of EUR 5 000.

1.

First plea in law, alleging no review of proportionality of the removal of the EU citizenship of certain categories of UK national. The applicant states that as an EU citizen who exercised his right to free movement within the European Union and given that he left the United Kingdom more than 15 years ago, he was not able to vote in the referendum of 23 June 2016 on the United Kingdom’s membership of the European Union.

2.

Second plea in law, alleging breach of the principles of democracy, equality of treatment, freedom of movement, freedom of expression and good administration.

3.

Third plea in law, alleging infringement of the legal order of the European Union and of the principle of equality of treatment which is an inherent part of EU citizenship. The applicant claims, inter alia, that the contested decision is contrary to the legal order of the European Union, which enshrines the principle of equality of treatment of all citizens, and to the legal order of the Convention for the Protection of Human Rights and Fundamental Freedoms.

4.

Fourth plea in law, alleging breach of the principles of legal certainty and of the protection of legitimate expectations. In that regard, the applicant claims, inter alia, that the contested decision authorises the loss of his permanent right to remain, which he acquired after 5 years of continual residence in a Member State without the real consequences of that loss being provided for and, in particular, without any review of proportionality.

5.

Fifth plea in law, alleging infringement of the right to respect for private and family life guaranteed by the Convention for the Protection of Human Rights and Fundamental Freedoms. The applicant claims that the contested decision limits his right to private and family life to the extent that it removes his EU citizenship and, consequently, his right to reside freely in the territory of a Member State of which he is not a national, but in which he has built his family life.

6.

Sixth plea in law, alleging an infringement of the right of UK nationals to vote and to stand as candidates in European and municipal elections. According to the applicant, Article 127 of the withdrawal agreement infringes Article 18 TFEU and Articles 20 and 21 of the Charter of Fundamental Rights of the European Union. The contested decision should therefore be annulled in so far as it ratifies an agreement including a provision creating discrimination between UK citizens.

7.

Seventh plea in law, alleging a systematic and indiscriminate distinction in the withdrawal agreement between EU citizens and UK nationals without any review of proportionality with regard to the private and family life of UK nationals from 1 February 2020. In support of that plea, the applicant argues that the removal of EU citizenship must not be systematic and indiscriminate, that a specific assessment of the consequences should be necessary and that, in the absence of such an assessment, the contested decision must be annulled.

8.

Eighth plea in law, alleging infringement of Article 35 of the Charter of Fundamental Rights of the European Union, namely the right to health. The applicant claims that, since the withdrawal agreement provides in no way for the protection of his right to health, the possibility for the United Kingdom and its nationals to be lent support disappears, which puts the latter in danger, in particular during a pandemic and a health crisis.