Assignment 1

1227 Words3 Pages

1. Issues
The main issue in the scenario is the conflict between the two Acts of Parliament: Education Act 2013 (EA 2013) and the Education Reform Act 2016 (ERA 2013). ERA 2016 is passed reducing the school leaving age to 16 from 18 under EA 2013 and without consulting the Ofsted as required by EA 2013. Madonna aged sixteen wishes to leave school now relying on the ERA 2016. The question therefore is whether EA 2013 or ERA 2016 would apply and why.

2. Introduction
The question raises number of issues regarding Parliamentary sovereignty and related issues of entrenchment and express and implied repeal. The principle of parliamentary sovereignty in the UK, originates historically from the troublesome relationship between the English Parliament and the Crown. The Bill of Rights 1689 created the foundation for the Parliamentary sovereignty where Crown agreed with the Parliament to limit its power. One of the key definitions of Parliamentary sovereignty was given by AV Dicey who defines it as “the Parliament has the right to make or unmake any law whatever; and that no person or body is recognised by the law of England as having a right to override or set aside the legislation of Parliament. Dicey’s theory has both positive element and negative element. Positive in that it states that Parliament can pass any laws on any subject as it sees fit and it can make and unmake laws and it is not bound by the previous Parliament nor can it bind the future Parliament. The negative element of Dicey’s theory is that no one can question the validity of Act of Parliament even the courts.

3. Jurisdiction
The Parliament is supreme and it can pass any laws it likes. However, in the given scenario Parliament has passed ERA 2016 without co...

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...sequent Parliament will be bound by the manner and form. In Attorney-General for New South Wales v Trethowan it was held that since the Colonial Laws Validity Act 1865 specifdied certain manner and form the later Parliament was bound by this. Similarly in Harris v Minister of the Interior court held that the South African Parliament had been created and given its powers by the 1909 Act and later Acts which tried make changes without following the correct procedure was invalid. The modern attitude of courts is changing as could be seen in R. (on the application of Jackson) v Attorney-General concerning the Hunting Act 2004, where Lord Hope of Craighead said Parliamentary sovereignty is no longer, if it ever was, absolute, instead its qualified.” Its enforcement by the courts is the ultimate controlling factor on which our constitution is based.”

Conclusion

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