Chapter 2 considered the responses to the striking down of legisla­tion in India and declarations of incompatibility in the UK sepa­rately.

This chapter will link the two, in order to determine whether it is genuinely more difficult for the Indian Parliament to respond to judicial review decisions than the Westminster Parliament.

The last chapter drew a distinction between two kinds of space available in responding to declarations of incompatibility—decisional space and remedial space. This chapter will invoke the two concepts of space in the context of both India and the UK. Thereafter, the chapter will examine parliamentary debates in both jurisdictions to consider the role that MPs believe they are playing when addressing declara­tions of incompatibility and judgments striking down legislation in the UK and India respectively. Finally, the chapter will consider the swiftness of responses to these remedies in both jurisdictions. Even if it is equally easy (or difficult) for legislatures in both jurisdictions to offer their rights-based reasoning in response to that of the courts, is this process undertaken faster under the HRA, as proponents of the new model claim?