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Comparison
The obvious question the argument raises is what the alternative looks like. Here is how three other democracies handle it.
Canada has an entrenched Charter of Rights, but also Section 33, the notwithstanding clause, which lets Parliament or a province override certain Charter rights for five years at a time. It is a middle path: rights protected by courts, but with the elected side keeping the last word. It is the model behind the idea of a British override discussed on the plan.
Denmark remains a member of the European Convention yet runs one of Europe's strictest migration policies. Its example is used by both sides: by those who say you do not need to leave the Convention to control borders, and by those who say Denmark constantly strains against it.
Australia is often cited for offshore processing, but analysts argue the measure that actually stopped the boats was turnbacks at sea under Operation Sovereign Borders. The lesson others draw is about enforcement at the border rather than deterrence alone.
Withdrawing from the ECHR is close to unprecedented among democracies. Greece left under its military junta in 1969 and returned, and Russia was expelled in 2022. That is the company the step keeps, which is why it is treated as major. The debate is on should the UK leave the ECHR.
Section 33 of Canada's Charter lets legislatures override certain rights for renewable five-year periods, keeping the elected branch's final say while retaining a rights charter.
Denmark is the example most cited by those who say yes, running a strict policy while remaining a member, though critics say it constantly strains against the Convention.
Only Greece, under its junta in 1969, and Russia, expelled in 2022. No established democracy has left and stayed out.
