from this perspective a redefinition of Parliament that binds the courts. However, she notes that Lord Hope, Lord Nicholls and Lord Carswell provide an alternative explanation for the decision: that the 1911 Act modified the rule of recognition defining valid legal documents. Under this view, the 1911 Parliament did not bind future Parliaments simply by passing the Parliament Act 1911, but by the legislation being recognised, in political fact, as valid; the courts were therefore altering the legal rule of recognition accordingly. This perspective allows the orthodox continuing view of parliamentary sovereignty (that every new parliament is sovereign) to be held while still explaining why future parliaments cannot modify section 2(1) of the 1911 Act. Christopher Forsyth suggests that the limitations of the 1911 Act could be explained by the common law constitutionalism theory, but argues that "if the judiciary frustrated by the failings of the elected legislature were to assert a power to hold Acts of Parliament invalid it would be stepping from law into politics and the outcome of its efforts impossible to predict". He instead proposes that section 2(1) of the 1911 Act was a redefinition of Parliament: it is a bicameral body for all legislation but also has a method of unicamerally legislating (except to extend Parliament beyond five years) if the requirements of the Parliament Acts have been fulfilled. However, he also notes that a "sufficiently determined elected House, coupled with an executive willing to influence the composition of the House of Lords by the creation of peers ... would in the end get its way. If the government advisors had a sufficiently secure Commons majority, it would in the end be able to extend the life of Parliament." Jeffrey Jowell proposes two justifications for limiting parliamentary sovereignty: legitimacy and the current hypothesis of constitutionalism. The argument from legitimacy highlights that Parliament's supremacy depends on the democratic and accountable nature of legislature; anything that undermines this status would invalidate the applicability of the doctrine. Jowell suggests that this view was expressly supported by Lord Hope and impliedly supported in other opinions that legislation limiting Parliament's accountability would be challenged by the judiciary. The argument based on the current hypothesis of constitutionalism reasons that no authority should be allowed to violate fundamental rights in a democratic society: they are essential features that cannot be removed, even by a supposedly sovereign Parliament. This view was also expressly