of the right of abode, when it limited right of abode through descent to a CUKC who had a parent who had CUKC status by "birth, adoption, naturalisation or .... registration in the United Kingdom or in any of the islands" or a grandparent CUKC who "at the time of that birth or adoption so had it". Whether "so had it" referred to a grandparent who had CUKC status generally or CUKC status from the UK and islands specifically was decided by the courts to refer to the latter. The right of abode on 31 December 1982 was necessary to become a British citizen on 1 January 1983 under the automatic transition at commencement of CUKC provisions of the British Nationality Act 1981, so failing to meet the interpretation of the right of abode test above resulted in no British citizenship through that route. The British Nationality Act 1981 modified the right of abode section of the Immigration Act 1971 to remove the wording at issue, although the former version still had effect for determinations of British citizenship through right of abode for persons born before 1983, and potentially for their descendants. Immigration Rules Section 1 of the act provides for "rules laid down by the Secretary of State as to the practice to be followed in the administration of this Act". In 1972, the Heath administration introduced the first proposed Immigration Rules under the 1971 act. The rules proposal drew criticism from Conservative Party backbenchers, because it formally implemented a limit of six months of leave to enter as a visitor for white "Old Commonwealth" citizens who were "non-patrial" (did not have Right of Abode under the 1971 act, generally because they did not have a parent or grandparent from the UK). At the same time the proposal opened the door to free movement of certain European workers from European Economic Community member states. Seven backbenchers voted against the proposed Rules and 53 abstained, leading to defeat. Minutes from a Cabinet meeting the next day conclude that "anti-European sentiment" among backbenchers, who instead preferred "Old Commonwealth" migration to the UK, was at the core of the result. The proposal was revised, and the first Rules were passed in January 1973. By August 2018, the Immigration Rules stood at almost 375,000 words, often so precise and detailed that the service of a lawyer are typically required to navigate them. That