The phrase "elective dictatorship" (also called executive dominance in political science) describes the state in which a typical Westminster system state's parliament is dominated by the government of the day. It refers to the fact that the legislative programme of Parliament is determined by the government, and government bills virtually always pass the legislature because of the nature of the majoritarian first-past-the-post electoral system, which almost always produces strong government, in combination with the imposition of party discipline on the governing party's majority, which almost always ensures loyalty. The phrase was popularised by the former Lord Chancellor of the United Kingdom, Lord Hailsham, in a Richard Dimbleby Lecture at the BBC in 1976. The phrase is found a century earlier, in describing Giuseppe Garibaldi's doctrines, and was used by Hailsham (then known as Quintin Hogg) in lectures in 1968 and 1969. In the United Kingdom, ultimate legislative sovereignty resides in Parliament (Parliamentary sovereignty). Parliament may pass any legislation on any subject it wishes. Parliament operates without restraints such as, for instance, an obligation to legislate in accordance with fundamental constitutional rights. The apparent exceptions to this rule are situations in which Parliament has chosen to limit itself as with the case of implementation of European Union law, where British courts can "disapply" UK legislation that is in conflict with EU law (see Factortame), but could withdraw such authority, as it has by and large done since leaving the European Union. Parliament consists of the House of Lords, the House of Commons and the Monarch. The customary common law rule is that in order for a bill to become an act of Parliament, it is necessary for it to be passed in both the Commons and the Lords. The bill will then go before the Monarch who has formal discretion whether to assent to the bill. On receiving Royal Assent, it will become an Act of Parliament and will be applied by the courts.