Not that I'm claiming the US model is inferior in some way, of course. Constitutional questions are complex and heavily dependent on a country's history and culture. One apparent weakness of the US system is that enormous power is placed in the hands of a group of unelected officials, appointed and approved by the current executive and legislature, who then wield that power for life. I could make that point by pointing out that the law on one of the most contentious issues, abortion, has been determined for decades by the partisan composition of the supreme court rather than by public opinion. I could say something like "the US constitution is there to prevent the hoi polloi having a say" but it wouldn't make any point worth making or lead to a reasoned discussion. The issue is rather more nuanced than that.
> [F3 (5A) In a householder case, the degree of force used by D is not to be regarded as having been reasonable in the circumstances as D believed them to be if it was grossly disproportionate in those circumstances.]
> (6) [F4 In a case other than a householder case,] the degree of force used by D is not to be regarded as having been reasonable in the circumstances as D believed them to be if it was disproportionate in those circumstances.
does not “give householders carte blanche in the degree of force they use against intruders in self-defence” (ref: https://www.bbc.co.uk/news/uk-43652308) – in essence, making the legal situation basically the same as before this amendment was made. (Apparently the lawmakers didn't quite understand how a “self-defence” legal defence worked in court, when they were writing this one up.) As I understand, as of the ruling, there's no legal distinction between “disproportionate force” and “grossly disproportionate force”.
Sure, the High Court didn't overturn it… except for the part where they basically did. They also “quashed with prospective effect” an amendment to primary legislation (the Copyright Designs and Patents Act 1988) made by a statutory instrument (The Copyright and Rights in Performances (Personal Copies for Private Use) Regulations 2014). There are many other instances of primary legislation on the books that manifestly say one thing, but that according to the High Court mean something different.
[1] https://ukconstitutionallaw.org/2021/10/18/michael-foran-par...