falls within the scope of courts of law carrying out their regular function". All nine judges accepted that the court had jurisdiction to consider whether the 1949 Act was valid. Mullen suggests that the failure of the Attorney General to challenge either standing or justiciability in the case could have wider implications by lowering the barriers to litigation and also by providing a precedent that people acting in their personal capacities can challenge the validity of primary legislation. Status of legislation passed using the Parliament Act 1911 The appellants' primary argument was that legislation passed using the Parliament Act 1911 is delegated and therefore could not be used to amend the procedure of enactment. However, their Lordships disagreed with this claim on the basis of the clear language in the Act. Lord Bingham found that the phrase "become an Act of Parliament on the Royal Assent being signified" denoted primary legislation. "The meaning of the expression 'Act of Parliament' is not doubtful, ambiguous or obscure ... It is used, and used only, to denote primary legislation ... The 1911 Act did, of course, effect an important constitutional change, but the change lay not in authorising a new form of sub-primary parliamentary legislation but in creating a new way of enacting primary legislation." Lord Nicholls agreed that the 1911 Act provided "a second, parallel route" of making Acts of Parliament and that "it would be inconsistent with [the parliamentary] intention to interpret [the legislation] as subject to an inherent, overarching limitation comparable to that applicable to delegated legislation." Lord Steyn, Lord Hope and Lord Brown concurred in similar terms. Limits of the Parliament Act 1911 The House of Lords rejected the Court of Appeal's finding that there was a distinction between non-fundamental constitutional changes, which could be passed using the Parliament Act 1911, and fundamental constitutional changes, which could not; Lord Bingham argued that "the ... solution finds no support in the language of the Act, in principle or in the historical record". Of the nine judges, only Lord Carswell suggested that there may be implied limits to the use of the Parliament Acts, but acknowledged the difficulty of defining the extent of these restrictions. However, seven of the judges endorsed the express limitation that a statute extending the life of Parliament beyond five years could not be passed using the Parliament Acts; a further five agreed with Lord Nicholls that