This text is a revised and annotated version of a lecture delivered by Francesca Klug at a conference on the Bill of Rights for the United Kingdom held at University College, London, on 4 July 1997, sponsored by Bindman and Partners. She compares the approaches of different States (notably Canada and New Zealand) to the conundrum of limiting the power of the executive without preventing a democratically elected Government from carrying out key popular reforms in areas where there is no settled human rights answer. She assesses what we can learn from other Bills of Rights when considering what form the British model should take, and argues for wide consultation and debate on any model involving signifi cant constitutional change before it is enforced.