?The doctrine of judicial precedent (judge made law) lies at the heart of the English legal system. As Michael Zander stated in "The Law-Making Process," “It is difficult to conceive of a legal system where judicial precedent plays no part at all”. This doctrine is based on stare decisis which means stand by that which is decided. Actually not all parts of a judgment form a precedent. The ratio decidendi follows from the doctrine of judicial precedent that like cases should be treated alike. The courts are only bound by the rules and principles provided in the decisions and these are what is called ratio decidendi. When a judge uses a dissenting opinion, then we can be quite sure that it is obiter dicta and thus, such statement will not be held as binding but somehow they may have persuasive power. This doctrine is also defined by R Cross in ‘Precedent in English Law’ as “any rule of law treated by the judge as an essential step in reaching his decision having regard to the line of reasoning adopted by him.” The hierarchy of courts is essential to the operation of judicial precedent. Usually, a court is bound by equally standing courts or those of higher authority than itself in the hierarchy. In September 2009, the Supreme Court replaced the House of Lords by virtue of the Constitutional Reform Act 2005. Since then, the Supreme Court sits at the pinnacle of the English court hierarchy and its decisions are binding on all other English courts. The House of Lords were bound by its own decision following the case of London Tramways v London County Council until 1966. In this case, Lord Halsbury stated that, “A decision of this House once given upon appoint of law is conclusive upon this afterwards.” Decisions of the highest court of the land should be final so that there will be certainty in law and finality in litigation. Undeniably, the result of strict binding would likely lead to individual hardship but if otherwise, it would be disastrously inconvenient and there would be no real final court of appeal. The Lordships recognised that it would be too rigid on adherence to precedent and may lead to injustice and unduly restrict or prohibit the development of law. In 1966, Lord Gardiner issued a Practice Statement which allows the House of Lords to depart from its own previous decision when it appears right to do so. However, the law lords used this power quite sparingly. In Miliangos v George Frank Ltd, Lord Cross stated that the Practice Statement will not necessarily be used whenever we think that a decision was wrong and we should reverse it. On the other hand, Professor Theodore Benedict expressed his view that, “If the rule of precedent is simply a rule established by the judge, then it should be easy for the practice to be changed, hence, the Practice Statement may be regarded as a revolutionary modification of the existing rule of precedent.” The House of Lords affirmed that the Court of Appeal is bound by House of Lords decisions in Broome v Cassell and Miliangos v George Frank Ltd. However, Lord Greene set out a few exceptions to this in the case of Young v Bristol Aeroplane that, if the House of Lords and the Court of Appeal decisions are in conflict, the House of Lords shall prevail. In Family Housing Association v Jones, the Court of Appeal first obliged to ignore its own decision as the decision was in conflict with later decisio