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proceedings as was available to your lordships. In particular he did not have anaccount of the development which had taken place in the granting of prerogativeorders against ministers, which meant that in practical terms the onoyconsequence of treating s 31 as enabling injunctions to be granted againstministers acting in their official capacity would be to provide an alternative inname only to the orders of prohibition and mandamus which were alreadyavailable and to allow interim relief other than a stay for the first time.A secondary cause was his reliance upon Upjohn J’s judgement in MerricksHeathcoat – Arrory (1955) 2 All ER 453, (1955) Ch 567, a judgment which asalready indicated, should be approached with caution. Lord Bridge was alsoinfluenced by the fact that the new Ord 53 was Introduced following the LawCommission’s Report on Remedles in Administrative Law (Law Com no 73)(1976) and that that report drew attention to the problem created by the lack ofjurisdiction to grant interim injunctions against the Crown and recommended thatthe problem should be remedied by amending s 21 of the 1947 Act. The reportincluded a draft of the legislation proposed. This proposal of the LawCommission was never implemented. Instead the decision was taken followingthe Law Commission was never implemented. Instead the decision wa takenfollowing the Law Commission’s report to proceed by amendment of the rules ofthe Supreme Court other thanmeant that s 31 of589