1. A Lexis-Nexis search suggests that the phrase was used in only 11 reported cases prior to 1998, whereas more than 50 references are revealed post-1998.
2. R(A and others) v East Sussex County Council [2003] EWHC 167 (Admin) at [86], per Munby J.
3. Harris, Clones, Genes, and Immorality (Oxford University Press, 1998), p. 31.
4. In this regard see Pretty v United Kingdom (2002) 35 EHRR 1.