bills over which it had no right of veto; and in several instances these were accepted by the Commons. These included the China Indemnity Bill 1925 and the Inshore Fishing Industry Bill 1947. The use of the Lords' now temporary veto remains a powerful check on legislation. It was used in relation to the Government of Ireland Act 1914, which had been under the threat of a Lords veto, now removed. Ulster Protestants had been firmly against the passing of the bill. However, the Government of Ireland Act 1914 never came into force because of the outbreak of the First World War. Amendments to the Parliament Act 1911 were made to prolong the life of the 1910 parliament following the outbreak of the First World War, and also that of the 1935 parliament due to the Second World War. These made special exemptions to the requirement to hold a general election every five years. Legislation passed without the consent of the Lords, under the provisions of the Parliament Act, is still considered primary legislation, ie. a fully valid Act of Parliament. The importance of this was highlighted in Jackson v Attorney General, in which the lawfulness of the Parliament Act 1949 was questioned. The challenge asserted that the 1911 Parliament Act had delegated power from Parliament as a whole to the Commons, and that the 1949 Parliament Act was therefore delegated rather than primary legislation. If this were the case, then the House of Commons could not further increase its own powers through the 1949 Parliament Act without direct permission from the House of Lords. Since it was passed under the 1911 Act, the 1949 Act had never received the required consent of the Lords. However, the Judicial Committee of the House of Lords found that the 1911 Act was not primarily about empowering the Commons, but rather had the purpose of restricting the ability of the Lords to reject legislation, ie. altering the process by which Parliament as a whole enacts legislation. The 1949 Act had therefore been lawfully enacted. This ruling also appears to mean that efforts to abolish the House of Lords (a major constitutional change) by using the Act could be successful, although the issue was not directly addressed in the ruling. Analysis The Parliament Act 1911 can be seen in the context of the British constitution: rather than creating a written constitution, Parliament chose instead