³⁵Inquiry into Regulation-Making Powers that Authorise International Treaties to Override any Provisions of New Zealand E nactments (March 2002 ). ³⁶[2002]  1  NZL R  58.  In  Drew  the  Court  of  Appeal  declared  invalid  a  regulation  denying  legal representation to an inmate charged with a disciplinary offence on the basis that the regulation-making power in the Penal Institutions Act 1954 did not authorise the making of a regulation that would be inconsistent with the Bill of Rights. The decision rests on the vires of the regulation , rather tha n incompa tibility with the B ill of Rights. 18 authorise  international  treaties  to  override  statutes.³⁵    The  Committee  sets,  and monitors the observance of, standards in regard to delegated law-making. Many other jurisdictions have similar parliamentary scrutiny committees. They are another discipline on law-makers. The influence of the courts 29 The courts also exert discipline on Parliament and the executive. Decisions in which enactments are found to be inconsistent with the Bill of Rights will cause careful consideration to be given to compliance within government. Although not strictly, a  Bill  of  Rights  case,  the  decision  of  the  Court  of  Appeal  in Drew v  Attorney- General³⁶  led  to  a  review  of  other  potentially  offending  regulations.  Just  as governments want to avoid section 7 reports, so to are adverse findings in the courts unwelcome.  The executive does not set out to exercise its delegated law-making powers in a way that will lead to court decisions declaring its efforts invalid.  That is the last thing it wants. A successful court challenge to regulations that prescribe fees or to an important order can have serious implications. It is sometimes thought that  the  development  and  drafting  of  delegated  legislation  is  done  to  a  lesser standard  than  primary  legislation.  That  is  not  so.  Because  delegated  legislation usually has the most direct impact on the citizen, whether individual or corporate, it is viewed with the utmost importance. 30 What  I  hope  this  illustrates  is  the  existence  of  powerful  influences  driving  the principled  development  of  legislation.  Bill  of  Rights  compliance  has  statutory