The HRA 1998 directly challenged the role of the Law Lords and their constitutional position. The Act incorporates into English law the European Convention on Human Rights. Article 6 of this stipulates that “everyone is entitled to a fair and public hearing within a reasonable time by an independent and impartial tribunal established by law.”[iii] As Gomien has pointed out, the “principle underlying the independence and impartiality clause of Article 6(1) is the separation of powers, but neither the Convention itself nor the Convention organs dictate the means by which this requirement should be met.”[iv] Indeed, in the case of McGonnell v United Kingdom (1998), the European Commission on Human Rights decided that there was a breach of the requirement of Article 6 when a Court hearing in Guernsey was presided over by the Bailiff of Guernsey. The Law Lords would thus appear to be in violation of this Article, as they are an integral part of the legislature as well as the judiciary, and there is, therefore, no effective separation of powers guaranteeing the fair trial prescribed herein. As Flinders points out, the incorporation of this into English law “created a sense of urgency” in the need for reform of the Law Lords’ constitutional position.The manifestation of this urgent need to reform the constitutional position was the inception of the Constitutional Reform Bill. This, which became the Constitutional Reform Act 2006, advocates the physical removal of the Law Lords from Parliament and the establishment of a physically and constitutionally separate Supreme Court in which the Law Lords can sit. The members of the Supreme Court will be appointed by a new independent Judicial Appointments Committee, which further enhances the judiciary’s independence and separation from the other branches of the state. One can see, then, how the HRA 1998 has fundamentally affected the constitutional position of the Law Lords.