What now stands between a populist authoritarian government with a huge majority and a full scale assault on civil liberties and human rights?

 18th March 2021

Earlier this week the house of commons passed the government’s illiberal Police, Crime, Sentencing, and Courts Bill with a ninety-six majority.

So given this high majority the obvious question is what would actually stop or hinder a populist and authoritarian government from seeking to pass primary legislation that would remove or undermine basic legal protections and rights? 

This is not a trivial or academic question.

The usual ‘gatekeepers’ that would prevent a government from not even proposing such things are no longer in place.

For example, the offices of lord chancellor and attorney-general are occupied by politicians who happen to be lawyers but have no credentials in protecting either the rule of law or fundamental freedoms.

And we have a government heady with ‘will of the people’ rhetoric that has developed a taste for attacking or disregarding what checks and balances the constitution of the United Kingdom has to offer.


In constitutional theory, the next check – once legislation is proposed – is the house of commons.

But with such a large majority – and the tendency for even supposedly ‘libertarian’ government backbenchers to vote in accordance with the whip and accept limp front-bench assurances – there is no realistic way that the house of commons is any check or balance on this government.

And if the opposition do oppose – which cannot be assumed, given the official opposition’s habit of not opposing things for tactical and strategic reasons – then such opposition can and will be weaponised by hyper-partisan ministers and their media supporters.


Next there is the house of lords, where (fortunately) the government does not have an in-built majority.

And the house of lords can vote things down and pass amendments.


When constitutional push comes to political shove, the house of lords will usually backdown once the house of commons has reaffirmed its support for a measure.

This is in part that the the house of lords has a, well, constitutional disability in respect of confronting the democratic house.

There will only be a few occasions where the house of lords will use its power to delay legislation under the parliament acts.

And that power is that: to delay.

A determined government, with the support of the house of commons, will get its legislative way in the end.

A government in these circumstances would not even need to resort to an ‘enabling act’ – as it would get through any desired illiberal legislation anyway.

There are a very few exceptions to this: such as a bill containing any provision to extend the maximum duration of a parliament beyond five years.

But otherwise: there is nothing that can ultimately stop an illiberal bill eventually becoming an act of parliament.


And then we come to the courts.

Here we have another problem.

Because of the doctrine of parliamentary supremacy there is nothing that the courts would be able to do – as long as the government has ensured that the statutory drafting is precise and tight.

The human rights act, for example, provides no legal basis for an act of parliament to be disapplied.

The judgments of the European court of human rights are not binding.

The European communities act, which did enable a court to disapply an act of parliament on certain grounds, is no longer part of domestic law.

‘Common law rights’ capable of frustrating an act of parliament exist only in undergraduate law student essays.

Even with the powers the courts do have, the government is seeking to limit access to judicial review by all possible means: in substantive law, by procedural restrictions, and by denying legal aid.

(And the courts have taken an illiberal turn anyway: and we now have a president of the supreme court, in an unanimous judgment, telling the court of appeal off for not according ‘respect’ to a home secretary’s assessments.)


Before the general election of December 2019 we had the unpleasant predicament of a government that was populist and authoritarian – but at least it did not have a parliamentary majority.

Now, by reason of that general election and its result, we have a government with the same illiberal instincts but with all the sheer legal force of parliamentary supremacy at their disposal.

That the opposition parties facilitated an early general election in December 2019 was a moment of political madness.

And now – until at least December 2024 – we have a government that is able with ease to get the house of commons to pass the most illiberal legislation – and there is ultimately nothing that either the house of lords or the courts can do – as long as the legislation is precise and tight.

Brace, brace.


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59 thoughts on “What now stands between a populist authoritarian government with a huge majority and a full scale assault on civil liberties and human rights?”

  1. Of course once this bill gets royal assent, it will be possible to bring a private prosecution against Boris for causing “serious annoyance” without “reasonable excuse” for very the act of bringing this bill before parliament!

    1. No. Because that would be allowing retrospective effect, which is not allowed by any regime which wants its laws to be obeyed.

  2. …and there is not a single thing anyone can do about it. I guess we could take to the streets and protest….oh, wait…

    1. “…and there is not a single thing anyone can do about it. I guess we could take to the streets and protest….oh, wait…”

      Protests around the world against oppressive regimes invariably involve breaking the law as the regimes pass laws to try to stop them. Historically and culturally breaking the law is un-British, but presumably that will have to change….

  3. Let’s now start calling it The Enabling Act. I suspect though that the reference will be lost on many of the younger Tory MPs. Even though they apparently won the war single handed.

  4. Does Steyn LJ’s dictum in Jackson really give the judiciary an opportunity to push back against an executive looking to rebalance the constitution in a truly authoritarian way? Or is it just an academic curiosity?

      1. One of the ripple effects of apartheid is that for decades the UK benefitted from the presence and influence of exiles, among them Lord Steyn and Lord Hoffmann, who really understood what an authoritarian government looked and felt like.

        The doctrine of Parliamentary sovereignty means just that – Parliament can do what it likes, until the next general election. In the end, a government with a majority in the House of Commons can override almost anything – the House of Lords, the courts, the Queen.

        The ultimate check on its power is the people, either on the streets or at the ballot box. So, will people wait patiently for 2024, or might things get ugly? Brace, indeed.

  5. When – over twenty years ago – Berlusconi was voted in by a vast majority of the electorate, in spite of his monstruous conflict of interests and opening the doors to a ghastly period of populism – which is far from dying out – a number of English friends quite rightly commented that Italians had only themselves to blame.

    In the light of the news from Britain, I cannot but reply – without a trace of Schadenfreude – in the same manner.

    1. I am of the same mind. Here in Italy I am in a spiting fury about what I can see happening in Britain but when I speak to relatives and friends – all politically well informed and by no means of a populist bent – I hear only a disinterested reconcilement to the situation. All voted Remain and most are of the Tory – lite persuasion. I think the idea that ‘dark forces’ can take over their lives to them is a bit of a scare story as they have such a long built in trust of traditional British politics being on their side that they cannot recognise the insidious turn of the tide.

  6. ”The European communities act, which did enable a court to disapply an act of parliament on certain grounds, is no longer part of domestic law.” (David Allen Green)

    Some of us as far back as 2014 on the day the referendum result was known declared that the MAJOR reason for leaving the EU was to avoid the jurisdiction of the ECJ and to avoid other legally binding commitments under the Treaty of Rome and subsequent EU treaties, in order to destroy civil liberties and a host of rights currently enjoyed by each and everyone of us, (and the equally important concomitant obligations on others that derive from those rights) and this was deemed ”worth it” by the likes of the ERG even given the negative economic impact that leaving the EU, CU and SEM/EEA would have on the UK economy.

    It was Ground Zero for this new breed of right wing market enthusiasts, the job was to finish what Thatcher had started. Nothing that has happened or been said or done in the last 4 years has caused me to doubt that my original analysis was correct.

    I am sure someone much cleverer than I am will explain how and why I am wrong.

  7. If, as seems likely the odious provisions of the Act are passed, there is only one recourse open to the public; embrace it and demonstrate (!) that it is unworkable.

    Everyone should make a complaint to the police, for example, if their neighbour buys their children a dog. Nuisance? Annoying? You bet it is – barking and yapping. They ‘ought to have known’ it would seriously annoy me. My town’s football team play 200 metres from my house – can I seek an order that the crowd can’t cheer a goal. It’s stops me from enjoying my movie on Netflix on Saturday afternoon and they knew there was a risk of upsetting me. The only upside is that, with all due respect to those from north of the border, I can finally take legal action if someone marches along the street playing the bagpipes as I detest the sound – SO noisy and annoying!

    Those complaints would no longer be frivolous, allowing the police to ignore them. They would (if proven) be serious offences with jail time and must be investigated. My neighbour who bought the dog could play along and make a complaint to the police that my making a complaint seriously annoyed him and that I ought to have known there was a risk of doing so by filing the complaint with the police.

    1. @Alan Damper The provisions still only apply to ‘protests’, allowing conditions to be imposed by police on protests which risk causing serious annoyance etc. So they haven’t *yet* gone quite as far as you suggest, albeit it probably is a realistic possibility at this point.

        1. @Alan Damper However, the statutory offence of public nuisance will require serious annoyance (etc) to be caused to a *section of the public*, not just to one individual. That is consistent with the position at common law, as discussed in cases such as R v Rimmington and Goldstein [2005] UKHL 63.

          1. Subsection (2) states

            For the purposes of subsection (1) an act or ommission causes serious harm to a person if, as a result, the person –

            (c) suffers serious distress, serious annoyance………

            It refers to ‘a person’ not ‘a section of the public’. Notwithstanding the case cited the victim in this legislation is ‘a person’. Just how small in number is ‘a section’?

          2. @Alan Damper Subsection (2) defines “serious harm” for the purposes of subsection (1)(b)(i): “causes serious harm to the public or a section of the public”. That means harm to the (local) community as a whole, rather than there being individual victims who are especially affected.

  8. The House of Lords does indeed have such a constitutional disability, but is this not largely just a self-imposed one?

    Could they not, for instance, unilaterally amend the Salisbury convention so that it only protects the manifestos of parties that win a majority share of the vote, not just of seats in Parliament? A protection for the majority against a disproportionately powerful minority of voters. Of course, the Salisbury convention began in the context of the Attlee government which I don’t think had a majority vote share, but was hardly attempting to extinguish its opposition in a comparable manner.

    The only downside I can think of is that the Tories might then simply saturate the Lords with new peerages until they are guaranteed a majority in both Houses (if there is indeed no legal impediment to doing so). But such unsubtle power grabbing and cronyism would look bad and could cost them some political capital, although probably not nearly as much as it ought to.

    My personal view on the House of Lords is that it should continue to exist until we have proportional representation in the House of Commons, which would then take over its role of constraining disproportionate majorities by almost always producing hung parliaments in the first place.

    1. They have already displayed an abundance of cronyism, and so far, appear to have been given a free pass by the general public. It’s hard to tell though, because what is being reported in the media, might not be what the person in the street thinks, but this is hard to gauge because the Covid regulations deter us from meeting up, and having those conversations.

  9. I am extremely sympathetic to AD’s proposal. Can we have some learned comment on the practicalities and the likelihood of success please!

  10. “Before the general election of December 2019 we had the unpleasant predicament of a government that was populist and authoritarian – but at least it did not have a parliamentary majority.

    Now, by reason of that general election and its result, we have a government with the same illiberal instincts but with all the sheer legal force of parliamentary supremacy at their disposal.”

    This is the heart of the problem: not what the government does, or wants to do, but what the electorate (in its “wisdom”) allows it to do. And there we come to the problem of democracy: the worst system of government, apart from all the others, but is that acceptable? And the answer has to be “Yes” because the alternative, however you dress it up, is giving a minority, whether that minority is fascist, revolutionary-communist or even pro-European, rights over the majority.

    One of the Founding Fathers famously said words to the effect: “Well, you have your republic, if you can keep it!” If the forces operating against good government overcome the ‘natural’ inclinations of most people to do broadly the right thing then I’m not sure what the solution, this side of Heaven, is.

    1. To continue to work for any length of time, a democracy has to do at least two things – to elect governments that implement policies that attract broad support from a majority of the people, and to protect minorities from oppression by the majority. The core of that is a rule of law which respects the majority view, and respects the rights of minorities.

      In 2019, the Conservatives won 52.6% of the seats on the back of 43.6% of the popular vote – just shy of 14 million out of 32 million votes cast, in a country with 47 million voters and a population of over 64 million. Our first-past-the-post, winner-takes-all system is very different to the US, where there are elections every two years, and many effective mechanisms of check and balance – not least, a fully independent judiciary, and the states.

      In the UK, MPs representing that 43.5% minority (which is just 30% of the voters, and 22% of the people) can do what they like for five years. Given the polls, they might very well be re-elected. God help us all.

  11. I think it is even worse than stated.

    One remaining check would be that of eventual electoral defeat. This government has been one of the most corrupt and incompetent in recent history. Just today they have been accused of causing over twenty thousand deaths due to inaction. They have blatantly handed jobs and money to friends. There can be very few people in the country who have not been affected by their actions.

    Yet, they continue to do well in the polls. If an election were called now, it is unlikely that they would lose.

    So long as they keep thumping the tub of populism and are backed by a compliant press there seems to be nothing they can do to risk their popularity.

    The only hope is that eventually, infighting will take over and tarnish the party. Even this has taken longer than usual this time.

  12. Did Johnson’s Pa buy him a degree in the classics? They both know that Western civilisation has been here before. And it does not end well.

  13. Absent express words of HRA repeal, will the courts be able to interpret the vaguer or otherwise relevant provisions of the likely forthcoming Police, Crime, Sentencing, and Courts Act on the basis that they were meant to put the old public nuisance common law on a statutory footing rather than widen liability?

    I’d have thought it would help hugely were a Section to be inserted to this effect, reminding the reader. Otherwise one can see the literal words being relied on by law enforcement officials prior to a several-year journey through the courts for clarification.

    1. I don’t think any court could take the view that the Government ‘meant’ simply to put Common Law on a statutory footing. The legislation adds to the original in clear terms and is intended to have effect. No ‘reminder’ will be added because it would be an antidote to the intended poison.

      1. I do sympathise with your wondering at the drafting intent, but I think it’s likelier an accidental oversight, or artefact of textual parsimoniousness, than malignity.

        Courts can and do interpret uncertain codificatory provisions in light of the common law which preceded it, even without being, as here, commanded to reach for Convention-compliant interpretations by the unrepealed s 3(1) HRA 1998 (assuming, as I think is fair, that your and my objections track those of Strasbourg). Where such objections are also Convention violations, then, to the extent an Act can’t be so ‘read down’, note that an s 4 declaration of incompatibility would be the next step.

  14. From Ireland, I watch developments in in the UK with sympathy and concern for the people.

    I think you are suffering from the compound effect of two serious defects in your system of governance.

    The first past the post system leads, as we have seen, to governments getting a large majority without winning a majority of the votes. This permits the type of extremism and unaccountability that we now see in the current government. In a voting system based upon proportional representation, while admittedly single-party governments would be rarer, no government could carry on as this Conservative government does without any accountability, there is always the need to preserve a wide appeal to the electorate.

    The second point, and I think it’s one the British people don’t want to hear, is that the current situation and the feared future authoritarian measures would be guarded against if you had a written constitution. This is not a full protection but it certainly makes matters much more difficult for those who would seek to strip away different rights.

    I’m sorry to say I see no no easy way to rectify these matters, I can only hope that in some way the British people can muddle through.

    1. My sentiments entirely.
      Ireland would be an excellent model for the UK.
      Even if the constitution were not written we need at least a Constitutional Court to interpret the existing ‘covention’ based constitution, because conventions have proved to be no barrier to charlatans,

    2. FPTP does indeed do as you say, but the remedy is not just any proportional representation system as they vary greatly from party list systems that are even worse to the STV with multi-seat constituency system that Ireland uses which is indeed far superior to FPTP.

      And a written constitution is no guarantee of anything as it depends entirely on what it says and the culture of enforcement that grows around it. For example, a constitution which says “Boris Johnson is dictator for life” is quite obviously not an improvement!

  15. Random thoughts:-

    1. Scots law appears to protect the rights of citizens better than English law does (eg over the proroguing of parliament). Maybe appeals to Scots courts could challenge / delay Westminster actions?

    2. Brexit. If the economic fall-out from Brexit is as rapid and all-embracing as I personally expect it to be, then the government’s “popularity”, media advantages and resources MAY fall equally quickly. There could well be civil unrest but I think the police and- to a lesser extent – the army would be very reluctant to attack an angry populace in support of a very fragile and unpopular government.

    That said, the main opposition party to the fragile and unpopular government has to seem credible as an alternative source of public leadership and government. It has also got to be publicly committed to removing anti civil liberties legislation. I have my doubts whether Starmer’s Labour fits the bill.

    3. Mussolini (whose job choices and techniques for building personal power seem remarkably similar to those of Johnson) turned democratic Italy into a dictatorship within 3 years. Mussolini did so through a combination of legal, constitutional measures / politicking and by illegal actions (including violence).

    What eventually rescued Italy from Mussolini was external force – the Allied invasion. Internal opposition to him was simply not strong enough to make any real difference.

    4. I have long felt very frightened about Johnson’s “entitled”, narcissistic political behaviour, mainly because I believe there are no lows to which he wouldn’t stoop. I also believe him to be fundamentally stupid and lazy.

    Someone who’s intelligent and aware of other people – even as potential threats – seems less dangerous than Johnson to me. Self-interest and an awareness of potential unwanted consequences might encourage more cautious political choices even amongst amoral beings.

    1. Your point 2, 2nd para. The Labour Party has yet properly to eliminate the anti-Jewish-anti-Israeli racism from its ranks before many of us would consider rejoining or voting for it. As has been discussed here before, Corbyn and his ism are largely responsible for the voting in of the obscene power of this government.

      1. Disagree with your views – which is no reason why you should agree with mine!

        The Forde Inquiry report seems the BEST option we have for determining what actually went on within Labour and who the real culprits are / were.

        The only other option is to wait for a proper analysis in 25 years time by historians … and by that time, I’ll have lost all interest in whatever conclusions they reach.

  16. Reading your excellent commentaries Mr Green, I usually find myself more negative even than you, but perhaps not on this occasion. Time to look up from the trenches. Although the Prime Minister has a huge majority in the House of Commons, and is attempting to build the same in the House of Lords, he had and has nowhere near a majority of the popular vote. At the last election the Conservatives won 43.6% of the vote, but because of our corrupt voting system, obtained 56.2% of the seats. The Prime Minister swaggers around as if he is master of all he surveys. He is not. It is well, well past time to stop the tyranny of this rancid, bigoted minority, and time for the realignment of the centre-left to happen. The second reason for hope is to see what appears to be happening in the US, where the Republicans appear to be burying themselves into their own hate-filled hole, ably led by their version of the Narcissist-in-Chief who fortunately is no longer Commander-in-Chief. Even for ordinary Republicans Trump’s behaviour after the election has been beyond the pale. And this morning I saw blazoned out on the tabloids Patel’s policy of dumping asylum seekers on islands, as to maintain the culture war our government pushes ever further into authoritarianism. The Prime Minister is digging his own disgusting, rancid hole. Scrabbling out of it will be painful, but scrabble out we will.

  17. Before I read this depressing tale I enjoyed the long read in the Guardian “the Clown king: how Boris Johnson made it by playing the fool”. I recommend it only as an antidote to this post. We will have to get our pleasures from wherever we can find them.

  18. I’ve had something pop up in my in box that I suggest could cause a lot of disquiet locally and serves to show us how the conservatives operate. My local council council (Bucks CC) has announced a change to planning rules. There is quite a lot to get through but basically all planning disputes are to go to the County Council, objecting is to be made much harder (you need a ‘tame’ councillor to call in your objection). There are some other changes, such as where the local regulations say the council ‘will’ do something, such as publicise planning applications they will be changed to say that the council ‘may’. As you can imagine the potential for developers to push through inappropriate developments aided and abetted by tame local councillors is huge.
    This information was dropped by the council on Tuesday night with replies closing by tomorrow (19th of March) so it’s a fairly typical approach. They genuinely don’t care about what they do and assume the area will always vote for them. I received the news via my local neighbourhood watch which received it from The Beaconsfield Society, who are somewhat annoyed. If anything will get the people of Beaconsfield out it will be over development on green belt land. With the people of Bucks already protesting about HS2 this could be the straw that breaks the camels back. When I think that the local conservative association replaced Dominic Grieve with Joy Morrisey I can’t helping thinking ‘well, serves you right’.

    1. It seems the Conservatives (ex ?) are not confining themselves to central government control. We recently had a school street closure imposed without the normal consultation (seemingly) by using an experimental traffic order. This is something introduced through covid legislation which itself was introduced using a statutory instrument.

      Then there is Priti Patel’s proposal that all local elections should now be FPTP.

  19. Your blog posts are fascinating, if also highly depressing!

    One minor correction: the latest date for the next general election is currently May 2024, not Dec 2024. See section 1(3) of the Fixed-term Parliaments Act 2011 (and note that section 1(2) of the Early Parliamentary General Election Act 2019 effectively confirms that).

    However, this assumes that the FTPA is not replaced before then, which could allow the date to slip…

  20. Here’s the relevant part of the FtPA that provides for when GEs take place: https://www.legislation.gov.uk/ukpga/2011/14/section/1/enacted
    Also, Johnson could bring forward ‘notwithstanding’ legislation to get around the FtPA and get an election via a simple majority, at any point before May 2024. Thus it is not correct to say we are stuck with this Government “until at least December 2024”.

    1. As you indicate (and as we have seen) there are already proven mechanisms that can bring the date of a general election forward. Further, section 1 of the Fixed-term Parliaments Act 2011 allows the Prime Minister to make an order to postpone a May 2024 election for up to two months.

      On further postponement, I may be misunderstanding the issue, but I suspect David is making a slightly more subtle point, which is that the Parliament Act 1911 (as it currently stands) could not be employed to get around the House of Lords blocking any such “notwithstanding” legislation, if that legislation attempted to postpone the date of the next election past 12 December 2024. The House of Lords would have to approve it.

      So the current government could use its majority in the Commons to pass legislation (without the consent of the Lords) pushing back the date of the election to 12 December 2024, but not later.

      That said, while the Prime Minster controls nominations to the House of Lords, resistance in the House of Lords is vulnerable to the threat that got the Parliament Act 1911 through in the first place. Would the Queen ennoble as many persons as the Prime Minister picked, to pack the Lords?

      1. David said in response to a earlier comment that he did not make the assumption that the FtPA would not be ‘replaced’. So, given that PMs usually do not let the full 5 year term run in its entirety (in case ‘events’ suddenly make them take a dive in popularity) I expect that the next GE will take place in either the spring or autumn of 2024. It will only take place in December 2024 if the Conservatives are consistently well behind in the polls.

        On a separate point, David says “That the opposition parties facilitated an early general election in December 2019 was a moment of political madness.” This is not quite right. Once the Liberal Democrats had joined with the SNP in publicly calling for an election, the writing was on the wall. The Conservatives now had the numbers to get an election via a simple majority, using the method I previously mentioned. Thus, Labour had no other choice but to support the election that was now going to take place, with or without their backing.

        If we look at at why the SNP supported an early election, they calculated that any Conservative majority would boost their aspirations of persuading enough Scots to back independence. So more cold calculated strategy rather than ‘madness’. For the Liberal Democrats though, the decision to support an election when they did not need to do so, was indeed, especially in hindsight; madness.

  21. Politicians lie – that’s normal. But I feel we have a deeper problem, we have jumped from the frying pan into the fire. some of us are going to get badly burnt.

    Sections of our society have been getting poorer for decades – slowly, like boiling frogs. Much the same was happening inside the EU but it was a large closed shop so able to hold off the effects of globalisation for a while. We were persuaded to leave the EU and be free to make our own way. But, there does not seem any real way this new found freedom will help, merely make the descent a bit quicker. Perhaps that was the idea.

    This is out of politician’s hands, bigger forces at work. Even if Boris were booted out and Starmer got in I can’t see he has many options or acceptable ways out of this mess. One way out would be to build and spend and ride roughshod over the planning rules and make social support a much rougher game. Truly make the UK ‘China-on-Thames’.

    Not the sunny green uplands some hoped for but desperate times require desperate measures. As preparation governments of any stripe will need to strongarm the populace. I am sure the DM & DT etc will be fully supportive….

  22. But
    the government must call an election before the end of 2024. Should the present authoritarian and populist government be re-elected then it is the will of the people. We may not like it but..
    Do you believe the next government will repeal these illiberal rules?

    1. According to the current laws an election must be called. Let us hope those laws remain free of amendments.

  23. I note with interest the reference to Mussolini above. I have referred friends to the tactics employed by this dictator and the disturbing similarities they have to our current government’s manoeuvres.

    The $64,000 question is when will it be determined appropriate to offer the ultimate illiberal policy of capital punishment as the (enhanced?) nuclear option in the perpetual culture war? Red meat for the beast.

    Is it better to deliver this policy with the current parliamentary majority and bask in electoral thanks or use the death sentence as a hostage during the next general election?

    The anti-woke manifesto will be so easy to write. A clear choice for true citizens to make, like a referendum.

    How would this impact on the UK’s position in the world?

  24. Disagree with your views – which is no reason why you should agree with mine!

    The Forde Inquiry report seems the BEST option we have for determining what actually went on within Labour and who the real culprits are / were.

    The only other option is to wait for a proper analysis in 25 years time by historians … and by that time, I’ll have lost all interest in whatever conclusions they reach.

  25. I agree. It is terrifying, but the country seems to be blind to the danger. The presumption that all MPs and ministers are “gentlemen” who can be trusted to act honourably is clearly not the case and lies are not being challenged in the House by the Speaker.
    We urgently need protection.

  26. Essentially, it would appear that if this current government wished to pass a UK equivalent of the Nuremberg Laws there is nothing that could stop it.

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