On 20 November 2013, Jonathan Philip Chadwick Sumption, a Justice of the Supreme Court of the United Kingdom since 2012, delivered the 27th Sultan Azlan Shah Lecture in Kuala Lumpur. Entitled "The Limits of Law", it explored the role that judicial review should play in a democratic system, expressing concern that particularly insofar as questions of fundamental rights are concerned, the English courts' expanding resort to judicial review was increasingly impinging upon political terrain that is more properly the purview of parliament. His argument along these lines derived primarily from two claims. The first is that judicial modes of investigation, which generally limit their focus to the concerns of the parties before the court, are inappropriate in the context of the much more polycentric nature of questions of fundamental rights