Abstract
The doctrine of parliamentary sovereignty appears to rule out any comparison between the Westminster Parliament and the United States Congress or the German Bundestag, whose powers are carefully circumscribed by their respective constitutions. Nevertheless, the nature of the British constitutional order is remarkably similar to that of the written constitution. This is because the doctrine of parliamentary sovereignty, contrary to Dicey's view, does not consist in a single dominant idea but in a number of related and mutually supporting principles. The way in which these principles interact is parallel to the interaction of the main clauses of the United States Constitution or the German Basic Law. In the United Kingdom, as elsewhere, the proper subject matter of constitutional law is the higher law that makes possible the operation of legislative, executive and judicial institutions under a public order of rules.
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