Arguments have been raised to the effect that the Acts of Union between England and Scotland and Ireland were intended to represent a higher form of law and so should be seen as substantively entrenched. The theory behind the argument is that the Acts of Union were not created by the UK Parliament but by the original English, Scottish and Irish Parliaments. Hence, the Acts created a new (UK) Parliament that was not sovereign, but limited by its founding constitutional documents. In the words of Professor J Mitchell, the new Parliament was 'born unfree'.