³⁷In R v Pora  [2001] NZLR 37 the Court of Appeal considered the effect of enactment by the Criminal Justice Amendment Act (No 2) 1999 of a new section 80 of the Criminal Justice Act 1986.  Section 4(2) of the principal Act provided that no court could impose a sentence or penalty on an offender which could not have been imposed at the time of the commission of the offence. The later amendment imposed a longer minimum non- parole period (13 years) for the offence of murder if the commission of the offence involved home  invasion.  The  amendment  was  expressed  to  apply  in  relation  to  offences  committed  before  the commencem ent of the amendment. The amendment was contained in a Supplementary Order Paper moved in the committee stages of the Bill by a back bench mem ber and adop ted by the House. It was not, however, the subject of separate Bill of Rights clearance. 19 support. Others, such as compliance with the LAC Guidelines, rely on a form of internal  self-evaluation  mandated  by  government  direction.  A  statute  protects against abuse by the executive of its law making powers. They are an effective combination of forces directed at promoting access to justice in the sense I have taken it. 31 The mechanisms are not necessarily ideal. There is no formal process for Bill of Rights scrutiny once a Bill has been introduced into Parliament. In his submission to the Standing Orders Committee in the context of the 2003 review of the Standing Orders, the Clerk of the House  advocated that select committees have a formal mandate to scrutinise Bills for Bill of Rights compliance. Others have made similar pleas. In a parliamentary environment in which significant changes are made to Bills as they pass through the legislative process, there will be risks that a non-complying measure will get through the net.³⁷  The scrutiny and reporting on Bill of Rights compliance is done within government. Would an independent  agency be more appropriate to carry out the task? For myself, I believe a process that imposes an onerous  self-discipline  on  government  Ministers  and  their  advisers  to  ensure compliance  with  fundamental  legislative  principles  and  the  principles  of  good legislative design is likely to be the most effective. At the same time, some form of separate parliamentary scrutiny could do no harm. 32 The Regulations Review Committee consists entirely of members of Parliament. While it is, by convention, chaired by an opposition member, it includes members