Conclusion
This chapter has sought to enhance our understanding of judicial accountability through consideration of certain features that are central to the systems of judicial review in the UK and the EU.
To this end the chapter has examined the conceptual foundation for judicial review, its legitimacy, its place within the hierarchy of norms and the treatment accorded to rights. There are not surprisingly similarities and differences between the respective systems. There are doubtless other features that might have been included within such an analysis, but limits of space place constraints in this respect. It is in any event difficult to think of additional features that would displace those discussed. The most significant additional factor that shapes the respective systems is the way in which they respond to the challenges posed by other legal regimes with which they inter-relate, such as the ECHR and the international legal order. The integration of this complex material with that discussed in the present chapter is a task for another day.
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