Jackson prompted debate about the legitimacy of limiting parliamentary sovereignty and the theoretical justifications for the ruling. Alison Young suggests that the opinions could be explained by the Parliament Act 1911 modifying the rule of recognition defining valid legal documents or by the Act redefining Parliament in a manner that binds the courts.:194 195 Christopher Forsyth argues 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).:139 141 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.:572 cheap iphone cases,578 579 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.:102 103In 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.
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