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Paragraph Focus
para 1 = judicial review
para 2 = basis for rights
para 3 =
para 1 = judicial review
US
mahmoud vs taylor 2025
judicial review is strong due to separation of powers
UK
illegal migration act
judicial review is weak due to parliamentary sovereignty
comparative theory
structural theory
para 2 = basis for rights
US
district of columbia vs heller - based on 2nd amendment
constitutional basis for rights
UK
for women scotland vs scottish ministers 2025 - based on equality act 2010
legislative basis for rights
comparative theory
structural theory = how strongly rights are entrenched
US = entrenched under article V
UK = sits in statue alone
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