the House of Commons could not "do indirectly by two stages what the House [could not] do directly in one stage" by using the Parliament Acts to remove the express limitation and then enact legislation extending the life of Parliament, a restriction that was considered necessary to ensure the effectiveness of the express limitation. Lord Bingham was the only judge to explicitly reject the validity of this implied limitation, arguing that there were no reasons for preventing the alteration of the clause limiting the subject matter of full Acts of Parliament and that "it cannot have been contemplated that if, however improbably, the Houses found themselves in irreconcilable deadlock on this point, the government should have to resort to the creation of peers". Outcome The House of Lords found that the Parliament Act 1911 did not have any limitations that would prevent it being used to enact the Parliament Act 1949. The 1949 Act had therefore validly amended the requirements for a bill to use the Parliament Acts procedure and the Hunting Act, which was passed in accordance with these amended requirements, was consequently also held to be valid; the appellants' appeal was dismissed. Significance Cosmo Graham argues that Jackson could be seen as "a constitutional curio, dealing with an obscure point, which is now effectively settled in favour of the Executive"; the case, from this perspective, is of no practical consequences given the limited use of the Parliament Acts and plans to further reduce the power of the House of Lords to delay bills. However, he suggests that Jackson is part of a trend of increased willingness by the judiciary to examine the claimed existence of executive powers and "to push at the borders of traditional techniques of judicial interpretation". Limits to parliamentary sovereignty Common law constitutionalism, a view that there are fundamental constitutional values that are protected even from interference by Parliament, had become increasingly popular at the time of Jackson. Four recent cases had found that "in the absence of express language or necessary implication to the contrary, the courts [will] presume that even the most general words were intended to be subject to the basic rights of the individual". There had also been extrajudicial comments by serving judges that parliamentary sovereignty may not be absolute: Lord Woolf had written that "if Parliament did the unthinkable, then I would say that courts would also be required to