Reviewing the Democratic Legitimacy of the House of Lords: Legislation Proposal
Written by William Rummage
International Law Department
Spring 2026 Volume 1: Issue 1
April 20, 2026
DOI: https://doi.org/10.5281/zenodo.19658612
ABSTRACT
The House of Lords is the second chamber of the United Kingdom’s parliament, serving as a constitutional check by revising legislation through its expertise. However, the current institutional design and legal framework of the House of Lords lacks democratic legitimacy. This framework is defined by the Life Peerages Act of 1958 and the House of Lords Act 1999, which allows the House of Lords to include hereditary peers and operate as an unelected chamber. This article examines the crucial role of the House of Lords, arguing that the current legal framework requires reform and that new legislation should be implemented to completely remove hereditary peers, cap the second chamber’s size, and allow for a cross-party parliamentary committee to be established to ensure that appointments are representative of all political parties within parliament and there is no prime ministerial influence.
I. ROLE OF THE HOUSE OF LORDS
The House of Lords is the upper chamber of the Parliament of the United Kingdom, helping shape the country’s laws. This second chamber plays a role in the legislative process of the UK government by examining the bills proposed in the House of Commons and helping to improve “the quality of legislation due to the Lords’ legislative expertise”[1] through their specialist knowledge from a range of professional backgrounds. The upper chamber is granted legal power to “suggest new amendments and alter the existing ones.”[2] The House of Lords is designed as a “delaying chamber”, meaning that it “may only reject bills or amendments made by the Commons or propose an amendment” but it can not implement it without the House of Commons.[3] The legal reasoning behind the institutional structure of the House of Lords is its “substantial role in the legislative process” and how the chamber is granted powers from the UK constitution to check the legislature through expertise and revision.[4]
The current institutional structure of the House of Lords arose from a complex history of UK governance. While other countries’ parliaments have a defining founding moment, “the English parliament emerged gradually, and evolved over centuries into the UK parliament that exists today.”[5] What would eventually become the House of Lords developed starting in the fourteenth century, with the chamber that was “presided over by the king’s chief minister, the Lord Chancellor.”[6] Throughout the next couple of centuries, the House of Lords underwent structural changes in size. In 1603, James I allowed for the “creation of new peerages after the long period of restraint under Elizabeth.”[7] Charles would abolish the chamber during the seventeenth century. However, the chamber would be reestablished as, in 1657, there was a “re-creation of a bicameral parliament.”[8] While the history of the House of Lords is tumultuous, by the nineteenth century, the House of Lords had “reached a very recognizable form” and “Parliament’s policy-making role was well established.”[9] The role of the House of Lords, as established by the UK constitution in the present day, is to spend half of its time considering bills, as all bills must be passed through both the House of Commons and the House of Lords to become law.[10] The Lords utilise their “extensive individual experience” to provide insights on policies in select committees, where a significant portion of their work takes place.[11] The UK parliament describes how the House of Lords has been “making a difference in recent years” and highlights the chamber’s importance in driving policy change.[12]
However, the House of Lords has been described by critics and scholars as being “deeply controversial” as the Lords are “an almost all-appointed upper chamber.”[13] Reform groups have called the House of Lords a “cosy club for the privileged few” and that the chamber is “outdated and unrepresentative.”[14] There are currently ninety-one lords who sit in the House and inherited their seats from family members.[15] This system is institutionally outdated in comparison to other modern democracies, as the “UK remains one of just two countries in the world with a hereditary element in its legislature.”[16] The democratic legitimacy of the House of Lords has been questioned by parliament itself as attempts at reform have been laid out over the years, such as introducing a “fairer and more sustainable appointments system” in 2023.[17] These appointments are important because Lords are allowed to sit and work in the chamber for life. Today, the House remains unelected, which raises questions about the democratic nature of the House of Lords.[18]
The House of Lords is not unnecessary to the law-making process, but strong reforms are needed to improve the chamber. The House of Lords plays a role in “passing and scrutinising legislation” from the House of Commons, which provides a check on the Commons’ power.[19] The House of Lords “reviews and amends proposed legislation,” which allows lords to question ministers and have productive debates about a piece of legislation.[20] This ensures that ministers in the Commons are not able to pass any legislation without proper scrutiny. The House of Commons would become more powerful without the House of Lords, as there would be no extra check on its policy agenda. The House of Lords also provides a range of specialists who look over legislation, as lords have had “successful careers in business, culture, sports, academia, law, health, public service or politics.”[21] It would be difficult to completely abolish the House of Lords due to the checks it provides, which is why reforms are necessary to allow lords to check power without the chamber being an unelected, hereditary, and life peer-dominated body of government. The chamber does play a role “in checking and challenging the decisions and actions of the government through questions and debates.”[22] The UK government recognizes the issues with the House of Lords and has passed reforms to mitigate the chamber’s undemocratic and outdated nature. The government understands the concerns about the chamber, but cannot abolish the House of Lords because of its role in checking the House of Commons. The current legal framework of the House of Lords is dictated by the Life Peerages Act of 1958 and the House of Lords Act 1999.
This article argues that the existing legal structure of the Life Peerages Act of 1958 and the House of Lords Act 1999 does not create the democratic legitimacy that is present in other modern parliamentary democracies. While the House of Lords does provide a constitutional role in revising legislation, the existing legal framework allows for an executive power overstep through appointments and a hereditary peer system that undermines the democratic legitimacy of the UK. This article proposes reforms to the current legal landscape by creating new legislation that combats democratic legitimacy issues by removing hereditary peers and restricting executive appointments to allow for modern democratic ideals to be instilled in a necessary institution of Parliament.
This article will proceed in three parts. Part I will discuss the current legal framework for the House of Lords established by these acts and amendments. The second part will analyze how the House of Lords lacks democratic legitimacy due to the current UK Parliament’s legal framework. The third part will discuss attempted reform and propose new legislation to democratically reform the House of Lords.
II. CURRENT LEGAL FRAMEWORK
The Life Peerages Act of 1958 is the foundation for the current legal framework of the House of Lords. This act proposed the “introduction of life peers in 1958” and persisted “until the removal of (most) hereditary peers in 1999.”[23] However, the implications of this act are still prevalent today since the House of Lords still includes life peers. The House of Lords Act 1999 included the “removal of the hereditary peers from the second chamber.”[24] However, there was an exception for “92 hereditary Peers to sit in the House of Lords by virtue of an inherited (hereditary) peerage.”[25] The UK government is distinctive as it is “one of only three nations that does not have a codified constitution.”[26] This means that there is not one single document that outlines the country’s laws, but rather “there is a body of laws (statutes and common law), conventions and practices that have developed over time” that set a precedent.[27] These statutes are criticized because they set the precedent for the House of Lords to be “an almost all-appointed upper chamber.”[28] Acts would be introduced to build on the Life Peerages Act of 1958, with the Reform Act of 2014. This act allowed members of the House of Lords to retire permanently, and members who did not attend or were convicted of serious crimes should cease to be members.[29] This reform strengthened the democratic legitimacy of the House of Lords by ensuring that those convicted of crimes were not allowed to sit as members. It also ensured a way to decrease the overall number of lords and allowed new people in by setting up a system of permanent retirement.
Another step towards accountability within the House of Lords came in 2015 with the Expulsion and Suspension Act, which gave the House of Lords power to expel or suspend members.[30] This act addressed concerns around accountability, as a legal framework was needed to remove members permanently or temporarily based on their actions or extenuating circumstances. This act showed that there is accountability within the House of Lords in terms of having a legal framework for suspending or expelling members. It did not get to addressing the issue of hereditary peers or the appointment system that undermines democratic accountability within the second chamber. While this was a step towards partial modernization, the reform did not address the more serious issues of lifetime membership and the appointment system.
III. DEMOCRATIC LEGITIMACY ISSUES IN THE CURRENT LEGAL FRAMEWORK
The institutional design of the House of Lords creates questions surrounding the democratic legitimacy of its legal framework. The Liberal-Democratic-Conservative coalition government, in 2012, pushed “a bill proposing an 80 percent elected chamber.”[31] The government claimed that “‘the fundamental democratic principle’” is that “‘those who make the laws of the land should be elected by those to whom those laws apply.’”[32] Although this bill was withdrawn due to significant opposition, the statements made by this government reveal how both the public and the Commons believe that the House of Lords lacks democratic legitimacy. While all politicians can use their position to gain unequal power, “equal autonomy” is especially “undermined when unelected civil servants use their position to gain superior political influence.”[33]
The lifetime appointment system is also flawed, as members of parliament have called for a reform to include an “appointing body to justify new appointments”, as part of a “commitment to greater diversity.”[34] This proposal stems from the stark lack of diversity within the House of Lords, which is largely attributed to the life peer system. The House of Lords is sixty-nine percent male, with the median age of those males being seventy-two.[35] The chamber is male-dominated, with very little age diversity because of the life peer system in place. Studies show that “descriptive representation can crucially support the principles of democracy”, as the people in power represent their society in terms of diversity.[36] While no parliament is fully representative of its constituents, the House of Lords falls short of representing the UK in terms of gender and age.
The appointment process also leaves behind a prime minister’s views long after they have been voted out because prime ministers can “appoint as many peers to the second chamber as they wish during their tenure.”[37] Former Prime Minister Liz Truss appointed thirty-two life peers during her tenure. This means that “for every one and a half days that Liz Truss was in power, she created a peer.”[38] These appointed lords will be in the chamber, dictating UK policy, for as long as they wish. For such a brief stint as Prime Minister, Liz Truss has left a lasting impression on UK policy through the House of Lords. This questions the democratic legitimacy of the UK government, as executives who have been voted out of office still affect policy change through their appointments.
The “UK remains one of just two countries in the world” with this hereditary system in place, as this system is not standard in other democratic countries.[39] In early forms of British government, the House of Lords was a “playground for the King’s friends” as Lords would “inherit hereditary power together” as the King’s peers.[40] This system was established during the fourteenth century, when the “two distinct houses of parliament began to emerge.”[41]
The number of lords within the chamber also raises concerns over outdated practices. The House of Lords currently has 859 members, making it “by far the largest second chamber in the world.”[42] Betty Boothroyd, former Congress speaker, stated that “the chamber’s ‘inflated size fosters [its] laughing-stock image.’”[43] This, along with prime ministerial appointments, “drag the Lords, parliament, and politics more generally into disrepute.”[44] The large number of lords by prime ministerial appointment is outdated, and reform has “been decades (even centuries) in the making.”[45] The public supports this shrinking movement, as when asked “whether the prime minister should have unlimited appointment powers, or be restricted to appointing no more members than those who leave”, only four percent agreed with the current situation, while “79% wanted change.”[46] With the largest second chamber in the world and one of only two countries with a hereditary peerage, the House of Lords has become largely outdated. The chamber needs reform to be on par with other democratic countries with a bicameral parliamentary system.
IV. REFORM AND LEGISLATION PROPOSAL
Reform to the House of Lords would need to include a reduction in the number of peers, removal of hereditary peers, and an amendment to the appointment system. The first reform that needs to be passed is one that was already proposed in 1999 with the House of Lords Act, which ended the right “of all but 92 hereditary Peers to sit in the House of Lords by virtue of an inherited (hereditary) peerage.”[47] The next step would be to enact the “House of Lords (Hereditary Peers) Bill 2024-25”, which is legislation from the Labour government that “would remove all remaining hereditary peers from the House of Lords and abolish the House of Lords’ jurisdiction in relation to claims to hereditary peerages.”[48] This reform would completely abolish the outdated hereditary peer system in the House of Lords, modernizing the chamber. Legislation passed to remove all hereditary peers is feasible, as seen by the “House of Lords (Hereditary Peers) Bill 2024-25.”[49] This new legal framework would allow for more democratic legitimacy by ensuring that a position of government can not be passed down without some form of merit. This matters because it means that lords have to be somewhat qualified to make political decisions instead of getting the position passed down through a family connection.
The next reform to modernize the House of Lords would be to reduce the number of Lords in the chamber. While the hereditary peers bill would reduce the number in the House of Lords, the chamber should be capped. In 2017, the “Lord Speaker’s Committee on the Size of the House (the ‘Burns committee’)” proposed that “the size of the chamber should be limited to no larger than the House of Commons.”[50] This committee also proposed that “the Prime Minister should initially be restricted in making appointments to ‘two-out-one-in’ to bring the chamber down to that size, and then to ‘one-out-one-in’, to keep it there.”[51] This would be a way to modernize the House of Lords by reducing the number of peers and maintaining a capped size. By reducing the number of peers, democratic accountability is increased as members are more easily recognizable to the public, and it does not allow for responsibility to diffuse since the number would be more concentrated. This would also alleviate the democratic concern of the prime minister appointing a large number of lords while in office, as if the prime minister were allowed to appoint a large number of lords, their ideology would last far longer than their term through the lord they appoint. If this is allowed to occur, it is anti-democratic as the will of voters is not being performed since an ideology that was voted out is continued through appointments in the second chamber.
The last reform on the legislative structure would be to push for the House of Lords to change its appointment system and install term limits. This would increase democratic legitimacy and keep lords from spending decades in the chamber. It would also lower the median age, allowing for more diversity. One argument for proposed legislation would be for the House of Lords to become a fully elected body. However, there are arguments against this reform, as lords being unelected can be seen as a positive aspect, as it would “free them from the constraints that infringe upon representatives seeking re-election.”[52] This means that lords would not be pressured by an election to make a certain policy decision. There are also a lot of issues that entail installing an election system in the House of Lords. Legislation has to be specific about how exactly an election would work for the House of Lords. The first problem the government in power would run into is deciding which voting system to adopt.[53] There would have to be a vote on what election system to use, as the “simple plurality (first past the post)” system used for the House of Commons would “merely create a second chamber elected on a very similar basis as the House of Commons.”[54] This would take away the expert role of the House of Lords and only create a second House of Commons. However, if a different election system is used, such as proportional representation, then questions would be raised about “why should the upper house be elected by an arguably fairer or more representative electoral system” be used if the House of Commons is not elected this way.[55] The next issue would be the timing of the election cycle. If the House of Lords and House of Commons elections are on the same cycle, then this increases the “likelihood of duplicating the result of a general election,” meaning that the House of Lords and House of Commons are represented by the same party.[56] If elections were held on a different cycle, then there is the possibility that “a different party (from the government) might prove more popular and thus win more seats.”[57] This would make it harder for parliament to pass legislation if there is gridlock. The third issue that elections would have is that “the vast reservoir of expertise which the second chamber currently enshrines” would ultimately be lost because “candidates for election (whatever the method) would almost inevitably be adopted or selected for party political reasons.”[58] A possible solution to this issue, according to Peter Dorey, a Professor of British Politics, would be for the House of Lords Appointments Commission (HOLAC) to be strengthened.[59] This committee recommends the Lords to the Parliament, and Dorey believes that HOLAC should become “solely responsible for selecting 80 per cent of members of the second chamber.”[60] The other twenty percent accounts for problems “in terms of party leaders and the Prime Ministers submitting nominations.”[61] This system ensures that there are fewer political appointments and that election issues are not present. Those appointed by HOLAC would be “in accordance with clear and transparent criteria, instead of being party political appointees or products of prime ministerial patronage.”[62] However, an act could be proposed that goes a step further by having members in HOLAC not being appointed by the Prime Minister at all. An independent cross-party parliamentary committee could fully appoint the members of the second chamber. There would be no prime ministerial discretion in who gets appointed to the House of Lords. This cross-party parliamentary committee would comprise members from all political parties in the House of Commons and would collectively determine who is appointed to the second chamber. This would allow people across the political spectrum to have a say in who gets appointed, without it being directly the choice of the Prime Minister and the political party they represent. It would also allow for HOLAC to be more representative of parliament and not the ideology of the Prime Minister at the time. This committee would include members from the House of Commons and allow for all political parties to be represented without one having full power of choosing who is appointed. This reform act could completely take away the Prime Minister’s ability to appoint people to the House of Lords while also keeping parliamentary sovereignty with a new cross-party committee. The vast reservoir of expertise is considered the House of Lords’ greatest asset, and the cross-party committee and reforms that would strengthen HOLAC would allow for a middle-ground solution to be found where this reform preserves merit while removing political patronage. This would create a solution for the appointment system without creating further issues with elections and diminishing the role of the House of Lords.
Overall, this article proposes that legislation be drafted for the House of Lords to include an appointment system, reduction of members, and hereditary peer reform, ensuring more democratic legitimacy in the UK government. This legislation would include the removal of the hereditary peer system completely from the House of Lords. This means that there would be no position to inherit from an existing member. These reforms would also cap the House of Lords at the same number of members as the House of Commons. It would enforce the “‘two-out-one-in’” policy for prime ministerial appointments to reduce the number of peers until this number is at the capped amount.[63] After the number is capped, the legislation would then create a system that uses the HOLAC appointment framework proposed by Peter Dorey. It would also allow for a cross-party parliamentary committee to be established within HOLAC to ensure that appointments are representative of all political parties within parliament and there is no prime ministerial influence. There would also be specific term limits enforced in this law. This legislation would create more democratic legitimacy within the House of Lords and for the UK government as a whole by increasing diversity and establishing a fairer appointment system.
Edited by Tyler Taplett, Elizabeth Elliott, & David Doyle
Footnotes
[1] Solomon Lartey, The Role of the UK House of Lords and Commons in the Legislative Process and Its Impact on Governance, RESEARCHGATE (2024), https://www.researchgate.net/publication/384446897_The_Role_of_the_UK_House_of_Lords_and_Commons_in_the_Legislative_Process_and_Its_Impact_on_Governance
[2] Id.
[3] Id.
[4] Id.
[5] Meg Russell, A Brief History of the House of Lords, in THE CONTEMPORARY HOUSE OF LORDS: WESTMINSTER BICAMERALISM REVISED 14 (Oxford University Press 2013), https://doi.org/10.1093/acprof:oso/9780199671564.003.0002
[6] Id. at 16.
[7] Id. at 18.
[8] Id.
[9] Id. at 21.
[10] What Does the House of Lords do?, UK PARLIAMENT, https://www.parliament.uk/business/lords/work-of-the-house-of-lords/what-the-lords-does/. (last visited Apr. 4, 2026).
[11] Id.
[12] Id.
[13] Sonail Campion, Sean Kippon. HOW UNDEMOCRATIC IS THE HOUSE OF LORDS?, in THE UK’S CHANGING DEMOCRACY: THE 2018 DEMOCRATIC AUDIT, LONDON: LSE PRESS, PP. 182-192 (Patrick Dunleavy & Alice Park, Ros Taylor 2022), https://doi.org/10.31389/book1.m.
[14] Electing a Modern Second Chamber, ELECTORAL REFORM SOCIETY, https://electoral-reform.org.uk/campaigns/elected-house-of-lords/, (last visited April 4, 2026)
[15] Hereditary Peers, UK PARLIAMENT, https://www.parliament.uk/site-information/glossary/hereditary-peers/ (last visited April 4, 2026).
[16] Cabinet Office, et al., Removal of hereditary peers from Parliament moves a step closer with Second Reading in the House of Commons, GOV.UK, (Oct. 15, 2024), https://www.gov.uk/government/news/removal-of-hereditary-peers-from-parliament-moves-a-step-closer-with-second-reading-in-the-house-of-commons#:~:text=This%20Bill%20is%20the%20first,of%20the%20House%20of%20Lords.
[17] UK Parliament, Lord Speaker’s committee on size of the house publish fifth report, UK PARLIAMENT (July 17, 2023), https://committees.parliament.uk/committee/369/lord-speakers-committee-on-the-size-of-the-house/news/196464/lord-speakers-committee-on-size-of-the-house-publish-fifth-report.
[18] Campion & Kippin, supra note 13, at 184.
[19] Alice Lilly, Emanuela Marku and Joshua Jakupi, House of Lords, INSTITUTE FOR GOVERNMENT (October 17, 2023), https://www.instituteforgovernment.org.uk/explainer/house-of-lords.
[20] Id.
[21] Id.
[22] Checking and Challenging Government, UK PARLIAMENT, https://www.parliament.uk/business/lords/work-of-the-house-of-lords/checking-and-challenging-government/. (last visited Apr. 4, 2026).
[23] Pete Dorey, Change in Order to Conserve: Explaining the Decision to Introduce the 1958 Life Peerages Act, 28 Parliamentary Hist. 246 (2009), https://doi.org/10.1111/j.1750-0206.2009.00109.x
[24] Alexandra Kelso, Stages and Muddles: The House of Lords Act 1999, 30 PARLIAMENTARY HISTORY: 101-113 (2011), https://doi.org/10.1111/j.1750-0206.2010.00238.x.
[25] Key Dates, UK PARLIAMENT, https://www.parliament.uk/about/living-heritage/evolutionofparliament/houseoflords/parliamentacts/keydates/. (last visited Apr. 4, 2026).
[26] Phillip Norton, BRITAIN’S UNCODIFIED CONSTITUTION, in Governing Britain: Parliament, Ministers and Our Ambiguous Constitution (Manchester Univ. Press 2020), https://doi.org/10.7765/9781526150240.00005
[27] Id.
[28] Campion & Kippin, supra note 13.
[29] House of Lords Reform Act 2014, UK PARLIAMENT: HOUSE OF COMMONS LIBRARY (Jul. 1, 2016), https://commonslibrary.parliament.uk/research-briefings/SN06832/
[30] House of Lords (Expulsion and Suspension) Act 2015, UK PARLIAMENT (2015), https://bills.parliament.uk/bills/1382
[31] Adam Lovett, Should the House of Lords Be More Democratic?, LSE: DEPARTMENT OF PHILOSOPHY, NEWS (November 10, 2023), https://www.lse.ac.uk/philosophy/news/should-the-house-of-lords-be-more-democratic.
[32] Id.
[33] Tine Hindkjaer Madsen, The Moral Roles of Democratically Elected Politicians and Civil Servants, TAYLOR & FRANCIS ONLINE (Aug. 19, 2024), https://www.tandfonline.com/doi/epdf/10.1080/13698230.2024.2380220?needAccess=true.
[34] House of Lords urged to axe 200 peers and boost diversity, THE GUARDIAN (Nov. 18, 2018), https://www.theguardian.com/politics/2018/nov/19/house-of-lords-urg
[35] House of Lords data dashboard: Current membership of the House, UK PARLIAMENT: HOUSE OF LORDS LIBRARY (Jan. 14, 2026), https://lordslibrary.parliament.uk/house-of-lords-data-dashboard-membership-of-the-house/
[36] Sveinung Arnesen & Yvette Peters, The Legitimacy of Representation: How Descriptive, Formal, and Responsiveness Representation Affect The Acceptability of Political Decisions, 51 Comp. Pol. Stud. 868 (2017).
[37] Rose Whiffen, The Current Status Quo of the House of Lords Leaves Too Many Corruption Risks Unchecked, TRANSPARENCY INTERNATIONAL UK (Apr. 3, 2024), https://www.transparency.org.uk/news/current-status-quo-house-lords-leaves-too-many-corruption-risks-unchecked.
[38] Id.
[39] Cabinet Office, et al., supra note 16.
[40] Lilian Trickey, Time to Embrace Democracy: The Case for Removing Hereditary Peers from the House of Lords or a Potential Risk to Democratic Balance?, U. OXFORD FACULTY OF LAW (Sep. 19, 2024, at 11:00:07 AM), https://www.jurist.org/commentary/2024/09/time-to-embrace-democracy-the-case-for-removing-hereditary-peers-from-the-house-of-lords-or-a-potential-risk-to-democratic-balance/.
[41] Id.
[42] UCL Constitution Unit, Public Wants House of Lords Reform to Go Further: to Limit Appointments and Size of Chamber, UCL Soc. & Hist. Scis. (June 2025), https://www.ucl.ac.uk/social-historical-sciences/news/2025/jun/public-wants-house-lords-reform-go-further-limit-appointments-and-size-chamber (last visited Apr. 15, 2026).
[43] Id.
[44] Id.
[45] Id.
[46] Id.
[47] UK Parliament, supra note 25.
[48] House of Lords (Hereditary Peers) Bill 2024-25: Progress of the bill, UK PARLIAMENT (Dec. 19, 2025), https://commonslibrary.parliament.uk/research-briefings/cbp-10219/.
[49] Id.
[50] UCL Constitution Unit, supra note 42.
[51] Id.
[52] Conor Farrigton, Unelected Upper Chambers can Play a Legitimate Democratic Role in Wider Political Systems, LSE BLOGS (Aug. 20, 2015), https://blogs.lse.ac.uk/politicsandpolicy/unelected-upper-chambers-can-play-a-legitimate-democratic-role-in-wider-political-systems/.
[53] Peter Dorey, Elected or Selected? The Continuing Constitutional Conundrum of House of Lords Reform, 94 POL. Q. 402-411 (2023), https://doi.org/10.1111/1467-923X.13298
[54] Id.
[55] Id.
[56] Id.
[57] Id.
[58] Id. at 406.
[59] Id. at 410.
[60] Id.
[61] Id.
[62] Id. at 411.[63] UCL Constitution Unit, supra note 42.