that the Parliament Acts redefined Parliament to be a bicameral body for all legislation which also has a method of unicamerally legislating (except to extend Parliament beyond five years). Jeffrey Jowell proposes that there are two reasons for limiting parliamentary sovereignty – if the democratic legitimacy of the legislature were undermined by its acts or if the body attempted to remove fundamental rights in a democratic society – and cites support for these arguments from the judgment. The case was also criticised for claims made by Lord Steyn and Lord Hope that the doctrine of parliamentary sovereignty was solely a judicial creation. Facts In the United Kingdom, bills are normally presented to the monarch for Royal Assent after they have been passed by both the House of Commons and the House of Lords, at which point they become primary legislation as Acts of Parliament. However, bills can also be passed using the Parliament Acts. The Parliament Act 1911 allowed bills to be presented for Royal Assent without the assent of the House of Lords if they had been passed by the House of Commons in three successive parliamentary sessions and there had been a delay of two years. The Parliament Act 1949, passed using the Parliament Act procedure, amended the 1911 Act to reduce the power of delay to two successive sessions and a period of one year. The legislation defines two exceptions in section 2(1) of the Parliament Act 1911: Money Bills can only be delayed for one month and "Bill[s] containing any provision to extend the maximum duration of Parliament beyond five years" are not eligible to use the procedure. The Hunting Bill was introduced as part of Labour’s 2001 general election manifesto pledge to hold a free vote on banning fox hunting and would make it illegal to hunt wild animals in England and Wales with dogs except in limited circumstances. The bill was passed by the House of Commons on 3 December 2002 but rejected by the House of Lords. It was reintroduced to, and passed by, the House of Commons on 9 September 2004, but was significantly amended by the House of Lords. The House of Commons rejected the amendments on 18 November and the bill was granted Royal Assent later that day through the use of the Parliament Acts. The Hunting Act was due to come into force on 18 February 2005. Judgment Divisional