Competitive strategy that Easyjet have utilised

Competitive strategy that Easyjet have utilised The aim of this report is to analyse and evaluate the competitive strategy that Easyjet have utilised in order to develop their current competitive position in the low price no frills airline market. Objectives Definitions of competitive strategy Explain Porters generic strategy Analyse the competitive strategy of Easyjet Evaluate the competitive strategy of Easyjet Recommendation for the future of Easyjet Methodology Porters generic strategy Investigate the strategy clock Find out advantage and disadvantages by creating a SWOT analysis of Easy Jet Theories on Easyjet competitive strategy The Competition Various Recommendation for Easyjets future Where the information was found? University library Internet Journals Newspapers Books Overview From this report, Easyjet can be seen as one of the main airlines in its market, and although it has some tough competition Easyjet is becoming stronger. Its competitive strategies are ahead of the competition and are being very successful. This is proven through various theories such as Porters generic strategy, the strategy clock and a SWOT analysis of Easyjets competitive strategy. Introduction Background Easyjet is one of the best known European low price no-frills airlines. Which begun in 1995 by Greek entrepreneur Stelios Haji-Ioannou. He intended to make flying to Europe affordable for more and more people. Easyjet now calls itself the webs favourite airline. (Thompson, Strategic Management , 2001) The airline is based at Hangar 89, a bright orange building adjacent to the main taxiway at Luton Airport. In an industry where corporate HQs are generally considered to be the ultimate status symbol, it is the very embodiment of the Easyjet low-cost ethos. Objectives To identify and analyse the competitive strategy that Easyjet have utilised in order to develop their current position. To critically evaluate the competitive strategy that Easyjet have utilised in the development of their current completive position. Also make appropriate recommendations regarding Easyjet. Competitive advantage Competitive advantage is the means by which a company can outperform its competitors and more profits. (Lomax Raman, 2006) The ability to create more economic value than competitors (Barney, 2010) Competitive advantage is more generally based on the stability and continuity in relationships between different parts of the organisation (Lynch, 2008) Design is a form of competitive advantageà ¢Ã¢â€š ¬Ã‚ ¦ Good design allows things to operate more efficiently, smoothly, and comfortably for the userà ¢Ã¢â€š ¬Ã‚ ¦ Customers appreciate good design. While they cant necessarily point out what specifically makes it good, they know it feels better. Theres a visceral connection. They are willing to pay for it, if you give them a great experience. (Hackett, 2009) Porters Generic Strategies This set of strategies consists of three: segmentation strategy, differentiation strategy and cost leadership Cost leadership strategy pertains to mass production of standardized products to lower the cost. Manufacturing the product in high volumes or by bulk would lower the costs of the product because fixed costs are maximized. Differentiation strategy means creating products that are being packaged as unique. Customers believe that the features of the products are incomparable and superior compared to others hence the reason for its uniqueness. Segmentation strategy means products are focused on few, selected market or the specialized markets. The company creates the product to suit the tastes or demands of a specific market. (Porter, 1998) Main Findings Analyse Easy Jets competitive strategy Easy jet which is the UKs leading low cost airline, currently operating in over 400 routes with over 175 aircraft in 27 countries is a no frill airline, the concept started in the beginning of the 1970s in the USA and then this concept was followed by Airlines in Europe, and the rest of the world. Easy jet is known as No-frills airlines, where airlines that have offer low fares but eliminate all unnecessary services Easy Jet offers a no frills service at low fares. EasyJets generic strategy is a typical cost leadership strategy. The business philosophy of easyJet is that money can be made on any route where a carrier can fly three times a day to a low-cost airport, based on a minimum market size. The basis of commercial success for such strategy is maintaining a 30-40% cost advantage over established airlines. Easyjets low prices strategy can be defined as A low price strategy seeks to achieve a lower price than competitors whilst trying to maintain a similar perceived product or service benefits to those offered by competitors (Johnson, 2005) They believe to achieve competitive advantage through this strategy, the company need two basic choices, one is to find a segment where main competitors are not interested in. The other one is find this segment attracts price sensible consumers. (Johnson, 2005) They utilize this by doing the following; Easyjet is a Ticket less airline which mean All you need to fly is your passport (or suitable photographic ID on domestic flights) and there confirmation number, based on their time of check in at the airport, this determines the order in which they board the aircraft (Easyjet.com). Efficient use of airport. Easyjet flies to main destination airports throughout Europe, but gains efficiencies through rapid turnaround times, and progressive landing charges agreements with the airports By reducing turnarounds to 30 minutes and below, Easyjet can achieve extra rotations on the high frequency routes, by maximizing utilization rates of its aircraft. Theres no such thing as a free lunch Easyjet does not offer free food from company, passengers are given the choice as to whether they wish to buy themselves drinks or snacks from the in flight. (McCosker, 2003) The absence of business class means gaining seats and maximizes capacity. Though EasyJet does not provide the same kind of flexibility as business class in traditional airlines, it is possible to change flights for a premium of  £10, plus the difference in price. Punctuality is a priority Direct marketing and Internet sales Stelios recognized the potential for sales on the Internet before it had become widely available. At first a call center allowed customers to book over the phone, a more familiar communication channel available to all. By offering discounts for Internet bookings, Stelios shaped his customers purchasing habit with the result that 80% of reservations were made on the Internet in 1998. It reduces distribution charges from travel agent commissions and computer reservation system costs. Easyjets strategy was modelled on Southwest air, but Stelios claimed he had been inspired by Richard Branson and Virgin Atlantic. His approach to customers and people mirrors that of Branson. He flies on his own planes some three or four times a week and week talk to the passengers. He is regularly present at Luton (his headquarters) and willing to revolve passenger problems. (Thompson, Strategic Management fourth editon, 2001) Easyjet favours an informal company culture with a very flat management structure, which eliminates unnecessary and wasteful layers of management. All office-based employees are encouraged to dress casually. Ties are banned except for pilots! Remote working and hot-desking have been characteristics of easyJet since the beginning. One of the strategies which easyJet is persuading is a cost leadership. In persuading cost advantage, the goal of the firm is to become the cost leader in its industry or industry segment (Grant, 2002) The Easyjet product is, in reality, a package of service, many subcontracted in. Easy jet provides the planes and their crews, and markets and the sells the flights. As a company, it is focused. Check-in and information services, snacks (for passengers to by before they board the aeroplane), baggage handling and fleet maintenance are all bought in from specialists. (Thompson, Strategic Management , 2001) Competition for customers in this sector of the market is intense, Virgin express and Fly Thomas cook are just a couple from many have low-price , no frills subsidiaries, neither of which is reputed to be profitable. The largest of the rivals is Ryanair, over 25 years old and based in Dublin, carrying over 75 million passengers a year. When Stelios established the position of the Easyjet as one of leading low cost airline in Europe by adopting an efficiency driven operational model, creating brand awareness and maintaining a high levels of customer satisfaction (where we are now) he took a step further in his perused of the strategy to offer low cost airline to masses (where we want to be) which is based on key strengths (how we going get there) (Easyjet: The Web`s Favourite Airline, 2002) Another of the strategies persuaded by founder of Easyjet can be seen, as strategy is perspective, that is, vision and direction. (Mintzberg, 1994) Evaluate Easyjet competitive strategy Competitive advantage grows out of value a firm is able to create for its buyers the exceeds the firms cost of creating it (porter,1985)A company relative position within an no frill Airline industry is given by its competitive advantage which is cost leadership and differentiation, from other frills airline companies and with its choice of competitive scope. Introducing new technologies new or shifting buyer needs the emergence of a new industry segment and availability changes in government regulations are competitive advantages. Where Differentiation is the firms product, associated services, and other activities affect its buyers activities.   All the activities in the value chain contribute to buyer value, and the cumulative costs in the chain will determine the difference between the buyer value and producer cost. (Porter, 1985) Easy jet gains competitive advantage by performing strategically important activities more cheaply or better than its competitors. (Easyjet.com) Comp etitive advantage can come not just from great products or services, but from anywhere along the value chain. To understand how a firm fits into the overall value system includes the value chains of its suppliers, channels, and buyers. Generic strategies are useful because they characterize strategic positions at the simplest and broadest level. Porter maintains that company achieving competitive advantage requires and makes a choice about the type and scope of its competitive advantage.(Porter, 1985) Concerning competitive advantage, Easyjet concentrates on costs therefore achieves overall cost leadership. It inhabits a low cost Niche position. The low cost airlines developed sufficient lead times and competitive advantage to limit any new entrants to niche positions and we still do not believe that the full service airlines have the culture to successfully develop sustainable in house low fares subsidiaries (Binggeli, 2002) However, there are problems associated with the idea of sustainable cost leadership as this entails that Easyjet has the lowest cost compared with competitors over time. This is unlikely to be achieved simply by cutting back costs however their competitors i.e. Ryanair will do this too. The search of a cost-leadership strategy will require Easyjet to have a strong focus on cost management, scale economies, and have experience curve cost advantages through the maintainer of volumes. In reality, it can be questioned whether cost leadership is a separate strategy. (Sharp 1991)  [1]  stated, having a cost advantage is merely a facilitator to differentiate, usually on price, adding that low-cost form seeks to remove bases for differentiation, so as to offer a generic service to the entire market, therefore reducing differences between segments. Another type of strategy persuaded by Stelios Haji Ioannou is express by sentence (Casell, 2002) It could be argued that cost leadership can be a precarious strategy, which may speed up the move towards a commodity market in which; ultimately, no one benefits (Partridge, 1994) Strategy Clock The Strategy Clock is based upon the work of Cliff Bowman. Its another Suitable way to analyze a companys competitive position in comparison to the offerings of competitors. As with Porters Generic Strategies, Bowman considers competitive advantage in relation to cost advantage or differentiation advantage. Easyjet are situated highly in strategic option 1 (low price, low added value) The eight core strategic options are: 1. Low price/low added value Likely to be segment specific. 2. Low price Risk of price war and low margins/need to be a cost leader. 3. Hybrid Low cost base and reinvestment in low price and differentiation. 4. Differentiation (A) Without a price premium: perceived added value by user, yielding market share benefits. (B) With a price premium: Perceived added value sufficient to bear price premium. 5. Focused differentiation Perceived added value to a particular segment warranting a premium price. 6. Increased price/standard Higher margins if competitors do not value follow/risk of losing market share. 7. Increased price/low values only feasible in a monopoly situation. 8. Low value/standard price Loss of market share. The strategy clock diagram http://htmlimg3.scribdassets.com/9l9911lw1u1cczk/images/2-2c81643482/000.jpg (Scribd.com) Easyjet SWOT analysis Strength: Easyjet has a strong brand name in the low cost airline industry; the company also owns the general popularity among customers, business or leisure, for its low fares and high efficiency Most seats are sold through Internet. Ticketless airline makes Easyjet different from rivals. Flattened structure and casual culture give efficiency in management and operation. Easyjet is frequently able to benefit from the latest technology and working practices. Efficient use of airports and aircraft is another critical strength of Easyjet. The sound network helps the company to cut costs. Paperless operation has simplified and given the huge flexibility in the management working practices. Easyjet standardise on a single aircraft type and purchase new aircraft in bulk, thereby minimizing maintenance costs. The merger of Go accelerates the company growth Weakness: Easyjet is limited at the present time to regional operations, which does not allow it to develop a more balanced portfolio of services. Although EasyJets benefits from the deal with airbus in many ways, it also causes a problem the company will operate on a mixed Boeing/Airbus fleet. Staff training and coordination in future are crucial to the move For the elder people or the people who do not use the internet, it is not convenience to book on line. They really should have more ways to book There is no business class in airplane of EasyJet, which makes it lose some business travellers Opportunities: From a political perspective, the deepening and widening of EU provides new opportunities industry wide. New routes can be introduced to those countries that will join EU in near future. Furthermore, Airlines are now able to operate a base out of any European Country, which gives many more opportunities for expansion. Comparing to US market, the European market is still an immature market, which provides opportunities to all players. General slump forces most companies and individual keep in a tight budget, therefore low cost airlines now have more chance to fight their expensive rivals. Threats: The low-cost carriers are facing rising costs, particularly in the areas of fuel, airport charges and salaries. Unpredictable incidents (e.g. Iraqi war, SARS) give uncertainties in fuel supply, customers sentiment, etc. Competition from rivals is another threat, including new businesses copying low price and no frills strategy Recommendations This report has shown that Easyjet has done very well since it begun in 1995, it is dong almost everything correctly using their competitive strategies to become successful and stay ahead of their rivals. Although the huge profitable company that it has become, its important that they do not become over confident, and be aware of what their competitors are doing, they should always have enough capital to them to make radical changes if needed to. There are a number of ways in which Easyjet could improve to take the organisation forward and make the company more profitable and improving performance. Firstly Easyjet could cooperate with other easy business, such as Easycar which could do deals on transport and parking at airports, Easyfinance could offer a special rate for loans used on flights. Easyhotel could give discounts on hotels around the airports. This could not only help easyjet and making it better for customers but also increase other easy businesses. It could be very beneficial for Easyjet to build alliances with transatlantic operations. This would build a better relationship with the transatlantic operations meaning it could create more routs. Easyjet have over 400 routes which means they have many more routes which they could add. This would mean gaining more customers that couldnt reach destinations before in which other airlines visited. As fast as the internet has grown over the last few years, not everybody has it or know how to use, more often its elder people, whom could add a bigger market if Easyjet could find out a way to reach them and make a better way of buying flights for them. Although Easyjet do have a phone number to book flights it has been stated Telephone bookings are more expensive and are not encouraged (Lowfareflights) which is very off putting. Possibly free phone calls or some sort of broacher sent through the post could let the people without internet find out about Easyjet and be able to purchase with no hassle. As the number of low cost carriers is growing another possibility could be created some sort of loyalty scheme such as loyalty card or member card. The customer would then collect points whenever they travel with Jeasyjet, which would add up and when they have enough points, they could receive some sort of reward such as a discount on flights, free flights etc. This would benefit Eeasyjet as well as the customers because the customer would want to travel with Easyjet instead of another company because they know they can save points and be rewarded with Easyjet. Major companies in the UK such as Tesco using clubcard who introduced it in 1994 to gain customers loyalty, it proved to be very successful, making customers from other stores switch to Tesco as they knew they would b rewarded with this scheme. David Sainsbury, then chairman of J Sainsbury plc, rejected the idea of introducing a similar scheme. However, the effect that Clubcard had on Sainsburys sales led to the reversal of th at decision, with the launch of the Sainsburys Reward Card in June 1996. (Randall, 1996-06-23) This will therefore stop customers switching to Easyjets rivals. From this report, Easyjet can be seen as one of the main airlines in its market, and although it has some tough competition Easyjet is becoming stronger. Its competitive strategies are ahead of the competition and are being very successful. No company is perfect and always need improvements therefore Easyjet could become ever more successful and dominate the market despite of the stiff competition. Reference List

Bill Gates & Steven Jobs

Bill Gates & Steven Jobs The technology term today is growing rapidly in hi competitor between different companies, and between different company leaders, and in this essay I will compare two famous people in this field. These two famous persons are Bill Gats Steven Jobs . However, Gates and Stevens share some surprising similarities. Some of you may think that because Gates and Jobs work at the same field; which is technology. These two persons are similar because of three main reasons, they have the same characteristic, the same education situation, and the same failed of the job.One major similarity of these two persons is the special characteristics that they have. For example, both Steven Jobs and Bill Gates are intelligent innovative thinkers who have always new things to show and give to the world, and also both of them are known as the best-known entrepreneur of the personal computer revolution in the modern age. Moreover, Bill Gates has this energetic spirit which spread to cover all the people who are surrounding him, and also Steven Job had this special thing which admires the others and encourages them. Therefore, because of these special qualities that they both have they become famous and popular.Another similarity between Gates and Steven is the situation that they both had in their education. They both had been dropped from the college and then they complete studying by their self. Actually, Bill Gates had been dropped from Harvard University because he had some problems in studying in the sophomore year. On the other hand, Steven Jobs had been dropped from Reed University because he had some problems in covering the tuition fees. Moreover, Steven Jobs and Bill Gates have big similarity because of the same field that the both work in which is technology.To illustrate, Steven Jobs worked at Apple, and he is the best known as co- founder, chairman, and chief executive officer of Apple Inc. In contrast, Bill Gates is the best known chairman of Microsoft company , and everybody know well that these two companies are the greatest in technology From the information given, we can say that these two persons are the largest contributors of the modern technology revolution. Also, we can infer that there a lot of similarities between them which represented in characteristic, education, and the field of job. Therefore, these people perpetuate their names for their big achievements that they did.

Edisons Portrayal Essay - 1072 Words

Edison’s Portrayal A dreamer, an inventor, and above all, Thomas Edison was an ambitious and ruthless businessman who manifested the deep determination to take over the electricity market. Edison’s portrayal in Moran’s book â€Å"The Executioner’s Current† holds much more realistic and in depth aspects of his personality, than shown in the short excerpt, â€Å"They Transformed the World† pertaining to â€Å"America’s greatest change-makers.† On top of being an inventor, as shown in the excerpt, Moran’s portrayal of Edison displays him as an aggressive and competitive businessman by using the media and press to influence public opinion, as well as by pushing for the Electrical Execution Act. nbsp;nbsp;nbsp;nbsp;nbsp;Edison knew he could persuade the†¦show more content†¦Edison announced, â€Å"Just as certain as death, Westinghouse will kill a customer within six months after he puts in a system of any size. He has got a new thing and it will require a great deal of experimenting to get it work practically. It will never be free of danger†1 Through these tactics, he did indeed accomplish his mission of alerting the public, and it was not about to end. After receiving the attention of the public due to the speech, Edison published a pamphlet entitled â€Å"A Warning from the Edison Electric Company†. This red pamphlet included attacks on competitors such as Westinghouse, who Edison claimed was a patent violator. (Moran 58) Edison’s attack was on-going and continued as the newspaper consisted of an article, â€Å"Edison Predicted It†. â€Å"’It’ was the New York Board of Health’s conclusion that the only way to light safely by electricity was to control, by ordinance, the strength of the current.†1 (Moran 58) Edison manipulated the public to think that by using by the AC power it would succumb to death due to the dangerous tension. The aggressive businessman Edison gained the dominance of the market and trust of the public.nbsp;nbsp;nbsp;nbsp;nbsp; nbsp;nbsp;nbsp;nbsp;nbsp;Edison was not done in trying to destroy Westinghouse’s business and reputation, which is evident through his support of the new electrical executionShow MoreRelatedThe Impact Of Sound On The World Of Sound Cinema965 Words   |  4 Pagessystem worked by using a tiny mirror that twisted and turned in response to sound waves and photographed those sound waves on film. The film, resembling mountain peaks and valleys, could be edited and did not require development and printing. Thomas Edison always intended to add sound to film since the late 1800’s, effortlessly trying to combine his phonograph and kinescope to work hand in hand. The only thing holding this revolutionary concept back was synchronization. It wasn’t until the 1920’s thatRead MoreTelevision Is An American Staple Essay1042 Words   |  5 Pagesand disturbing. 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UKs unwritten constitution - Free Essay Example

Sample details Pages: 9 Words: 2724 Downloads: 3 Date added: 2017/06/26 Category Law Essay Type Compare and contrast essay Did you like this example? à ¢Ã¢â€š ¬Ã…“The unwritten nature of the UK constitution has made the legal system of the UK even better structured. It has the most supreme authority over its institutions and is organised enough as to run the functions of parliament in comparison to the written constitution of the peopleà ¢Ã¢â€š ¬Ã¢â€ž ¢s republic of Bangladesh Critically analyse. Every state has an ultimate source of legal authority. A written constitution is a document which provides the state an ultimate authority.[1] By contrast, United Kingdom (UK) does not have a written constitution[2], as a result, the ultimate law-making power lies with Parliament, the House of Commons (HC), House of Lords (HL) and the Crown[3]. Don’t waste time! Our writers will create an original "UKs unwritten constitution" essay for you Create order For this everything that happening in UK it is constitutional and if nothing happens that would be constitutional also.[4] But as the parliament and judges are the safeguards of justice and liberty and they embody the spirit of the constitution[5]in compare to giving unconditional power to the Westminster Parliament and carefully limiting the powers of Bangladesh parliament by the constitutional or judicial supremacy concept it is very doubtful in reality that whether man is enough of a political animal to produce a good, sensible, serious and efficient constitution as all the evidence is against it.[6] (George Bernard Shaw). In other word in this question i will discuss the importance of a constitution and the nature of it exist in UK and Bangladesh and finally i will give a compare idea of two kind of supremacy exist in a constitutional system, which is most justifiable to uphold and maintain the liberty and justice in a democratic system, in reality. A constitution is defi ned by Aristotle (b. 384 à ¢Ã¢â€š ¬Ã¢â‚¬Å" d. 322 BCE)[7] as the way of life that the state has chosen for itself[8] and it is the highest of all.[9] He identifies it as same with the government.[10] [11] But According to Thomas Pains and De Tocqueville the constitution means the aggregate[12] of only those written principles which regulate the administration of the state. K.C Wheare, Hood Phillips and Gilchrist included also the unwritten principles.[13]So, whether it is in written or unwritten, it is a collection of principles[14] and rules, which identify and regulate the major institution of the state and govern and define the relationship between the state and individual citizen; i.e. define the extent of civil liberty.[15] At first considering the UK constitution, which is a product of gradual evolution and its main features are- Unwritten, Flexible, Unitary, Supremacy prevail to parliament, generally centralised, Monarchical in nature with a Bicameral parliament.[16] It i s wildly known as un-codified constitution for its main sources, like Israel and New Zealand.[17] As the main sources of UK constitutional are à ¢Ã¢â€š ¬Ã¢â‚¬Å" (i) Parliamentary statutes (ii) Conventions and custom (iii) Historical Principles(the sovereignty of Parliament, rule of law) (iv) Common Law (v) Royal prerogative (vi) European laws. Due to its flexible nature, the constitution is described as a à ¢Ã¢â€š ¬Ã‹Å"constitution in fluxà ¢Ã¢â€š ¬Ã¢â€ž ¢[18]. On the other hand the Constitution of Bangladesh (BD) is the product of the Liberation Struggle. After nine month war Bangladesh achieved its independent on 16th December 1971 from Pakistan and soon after only within eleven month on 4th November 1972 the final draft was adopted by its Constituent Assembly.[19]The Silent features of this constitutions are- Written, Rigid, Preamble, and Supremacy of the constitution, unitary govt. system, Independence of judiciary, Fundamental Principle and rights. It has a unicameral par liament.[20] So, in compare to the Bangladesh constitution some argued that British Constitution should be codified. As a written constitution would be a better safeguard for the peopleà ¢Ã¢â€š ¬Ã¢â€ž ¢s rights, Liberals and freedoms. It reduces the executive powers of the Politianà ¢Ã¢â€š ¬Ã¢â€ž ¢s. Ità ¢Ã¢â€š ¬Ã¢â€ž ¢s creating much better public awareness. But there are some arguments for an un-codified constitution those are- It is adaptable to changing circumstances as it is easy to amend. The power of unelected bodies has simply passed to elected or accountable bodies. The constitutional safeguards are weaker in the UK Governments can respond more easily to crises such as the increased terror threat after 9/11. It has stood the test of time, unlike much of the Countries there have been no violent revolutions or civil wars for several centuries.[21]So, it is so much justified that the un-codified nature of UK constitution is more efficient from a written one. Now, I will give a compare idea about constitutional supremacy in Bangladesh with the parliamentary supremacy in UK. Firstly considering the UK constitution the doctrine of the unlimited sovereignty of parliament in UK is a product of a long struggle between parliament and the crown which culminated in 1688 with the bill of rights 1689.[22] As According to A.V. Dicey (1885) sovereignty are of two types, legal sovereignty and political sovereignty. [23] The people hold political sovereignty whilst legal sovereignty rests with the à ¢Ã¢â€š ¬Ã…“Queen in Parliamentà ¢Ã¢â€š ¬Ã‚  in UK.[24] Dicey had illustrated three main rules of legal sovereignty. According to the first principle of Dicey, Parliament is the supreme law making body and may enact laws on any subject matter. For instance UK parliament in 1716, to extend its own life enacted the Septennial Act to extending the duration of parliament from 3 to 7 years (Now 5 years by Parliament Act 1911, s.7). By enacting the Act of Settlement 1700[25] and His Majestyà ¢Ã¢â€š ¬Ã¢â€ž ¢s Declaration of Abdication Act 1936,[26] now UK parliament may legislate to change the succession to the throne. By passing the Union act with Scotland in 1706[27], Parliament may abolish itself and reconstitute itself as a different body. Now it may also legislate to alter its own powers (Parliament Act 1911 and 1949) by enacting the House of Lords Act 1999, its removed the hereditary peers from the Upper House. UK Parliament may grant independence to dependent states, whether dominions or colonies, as with the Nigeria Independence Act 1960 and the Zimbabwe Independence Act 1979. UK Parliament can pass laws which are retrospective or prospective. Following the House of Lords decision in Burmah Oil Company v Lord Advocate, [28]parliament passed retrospective legislation, the War Damage Act 1965 to nullify the effect of the House of Lordà ¢Ã¢â€š ¬Ã¢â€ž ¢s decision.[29] UK Parliament may legislate with extra territorial effect beyond the jurisdiction of the UK even if this produces a conflict with international law. (See Cheney v Conn [30]and Morisneen v Peters [31]case). As, the Aviation Security Act 1982, which extends the jurisdiction of the courts to try the hijacking cases irrespective of the territory in which the offence occurred. It can also pass laws which are contrary to fundamental constitutional principles (R v Jordan[32]). In R v Secretary of state for the Home Department ex parte Simms Lord Hoffman stated that the principle of Parliamentary Sovereignty means that parliament can if it chooses; legislate contrary to fundamental principles of human rights.[33]So we can say that according to Sir Ivor Jennings (1882) parliament can legislate to ban smoking on the streets of Paris. However it is important to note that Diceyà ¢Ã¢â€š ¬Ã¢â€ž ¢s theory is concerned purely with the absence of any legal limitations on Parliament. He acknowledged that there were clearly political limits on what parliament could do. According to him sovereignty is limited on every side by the possibility of popular resistance. The second limb of Dicey is, No Parliament may be bound by his predecessor or bind his successor. That means each parliament must enjoy the same unlimited power as any before it. In Austinà ¢Ã¢â€š ¬Ã¢â€ž ¢s word à ¢Ã¢â€š ¬Ã…“illimitableà ¢Ã¢â€š ¬Ã‚ . Two forms of repeal exist to signify that fact that parliament are not bound. They are; As Express Repeal is where legislation is passed which expressly states its intention an act should be repealed. There are some strong arguments that the UK has succeeding in binding itself in this way in considering the effect of human rights act 1998 and the European Communities 1972. However there is also the argument that the requirement to use express words is not particular onerous and represents at best a limited form of entrenchment. Another, the doctrine of implied repeal provides the mechanism by whi ch the judge gives effects to the rule against Parliament being bound by previous Parliaments. If Parliament passed an Act and did not repeal the previous Act expressly, then the doctrine of implied repeal come into the play and the judges will apply the latest statute deeming that the earlier Act was impliedly repealed. The two cases (Vauxhall Estates LTD v Liverpool Corporation 1932[34]) and (Allen Street Estates LTD v Minister of Health 1934[35]) illustrated the principle of doctrine of implied repeal. As The Statute of Westminster 1931, s4 was enacted to give statutory force to the convention that the UK parliament would not legislate for Dominions without their consent. The Statute imposes substantive and procedural restrictions on Parliamentà ¢Ã¢â€š ¬Ã¢â€ž ¢s ability to legislate for former colonies. In Blackburn v AG Lord Denning stated that, in legal theory one parliament cannot bind another. But legal theory does not always march alongside political reality. Legal th eory must give way to practical politics.[36] (British coal corporation v The King case )[37] But In manuel v AG[38]and Megarry v C case clearly restated the orthodox view of sovereignty. In this view, à ¢Ã¢â€š ¬Ã…“it is a fundamental of the English Constitution that Parliament is supreme. As a matter of law the courts of England recognize Parliament as being in all same the power to destroy its own omnipotenceà ¢Ã¢â€š ¬Ã‚ . There can be seen that the grants of independence do impose political limits on parliament but do not limit the legal power of Westminster to pass laws governing these states. Furthermore, The Act of Union with Scotland 1707 provided a fertile source for academic debate which remains a powerful argument against the unlimited freedom of any Parliament at any time to legislation. In the words of Prof. J Mitchell the near parliament was à ¢Ã¢â€š ¬Ã‹Å"born unfreeà ¢Ã¢â€š ¬Ã¢â€ž ¢, because the Acts bind and limits the power of Parliament [39]( MacCormick v Lord Advocate [40]and Gibson v Lord Advocate stated the above also). In Attorney-General for New South Water v Trethowan[41]case others the validity of the Constitution (Legislative Council) Amendment Act 1929 was tested also.[42] But according to Diceyà ¢Ã¢â€š ¬Ã¢â€ž ¢s viewed the acts as having no higher legal status than any other act and could not threaten sovereignty. As the UK Parliament has altered may of the principles contained in both the Scottish and Irish Acts of Union. Further the judicial remarks were obiter and for others arguments some academics have challenged that as parliament cannot bind its successors as a result of some commonwealth cases. The third limb of A. V. Dicey is, no person or body à ¢Ã¢â€š ¬Ã¢â‚¬Å" including a court of law- may question the validity of Parliamentà ¢Ã¢â€š ¬Ã¢â€ž ¢s enactments. As the manner in which sovereignty is upheld in UK is through judicial decisions. Lord Denning stated this as à ¢Ã¢â€š ¬Ã…“in my opinio n, it is the function of the court to see that the procedure of the Parliament itself is not abused and that undue advantage is not taken of it. In so doing the court is not trespassing on the jurisdiction of Parliament itself. It is acting in aid of Parliament, and, I might add, in aid of justice. If is proved that Parliament was misled, the court can and should draw it to the attention of Parliament.à ¢Ã¢â€š ¬Ã‚  But, the House of Lords rejected this view and Lord Reid stated, à ¢Ã¢â€š ¬Ã…“The function of the courts is to construe and apply the enactments of Parliament. The courts have no concern in the proceedings how the Act was passed.à ¢Ã¢â€š ¬Ã‚  (Pickin v British Railways Board 1974[43]and Jackson v Attorney General 2006 )[44] The U.K. has incorporated the European Convention of Human Rights (ECHR) into domestic law through the Human Rights Act 1998 (HRA 1998). It imposes some obligations on Parliament and judges. Under this act Section 3 requires the legislati on to be interpreted as far as possible in a way which is compatible with Convention rights. Section 4 allows the higher courts to make a à ¢Ã¢â€š ¬Ã‹Å"declaration of incompatibilityà ¢Ã¢â€š ¬Ã¢â€ž ¢ but the courts cannot declare an Act of Parliament invalid. If the Act is not compatible with Convention rights, then the courts have to leave it to Parliament to enact the necessary changes. (Thoburn v Sunderland City Council 2002)[45] Furthermore the UK became a member of European Community by means of European Communities Act 1972 (ECA 1972). The ECA 1972, Section 2 and Section 2(4) has radically altered the standing of Parliamentary Sovereignty. In Van Gend en Loos (1963) the European Court of Justice (ECJ) held that by signing treaties, the member states had created a new legal order in which individual states had limited their sovereign rights.[46] In Internationale Handelsgesellschaft (1970[47]) where ECJ stated that EU law is even superior to U.K. law. (Factortame no. 1 to 5.)[48] Moreover, in Simmenthal case, ECJ held that EU law is superior to national law whenever enacted.[49] As discussed above, EU and ECHR law is superior to English law and now U.K. parliament will not enact any law which is contrary to EU law and violates of Human rights. Therefore, rule 1 of A.V. Dicey is violated. As far as present U.K. Parliament is concerned, it is still bound by the obligations which were accepted by the Parliament of 1972 and HRA 1998. This is the violation of rule 2 of A.V. Dicey. Moreover, if U.K. Parliament enacts any law contrary to EU law, U.K. courts will never accept it. Moreover, judges now have the power to issue à ¢Ã¢â€š ¬Ã‹Å"Declaration of incompatibilityà ¢Ã¢â€š ¬Ã¢â€ž ¢ if the law is contrary to human rights .This is a form of challenge and therefore rule 3 of A.V. Dicey is violated. However, theoretically Sovereignty of Parliament remains as the Parliament can repeal the ECA 1972 and HRA 1998 and take UK out from EU. But in practi cal, it may not be possible due to ever increasing involvement of the U.K. with the European Communities and as the HRA 1998 it provides basic rights and freedom to the citizen of UK. To sum up, it is to say that, by the passage of time, parliamentary sovereignty has become limited to some extent. Since 1689 to recent time, numerous changes has occurred and thus, Diceyà ¢Ã¢â€š ¬Ã¢â€ž ¢s limbs of parliamentary sovereignty has lost their significance to some extent and are not relevant with todays modern changed civilization. But, it is essential to say that, under an uncodified constitution of United Kingdom, Diceyà ¢Ã¢â€š ¬Ã¢â€ž ¢s theory and principles of parliamentary sovereignty has provided a guideline to the United Kingdom. In conclusion, it can be said that with the inclusion of membership of EU and incorporation of HRA 1998, it is obvious that Parliamentà ¢Ã¢â€š ¬Ã¢â€ž ¢s law making power has been practically limited and partial, but theoretically parliamentary sover eignty remains in UK. In other words, all legally organised parliaments have limited powers. The Westminster Parliament has constitutionally limited powers, very much like banglad [1] H. Barnett, Constitutional Administrative Law (7th ed. 2008), chapter 6, at P.146. [2] H.A. Barnett and Morison, Public law, University of London subject Guide, 2012(London, UOL, 2012), P 20. [3] See (n) 1 H Barnett (2009) P.146 [4](Griffith à ¢Ã¢â€š ¬Ã‹Å"The Political Constitutionà ¢Ã¢â€š ¬Ã¢â€ž ¢) Belal Husain Joy, Constitutional History of Bangladesh,1st ed (Dhaka, Bangladesh Law Book Company, 2008)P 7 [5] Lord Denning , The Changing Law , 1953 , P 18 [6] See (n) 3 Belal Husain Joy (2008) P 7 [7] https://plato.stanford.edu/entries/aristotle-politics/ [8] Abdul Halim, Constitution, Constitutional law and politics: Bangladesh perspective ( 2nd Edition, 2003)P. 25 [9] Pol. 1278b10-11. [10] Pol. 1278b11-14. [11] https://www.scholardarity.com/?page_id=2564#_ftnref6 [12] Lord Bryce [13] See, Zink, Harold, Modern Governments , 2nd ed, ( New York : D. Van Nostrand Company, 1983), P.18 [14] Stong, CF, Modern Political Constitution , (Lo ndon : ELBS, 1970), P 11 [15] See (n) 2 UOL subject Guide, 2012, P 18. [16] See (n) 1 H Barnett (2009) P.14. [17] See (n) 2 UOL subject Guide, 2012, P 20. [18] Ibid. [19] For details see: Chowdhury, A.K,The Independence of East Bangla, (Dhaka, Jatiya Granthakendra,1984 ) P 270-274. [20] See (n) 7 MD. Abdul Halim (2003) P. 41-44. [21] See (n) 1 H Barnett (2009) P.14. [22] Diplock Lj In BBC v Johons (1965). [23] Dicey, AV, Introduction to the study of the law of the Constitution, 10th edn, (London : Macmillan1959). P 39 [24] For more elaborate categorisation, see Rees, à ¢Ã¢â€š ¬Ã…“The theory of sovereignty restatedà ¢Ã¢â€š ¬Ã‚ , ( Latett, 1975), Chapter IV. [25] See (n) 23 said by Priestly in 1771 , cited in Dicey ,1885,P 47 [26] See (n) 23 Dicey, 1885, P 47. [27] https://www.legislation.gov.uk/aep/Ann/6/11 [28] [1965] AC 75 [29] See (n) 1 H Barnett,(2009) P.159 [30] [1968] 1 All ER 779 [31] [1906] 14 SLT 227 [32] [1956] 40 Cr App R 152 [33] [1999] 3 All ER 400, [1999] UKHL 33 [34] [1932] 1KB 733 [35] [1934] 1 KB 590 [36] [1971] 1 WLR 1037 [37] [1935] A.C. 500 [38] [1982] 3 All ER 786,822 [39] Mitchell. JDB à ¢Ã¢â€š ¬Ã…“Sovereignty of parliament à ¢Ã¢â€š ¬Ã¢â‚¬Å"yet againà ¢Ã¢â€š ¬Ã‚  (1963) 79 LQR. [40] [1953]SC 396 [41] [1974] AC 763 [42] [1931] 44 CLR 395 [43] [1974] 2 WLR 208 [44] [2005] U.K.HL. 56 [45] [2002] EWHC 195 [46] [1963] EUECJ R-26/62 [47] [1970] E.C.R. 1125 [48] Factortame I [1991] 1 A.C. 603 Factortame II [1991] ECR 1-4586 Factortame III [1996] ECR 1-1034 Factortame IV [2000] EULR 40 R v S of S for Transport ex p Factortame Ltd (No 2) [1991] [49] [1978] ECR 629