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 length represented nearly a doubling in just a decade. During the period of the introduction of the "hostile environment" policy under Prime Minister Theresa May, more than 1,300 changes were made to the Rules in 2012 alone. Former Lord Justice of Appeal Stephen Irwin referred to the complexity of the system as "something of a disgrace", and an effort to gradually overhaul the Rules into a more understandable system began to take place. The England and Wales Law Commission began to make recommendations for clearer rules to be adopted. Managed migration "Managed migration" is the term for all legal labour and student migration from outside of the European Union and this accounts for a substantial percentage of overall immigration figures for the UK. Many of the immigrants who arrive under these schemes bring skills which are in short supply in the UK. This area of immigration is managed by UK Visas and Immigration, a department within the Home Office. Applications are made at UK embassies or consulates or directly to UK Visas and Immigration, depending upon the type of visa or permit required. In April 2006, changes to the managed migration system were proposed that would create one points-based immigration system for the UK in place of all other schemes. Tier 1 in the new system – which replaced the Highly Skilled Migrant Programme – gives points for age, education, earning, previous UK experience but not for work experience. The points-based system was phased in over the course of 2008, replacing previous managed migration schemes such as the work permit system and the Highly Skilled Migrant Programme. A points-based system is composed of five tiers was first described by the UK Border Agency as follows: Tier 1 – for highly skilled individuals, who can contribute to growth and productivity; Tier 2 – for skilled workers with a job offer, to fill gaps in the United Kingdom workforce; Tier 3