The Safe Access Zones Bill Reference [2022] UKSC 32: clearing the fog of proportionality?

A case comment on the judgment of the UK Supreme Court in the Reference by the Attorney General for Northern Ireland - Abortion Services (Safe Access Zones) (Northern Ireland) Bill [2022] UKSC 32. The comment discusses the judgment in terms of its exploration of the ab ante test of a law's proportionality, the nature of a proportionality assessment under the ECHR and the Human Rights Act 1998 as well as the nature of a proportionality analysis in an appellate setting. The comment critiques the Court's decision on the basis that the Court's assessment of all 3 aspects left significant problems in domestic case law.