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Richard Cornes: 11-1 gender ratio Court’s Achilles Heel: Reporting of the Supreme Court’s start of the year press briefing

SCA relationship of cooperation but also competing interests

On October 2 at 10am, the United Kingdom Supreme Court held an hour long pre-term press-briefing to mark the opening of the Court’s fifth year. This blog looks not only at what was said by the Court, and asked by the journalists on the day, but also what was then reported.

The Supreme Court’s relationship with the media is marked by the same combination of common interests and tensions which mark the media’s relationship with any other public body. Yes the Court wants media coverage; and a function of the media is to cover the Court. The media though will always want more than its subjects are looking to give up, and not only that, will often frame how the subject is presented according to each outlet’s particular agendas. Further, the Court, and its justices, will also have their own goals about what messages should be highlighted.

The new transparency – Court opens year with press briefing

That a press briefing featured in the start of year events says something about this still new court. Unlike what went before – the Appellate Committee – the @uksupremecourt has a now seasoned press office (for previous analysis see here and here). While the Court will not rival Strictly for coverage (and likely would not want to – justice, while prepared to show a little leg, still likes to maintain some mystique), its communications operation, which continues to innovate, has made it a world leader amongst top courts for transparency and accessibility.

The President and Deputy President speak

First, what did the Court say in opening? The President and Deputy President both spoke for a total of about fifteen minutes. Lord Neuberger opened by seeking to set the boundaries of what he and Lady Hale would be prepared to say:

As judges we are constrained in some respects as to what we can discuss. For instance, it is inappropriate for judges to give opinions publically on political matters save in so far as they impinge on the rule of law. We have to be wary of expressing views on issues which we may have to decide in due course in court.

His remaining remarks reviewed the number of cases decided since October 2012 (82), and highlighted a selection before closing with a paean to the importance of open justice, including discussing elements of the Court’s communications innovations.

Lady Hale, still, remarkably, the only woman on the Court noted some of the forthcoming terms “highlights”. There’s a curiosity here, almost all cases require leave, and must therefore be “Supreme Court worthy”, and yet this trailing of cases the Court considers likely to be of greater public interest gives us a new gloss on the leave process: the “super-Supreme Court case”. Lady Hale closed with a reflection she must be tiring of making about the lack of women on the Court, and the need for greater diversity in the judiciary generally. It was a reflection though which, as we shall see, made for good press.

Questions from the press

Then came the press questions – each topic necessarily revealing of the questioners’ interests, and in places, their outlet’s agendas. The Court (its Chief Executive, Jenny Rowe, in the chair for this purpose) gave the prized first question to Joshua Rozenberg who asked for a reaction to Conservative policy on repeal of the Human Rights Act, with a techy follow up on what the Court would do if the Act were repealed: develop a common law equivalent of the s.3 obligation (my gloss on Rozenberg’s question)? Faced so directly with such a potentially politically charged question both the President and Deputy declined to speculate. However, coming back to the point later in the hour Dominic Casciani from the BBC did get a little further, eliciting this from Lord Neuberger:

I am now doing what I said I would not do – picking up on Joshua’s point… if we did not have the Human Rights Act, the common law might develop in certain directions to accommodate a degree of change because the common law does change with the times. How it would change and in what respect is pure speculation.

The subtle message being sent by the President that repealing the Human Rights act might not be the last word on human rights principles appearing in Supreme Court jurisprudence was not one which lent itself to an easy headline (the discussion was really only covered by the UKSC blog); the skill was in putting the idea on the record without providing material for “Supreme Court responds to Tory plan to scrap Human Rights Act” type coverage. And indeed, Rozenberg chose the elements of the briefing touching on open court processes for a subsequent Guardian piece.

Francess Gibb of the Times was called next and followed up Lady Hale’s comments about diversity – an issue she did choose for one of her subsequent reports, the others highlighting the concerns Lord Neuberger raised over legal aid, and the Court’s openness agenda. David Barrett of the Telegraph followed up on diversity asking Lady Hale whether she still did not favour positive discrimination (she does not). Barrett’s story on the topic ran under the headline, “Top female judge questions male ‘dominance’”. The other story Barrett chose for print concerned a series of comments Lord Neuberger made about the importance of open justice.

Jack Doyle from the Mail then followed with a question about the wearing of veils in court rooms, including whether the Supreme Court would allow veiled advocates before it – a question which the President chose, in his own words, to “duck”. The veil question did not headline in Doyle’s coverage (though it did make the Express). Like others, one of Doyle’s subsequent pieces also pursued the theme of judicial diversity, “Women not being made top judges because men ‘dominate’ the selection process, says Britain’s only female Law Lord.” Another “’I welcome increased openness unreservedly’ Supreme Court judge’s praise for Mail’s open justice fight”. While both headlines had a basis in what had been said by the two judges, both were the most tendentious of all the subsequent coverage. The open justice theme in particular being linked to a wider Mail campaign about openness in the justice system per se.

Owen Bowcott from the Guardian brought the discussion back to open justice issues, referring to the Supreme Court’s decision (on a 6-3 vote) to allow for closed sessions in connection with the Bank Mellat case. While subsequently reporting on that discussion, and a latter question about the appropriateness of judges attending an Anglican church service to mark the opening of the legal year (which Bowcott raised as a possible independence problem for a court system grappling with questions of veils in courts), the headline for Bowcott’s coverage was, “Lady Hale, supreme court’s sole female justice, calls for diversity.”

From the BBC, this time Danny Shaw, came a question to Lord Neuberger about his previously expressed concerns about cuts to legal aid. For political sensitivity – touching as it does on sensitive resource questions for the Ministry of Justice – the question was up there with Rozenberg’s gambits on the consequences of repeal of the Human Rights Act. Lord Neuberger’s comments on October 2 included:

Rights, whether human rights or other rights, are valueless if they cannot be enforced in court. Reductions in legal aid therefore inevitably cause one concern. … I think that legal aid cuts therefore do cause any person concerned with the rule of law a worry.

The President did couch his concern in an explicit acknowledgment that difficult economic times have to be taken into account; referring back to his opening comments, he provided more of an insight into his view of the wider role of a lead judge, “one of our functions is not merely to sit in court, but also to support and ensure the rule of law.” It was a potent point, subtly made.

With the clock heading towards 11am, Brian Farmer from the Press Association asked about the wearing of legal wigs in court, linking discussion about rules for dress in court back to earlier questions about veils in court. Jane Croft from the Financial Times then came in with a question about divorce cases which allowed Lady Hale, while commenting that the principles in the area were now mostly settled (and thus not likely to give rise to Supreme Court level questions) to note, “obviously, we are not law reformers.” The line, “we are a court, and not a law reform body”, it will be recalled was one strand of Lady Hale’s dissent in the Radmacher v Granatino decision. Croft’s story the next day though was the “First woman law lord Brenda Hale calls for more female judges.”

So far I have only mentioned press coverage. The only other media coverage I found was on Radio 4’s 6pm news which picked up Lady Hale’s comments about the lack of female appointments to the Court. Standing back then, what comes through? First, the event resulted in no media “gotchas.” In particular neither what was said about the Human Rights Act nor legal aid were written up in any sense as “judges criticise government (or Conservative party) policy”. Partly I suspect that is because the judges did not give their audience any suitably juicy sound-bite. Second, there were clearly other issues running of potentially greater controversy on which the press wanted comment on the day: specifically, veils in court, and general concerns about the openness of judicial processes.

Stand-out message? 11-1: the Court’s Achilles heel

The stand-out message emerging from the exercise though is that despite 13 appointments at the Law Lord level since Brenda Hale was appointed 10 years ago, Lady Hale remains the lone female voice on the UK’s top court. Lady Hale can take only some of the credit for this point dominating the next day coverage (including comments which made it online in video form). What actually gets covered from an event like this is the press’s call. And it is striking that of coverage of the briefing (I counted around 15 or so stories), about 75% headlined the diversity point. The Court’s 11-1 gender ratio is clearly of interest to a goodish cross section of the mainstream press. And if that is the message getting through to readers from the Guardian to the Telegraph (and all points in between and beyond), the Court should be worried.

Dr Richard Cornes (@CornesLawNZUK) is a Senior Lecturer at the @EssexLawSchool, and Associate Member of Landmark Chambers, London.

 Suggested citation: R. Cornes, ’11-1 gender ratio Court’s Achilles Heel:  Reporting of the Supreme Court’s start of the year press briefing’  UK Const. L. Blog (16th October 2013) (available at http://ukconstitutionallaw.org)

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Christopher Forsyth: Principle or Pragmatism: Closed Material Procedure in the Supreme Court

forsyth1 In Al Rawi & Ors v The Security Service & Ors [2011] UKSC 34; [2012] 1 AC 531 the claimants (respondents in the Supreme Court) were bringing civil claims for damages against the defendants (appellants in the Supreme Court) alleging complicity by the defendants in their mistreatment by foreign powers (including detention at Guantanamo Bay). The defendants as part of their defence wished to place before the court “security sensitive material” – presumably the evidence of intelligence agents, or similar, denying the complicity – which for security reasons could not be disclosed to the claimants. Thus the defendants submitted that the court hold a “closed material procedure”. They envisaged that the evidence would be placed before the courts in closed session, i.e. a session from which the claimants and their representatives (and the public) were excluded. In the closed session the claimants would be represented by “special advocates” appointed by the court who would have access to the evidence but would not be able to take instructions from the claimants. Such procedures are controversial since they threaten the fundamental principles of open justice and natural justice. On the other hand, the national interest would doubtless be impaired, in some cases, if intelligence agents gave evidence and their methods and secrets were exposed in open court.

Statute makes express provision for such “closed material procedure” to be adopted by judicial bodies in several cases (for instance, the Terrorism Prevention and Investigation Measures Act 2011, Schedule 4, or the Counter-Terrorism Act 2008, Part 6); but there was no specific statutory provision applicable to civil actions for damages.  Thus the question arose whether the court had power at common law (or under its inherent jurisdiction) to craft such a procedure.  Lord Dyson, giving the lead judgment in which Lords Hope, Brown and Kerr concurred, was clear. He said:

“Closed material procedures and the use of special advocates continue to be controversial. In my view, it is not for the courts to extend such a controversial procedure beyond the boundaries which Parliament has chosen to draw for its use thus far. It is controversial precisely because it involves an invasion of the fundamental common law principles to which I have referred [viz, open justice and natural justice particularly the right to know the case to be answered]. I would echo what Lord Phillips said in Secretary of State for the Home Department v AF (No 3) [2009] UKHL 28; [2010]2 AC 269. ‘How [the] conflict [between full disclosure of the allegations against a party and other aspects of the public interest] is to be resolved is a matter for Parliament and for government, subject to the law laid down by Parliament’.”

That one might have thought was that. In the absence of clear Parliamentary warrant there could be no “closed material procedure” or its concomitant “special advocate”.  But what then is to be made of Bank Mellat v Her Majesty’s Treasury (No. 1) [2013] UKSC 38? Here the Supreme Court, in the absence of an express statutory warrant, held that it had the power to order a “closed material procedure” and indeed went on to hold such a procedure!

What had happened here was that the Treasury had made the Financial Restrictions (Iran) Order 2009 which in effect closed down the UK operations of Bank Mellat, an Iranian Bank, and its subsidiary. The Order was made under section 62 and Schedule 7 of the Counter-Terrorism Act 2008 which provides that amongst many other things if “the Treasury reasonably believes” that “the development or production of nuclear …. weapons in [a] country … poses a significant risk to the national interests of the United Kingdom”  it might give directions which had the effect mentioned. The directions had to be (and were) approved by affirmative resolution of Parliament within 28 days.

This decision could be challenged and was challenged by Bank Mellat by way of a statutory form of judicial review provided for in section 63 of the 2008 Act. The 2008 Act, in Part 6, provided for a “closed material procedure” in such proceedings. And the Treasury “took the view” (which was accepted by Mitting J at first instance) “that some of the evidence relied on by the Treasury to justify the 2009 Order was of such sensitivity that it could not be shown to the Bank or its representatives”; consequently that evidence was dealt before Mitting J by a closed material procedure (and there was a short closed judgment). On appeal to the Court of Appeal that material was dealt in a short closed session.  But now the matter had come before the Supreme Court. Part 6, and in particular section 73 of the 2008 Act, made provision for “closed material procedures” to be adopted in the High Court, the Court of Appeal and the Court of Session. But no mention was made of the Supreme Court. Where was the Parliamentary warrant for “closed material procedures” before the Supreme Court?

Lord Neuberger (with Lady Hale, Lord Clarke, Lord Sumption, and Lord Carnwath concurring), however, held that the Supreme Court had the power to conduct a “closed material procedure”. (Lord Dyson agreed with this outcome.) But here is the interesting part: the Supreme Court (or at any rate the majority) was not, in its view, disregarding or departing from Al-Rawi.  The statutory warrant to hold a “closed material procedure” was found or implied from section 40(2) and 40(5) of the Constitutional Reform Act 2005. Section 40(2) provides that “An appeal lies to the [Supreme] Court from any order or judgment of the Court of Appeal in England and Wales in civil proceedings” (emphasis added) and section 40(5) provides that “The [Supreme] Court has power to determine any question necessary to be determined for the purposes of doing justice in an appeal to it under any enactment.” Thus the majority reasoned: since “section 40(2) provides that an appeal lies to the Supreme Court against ‘any’ judgment of the Court of Appeal… that must extend to a judgment which is wholly or partially closed…[and] in order for an appeal against a wholly or partially closed judgment to be effective, the hearing would have to involve… a closed material procedure;.. such a conclusion is reinforced by the power accorded to the Court by section 40(5) to ‘determine any question necessary … for the purposes of doing justice’, as justice will not be able to be done in some such cases if the appellate court cannot consider the closed material” (Lord Neuberger, para 37). This is a powerful argument. How could the Supreme Court do justice in a case where there had been a “closed material procedure” in the Court of Appeal or at first instance, without looking at that material itself? And, ignoring the closed material, or revealing it before the Supreme Court, were not attractive alternatives.

But the dissenting judges (Lord Hope, Lord Kerr and Lord Reed) took a different view. Naturally much was made of Lord Hoffmann’s canonical words in R v Home Secretary, ex parte Simms [2000] 2 AC 115 at 131: “…the principle of legality means that Parliament must squarely confront what it is doing and accept the political cost. Fundamental rights cannot be overridden by general or ambiguous words. This is because there is too great a risk that the full implications of their unqualified meaning may have passed unnoticed in the democratic process. In the absence of express language or necessary implication to the contrary, the courts therefore presume that even the most general words were intended to be subject to the basic rights of the individual.” Whatever else might be the case there had been no careful consideration by Parliament in enacting the 2005 Act whether the right to open justice should be overridden (in 2008!).

And Lord Kerr (paras. 124-5) explained why he was not persuaded by the claims of the pragmatic considerations of the majority. He said:

“Pragmatic considerations can – and, where appropriate, should – play their part in influencing the correct interpretation to be placed on a particular statutory provision. But pragmatism has its limits in this context and we do well to recognise them. As a driver for the interpretation of section 40(5) for which the respondent contends, pragmatism might seem, at first blush, to have much to commend it. After all, this is an appeal from courts where closed material procedures took place. How, it is asked, can justice be done to an appeal if the court hearing the appeal does not have equal access to a closed material procedure as was available to the courts whose decision is under challenge? And if one proceeds on the premise that the court will be more fully informed and better placed to make a more reliable decision, why should the Supreme Court not give a purposive interpretation to section 40(5)?

The answer to this deceptively attractive presentation is that this was never the purpose of section 40(5). It was not even a possible, theoretical purpose at the time that it was enacted. It was never considered that it would be put to this use. The plain fact is that Parliament introduced a closed material procedure for the High Court, the Court of Session and the Court of Appeal and did not introduce such a procedure for the Supreme Court. This court has said in Al-Rawi that it does not have the inherent power to introduce a closed material procedure. Only Parliament could do that. Parliament has not done that. And to attempt to graft on to a statutory provision a purpose which Parliament plainly never had in order to achieve what is considered to be a satisfactory pragmatic outcome is as objectionable as expanding the concept of inherent power beyond its proper limits.

“Closed material procedure” and “Special Advocates” will never be popular with lawyers bred, as they should be, with natural justice in their bones. So the courts, and particularly the Supreme Court, will be rightly sceptical of such devices. But Parliament has ordained that such procedures are lawful in certain circumstances. The inevitable tensions and discontinuities between what Parliament has ordained and the instincts of the courts are difficult to resolve. In this fallen world there will never be an easy resolution to this clash between pragmatism and principle. The clash between the protection of fundamental rights and the protection of national security (as well as loyalty to Parliament’s will) will always be acute.  Bank Mellat shows that the pragmatists are, on this issue, in the ascendency. But the issue is still contested and we have not heard the last of it.

In one respect the tension is resolved. Part 2 of the Justice and Security Act 2013 enacted in response to Al-Rawi provides for closed material procedures in civil proceedings; and section 6(11) provides that “relevant civil proceedings” means “any proceedings (other than proceedings in a criminal cause or matter) before (a) the High Court,  (b) the Court of Appeal, (c) the Court of Session, or (d) the Supreme Court” (emphasis added).  Alas, in enacting the Terrorism Prevention and Investigation Measures Act 2011, Schedule 4 (dealing with closed material procedures for TPIM) Parliament was presumably not mindful of Al-Rawi and refers only to the High Court,  the Court of Appeal and  the Court of Session! Presumably in TPIM cases the power to hold closed material procedures will be vouchsafed by section 40(2) & (5) of the 2005 Act.

Bank Mellat prompts a final reflection based on something that is not mentioned in any of the judgments. In R v The Lord Chancellor, ex parte Witham [1998] QB 575 Laws LJ suggested that common law constitutional rights – he had in mind the right of access to the courts but the right to open justice would serve as well -  could only be removed by express words in legislation.  He said: “I find great difficulty in conceiving a form of words capable of making it plain beyond doubt to the statute’s reader that the provision in question prevents him from going to court (for that is what would be required), save in a case where that is expressly stated. The class of cases where it could be done by necessary implication is, I venture to think, a class with no members”. But the bold approach by the majority in Bank Mellat suggests that limitations on constitutional rights may established by necessary implications from the relevant statute.

Christopher Forsyth is Professor of Public Law and Private International Law at the University of Cambridge.

Suggested citation:  C. Forsyth, ‘Principle or Pragmatism: Closed Material Procedure in the Supreme Court’  UK Const. L. Blog (29th July 2013) (available at http://ukconstitutionallaw.org)

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Kate Malleson: Judicial views on the selection process for senior judges

The President of the Supreme Court, Lord Phillips, gave evidence to the House of Lords Constitution Committee¹s inquiry into the judicial appointments process last week. He argued against the introduction of any form of parliamentary hearings for Justices of the Supreme Court or the Lord Chief Justice. In this view, he is joined by most, if not all, the other members of the Supreme Court and senior judiciary who remain to be convinced that there is any role for Parliament in the appointment process of individual judges. More surprising, was Lord Phillips’ view about potential reforms to the role of the Lord Chancellor in the process. He argued that he would like the Lord Chancellor to be on the selection commission for Supreme Court appointments, believing that this would be preferable to the LC having a veto late in the process. Even more unexpectedly, Lord Phillips strongly objected to the requirement that he must sit on the panel to choose his successor – he said that he had tried to argue that one can interpret the provision to excuse the President when the next President is to be selected but that he had not been successful in persuading others that his interpretation is tenable. Although this is the first time (as far as I am aware) that Lord Phillips has expressed this view publicly, he is not alone amongst the judges in accepting that the current process, whereby the President and Deputy President both sit on the Supreme Court ad hoc selection committee is problematic. There has been a strong groundswell of opinion outside the judiciary that this arrangement is likely to promote self-replication and is inconsistent with all other senior appointments processes in either the public or private sector. It appears from the evidence taken by the Committee that some of the senior judges share this concern. This therefore looks like an area in which the Committee is likely to recommend reform.  The last surprise from Lord Lord Phillips was his decision to produce a draft of a provision that might replace the ‘merit’ provision in the Constitutional Reform Act 2005. His amendment read that: “The Commission must select that candidate who will best meet the needs of the Court having regard to the judicial qualities required of a Supreme Court Justice and the current composition of the Court”. Having produced the draft provision Lord Phillips made clear that he  himself would object to such a change and would argue against it. What the Committee will make of that position, is hard to know.

This post originally appeared in  the Constitution Unit’s Blog as part of a project on judicial independence.

Kate Malleson is Professor of Law at Queen Mary University of London.

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Roger Masterman and Jo Murkens: What Kind of a Court is the UK Supreme Court?

The United Kingdom Supreme Court (UKSC) is something of a novel institution among apex courts.  It is not a typical supreme court with strong powers of constitutional review, but it has powers to determine the legality of administrative and executive acts and to review statutes on human rights and European Union law grounds.  It cannot be conceived as the ‘ultimate guardian of the constitution’, but it clearly discharges a range of constitutional functions which are in many ways approximate to those carried out by top courts elsewhere.  It is not a federal court, but has power to determine competence disputes between the Westminster Parliament and devolved legislatures and administrations.  It is not an agent of the legislature, though its work is conditioned by the doctrine of parliamentary sovereignty.  It undertakes no constitutionally-prescribed checking function, though it can be seen to play a ‘counter-majoritarian’ (at paras 209-211) role in holding government to account.  It is not a political institution, though it clearly makes decisions that are politically controversial.  As a result, the UKSC neither clearly fits, nor completely eschews, the institutional precedents of other national apex courts.

Some explanation for this can be found in the fact that it was never an objective of the Labour government to engage (in this area at least) in radical constitutional redesign.  The transition from Appellate Committee of the House of Lords to Supreme Court displays much of the continuity and incrementalism that is characteristic of constitutional change in the United Kingdom; neither the jurisdiction nor composition of the UKSC, for instance, depart radically from those of the House of Lords.

At the same time however, as a result of the of the UK’s traditional apathy towards separation of powers as a template of institutional design, the severing of structural links between the legislature and top court was a marked development, and the most visible aspect of the Constitutional Reform Act’s new regime.  The creation of a formal apex court, autonomous of the elected branches of government, is also a milestone in the formalisation of the judicial branch and its functions and a manifestation of the ongoing shift in the balance of power, away from politicians towards the judges, which has implications for all constitutional institutions.

Any attempt to characterise the UKSC has to take account of the past: the judicial House of Lords was subordinated to Parliament, and did not play a leading role in the interpretation of constitutional law and politics.  Any new conception also has to take account of the present: the incremental accrual of functions relating to EU Law, individual rights and devolution – alongside the burgeoning constitutional function of the common law – have begun to cement the place of the UKSC as a constitutional actor in its own right.  Lord Hope has spoken of the ‘added authority’ carried by decisions handed down by a Supreme Court independent of Parliament.  In terms of powers, Lord Phillips has acknowledged that the UKSC discharges ‘some of the functions of a constitutional court’, while in Parliament the suggestion has been made that the UKSC is becoming ‘increasingly robust’.  Finally, the conception of the UKSC has to make provision for the future: there are judicial dicta by Lord Steyn and Baroness Hale in Jackson that the courts may claim an inherent power to strike down legislation or, at least, to render ineffective any Act of Parliament deemed to be ‘unconstitutional’.  Whilst this may still be viewed as a hypothetical scenario, how widespread is the view amongst the senior judiciary that Parliament can with impunity violate the fundamental precepts of the rule of law?

The precise constitutional status of the UKSC is difficult to encapsulate, but two traps need to be avoided.  The UKSC does not have suprema potestas: the establishment of the UKSC will not usher in an age of ‘judicial supremacy’.  But neither is it ‘a third chamber in perpetual session’: the passive-subservient conception of the United Kingdom’s apex court no longer reflects judicial attitudes, nor the status of the UKSC as an independent constitutional actor.

In short, the essence of modern constitutionalism is not determined by its form (e.g. visible separation of powers, documentary constitution, higher-order law etc.) but through its content.  The ‘new constitutional settlement’ that consists of the Human Rights Act 1998, the devolution legislation of 1998, and the Constitutional Reform Act 2005 is best understood as allowing for a constitutional relationship between Parliament and the courts in which each is able to make a distinctive contribution to the furtherance of rights protection and the articulation of constitutional standards.  The search for an ultimate constitutional authority is a diversion: as Lord Cooke has argued ‘legislative and judicial functions are complementary; the supremacism of either has no place.’

In providing a focal point around which the judicial checking and balancing functions of the UK constitution might coalesce, the creation of the UKSC finally vindicates aspects of the French and American constitutional paradigm.  However, instead of forming part of a revolutionary constitutional moment or explicit break with the past, the UKSC ushers in a more visible separation of powers by stealth.  Alongside the traditional legislative-executive dualism, and skirting the extremes of constitutional subordination and superiority, the UKSC has emerged as an autonomous and co-equal agent of the constitution.

 

Roger Masterman is Reader in Law at Durham University.

Jo Murkens is Senior Lecturer in Law at the London School of Economics and Political Science

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