The first decision to consider the meaning and extent of HRA 1998, s 2(1) was R (Alconbury Developments Ltd) v Secretary of State for the Environment, [2001] UKHL 23, where the House of Lords held that, while the case law of the ECtHR is not binding, domestic courts should follow any clear and consistent jurisprudence unless there were special circumstances, or the decisions of the ECtHR compelled a conclusion fundamentally at odds with the distribution of powers under the UK constitution.