Case Law — FLK1 · Chapitre 1

English Legal System

1. Case law and the doctrine of precedent

London Street Tramways Co Ltd v London County Council [1898] AC 375

The House of Lords held that it was absolutely bound by its own previous decisions, with certainty of the law treated as outweighing the risk of occasional injustice. This rigid rule stood until the Practice Statement [1966] 3 All ER 77, by which the Lords (now the Supreme Court) reserved the power to depart from their own earlier decisions when it appears right to do so.

Key point
Exam relevance: It is the foundational authority on vertical and horizontal stare decisis in the highest court, regularly tested alongside the 1966 Practice Statement.

2. Different types of case law: precedent in the Court of Appeal

Young v Bristol Aeroplane Co Ltd [1944] KB 718

The Court of Appeal is generally bound by its own previous decisions, subject to three exceptions: where two of its own decisions conflict (it chooses which to follow); where its decision cannot stand with a later House of Lords/Supreme Court decision; and where the earlier decision was made per incuriam.

Key point
Exam relevance: It states the precise rule and exceptions governing when the Court of Appeal may depart from its own precedent, a frequent MCQ point.

3. How case law is made: judicial development of the common law

R v R [1992] 1 AC 599

The House of Lords abolished the marital rape exemption, holding that a husband can be convicted of raping his wife and that the supposed irrevocable consent on marriage is a common-law fiction with no place in modern law.

Key point
Exam relevance: It is the classic example of the senior courts developing and updating the common law through precedent rather than awaiting legislation.

4. Acts of Parliament and parliamentary sovereignty

British Railways Board v Pickin [1974] AC 765

Under the enrolled bill rule, the courts have no power to examine parliamentary proceedings or to question the validity of an Act that has passed both Houses and received Royal Assent, even where fraud on Parliament is alleged; the court's duty is simply to apply the Act.

Key point
Exam relevance: It is the leading authority that courts cannot invalidate or look behind a duly enacted Act of Parliament, a core sovereignty principle.

5. Bills and primary legislation: the Parliament Acts

Jackson v Attorney General [2005] UKHL 56

The House of Lords upheld the validity of the Parliament Act 1949 (and thus the Hunting Act 2004 enacted under it), holding that legislation passed using the Parliament Acts 1911 and 1949 procedure without the Lords' consent is primary legislation, not delegated legislation.

Key point
Exam relevance: It confirms how primary legislation can be enacted without the House of Lords and the legal status of Acts passed under the Parliament Acts procedure.

6. The court's power in relation to statute law: implied repeal

Ellen Street Estates Ltd v Minister of Health [1934] 1 KB 590

Parliament cannot bind its successors as to the form or content of future legislation; where a later Act is inconsistent with an earlier one, the earlier is impliedly repealed to the extent of the inconsistency.

Key point
Exam relevance: It establishes the doctrine of implied repeal and the continuing-sovereignty principle that no Parliament can entrench legislation against later Parliaments.

7. Origins and commencement of Acts of Parliament

R v Secretary of State for the Home Department, ex parte Fire Brigades Union [1995] 2 AC 513

A minister may not use prerogative power in a way that frustrates the will of Parliament; where an Act confers a statutory scheme to be commenced by the minister, he must keep commencement under genuine review and cannot introduce an inconsistent prerogative scheme that defeats the un-commenced statute.

Key point
Exam relevance: It illustrates the relationship between statute and the executive, and the limits on prerogative power where it conflicts with primary legislation.

8. The court's power in relation to statute law and the rule of law

R (Evans) v Attorney General [2015] UKSC 21

The Supreme Court quashed the Attorney General's veto certificate, holding that, absent the clearest statutory words, the executive cannot override a final, reasoned decision of a court, as this would breach two basic rule-of-law principles: that court decisions bind the parties and that executive action is reviewable by the courts.

Key point
Exam relevance: It shows how courts construe statutory powers narrowly to protect fundamental constitutional principles and the rule of law.

9. Acts of Parliament: separation of powers and prorogation

R (Miller) v The Prime Minister; Cherry v Advocate General for Scotland [2019] UKSC 41

The prerogative power to prorogue Parliament is justiciable and limited; advice to prorogue is unlawful (and the prorogation void) if it frustrates or prevents, without reasonable justification, Parliament's ability to perform its constitutional functions as legislature and supervisor of the executive.

Key point
Exam relevance: It is the leading modern authority on the separation of powers and the courts' role in protecting Parliament's legislative function.

10. The court's power in relation to statute law: role of the judiciary

Duport Steels Ltd v Sirs [1980] 1 WLR 142

Per Lord Diplock, the UK constitution is based on the separation of powers: Parliament makes law and the judiciary interprets it. Where statutory words are clear, judges must give effect to them and cannot, under the guise of interpretation, rewrite the statute to reach a result they prefer; any defect is for Parliament to remedy.

Key point
Exam relevance: It is the key statement of the constitutional limit on judicial interpretation and the distinction between interpreting and amending statute.

11. Secondary legislation and access to justice

R (UNISON) v Lord Chancellor [2017] UKSC 51

The Employment Tribunal Fees Order 2013 was quashed as ultra vires because it unlawfully interfered with the constitutional common-law right of access to the courts; delegated legislation is unlawful if it effectively prevents access to justice without clear authorising words in the parent Act.

Key point
Exam relevance: It shows how the courts strike down secondary legislation that exceeds its enabling power or infringes fundamental rights, central to the secondary-legislation chapter.

12. Principles of statutory interpretation: the mischief rule

Heydon's Case (1584) 3 Co Rep 7a

Establishes the mischief rule: in construing a statute the court considers the common law before the Act, the mischief or defect for which the common law did not provide, the remedy Parliament resolved on, and the true reason for that remedy, then interprets the Act so as to suppress the mischief and advance the remedy.

Key point
Exam relevance: It is the origin of the mischief rule, the historical foundation of today's purposive approach to interpretation.

13. Principles of statutory interpretation: the literal rule

Fisher v Bell [1961] 1 QB 394

Applying the literal rule and the established contract-law meaning of 'offer for sale', a flick knife displayed in a shop window with a price was only an invitation to treat, not an offer for sale, so no offence was committed under the Restriction of Offensive Weapons Act 1959 as then worded.

Key point
Exam relevance: It is the textbook illustration of the literal rule producing a strict result that prompted Parliament to amend the statute.

14. Principles of statutory interpretation: the golden rule

R v Allen (1872) LR 1 CCR 367

Applying the golden rule to avoid an absurd result, 'shall marry' in the bigamy offence under s 57 of the Offences against the Person Act 1861 was read as 'shall go through a ceremony of marriage', so a second ceremony during a subsisting marriage is bigamy even though that second marriage is legally void.

Key point
Exam relevance: It is the leading example of the golden rule applied to prevent a literal reading from rendering an offence impossible to commit.
Adler v George [1964] 2 QB 7

To avoid the absurdity of an offence covering obstruction near, but not inside, a prohibited place, 'in the vicinity of a prohibited place' in s 3 of the Official Secrets Act 1920 was read as 'in or in the vicinity of', so obstruction within the prohibited place was an offence.

Key point
Exam relevance: It is a clear, frequently cited application of the golden rule to extend statutory words just enough to avoid an absurd gap.

15. Principles of statutory interpretation: use of Hansard

Pepper v Hart [1993] AC 593

The exclusionary rule was relaxed so that courts may refer to Hansard as an aid to construction where the legislation is ambiguous, obscure or leads to absurdity, the material consists of one or more statements by a minister or promoter of the Bill, and those statements are clear.

Key point
Exam relevance: It defines the limited circumstances in which parliamentary debates may be used to interpret statute, supporting the purposive approach.

16. Rules of language: ejusdem generis

Powell v Kempton Park Racecourse Co [1899] AC 143

Under the ejusdem generis rule, where general words follow a list of specific items they are limited to the same class as those items; since 'house, office, room' in the Betting Act 1853 were all indoor places, 'or other place' did not extend to an outdoor betting enclosure.

Key point
Exam relevance: It is the standard authority for the ejusdem generis rule of language in statutory interpretation.