Aside from this specific statutory form of illegality, the 2011 UK Supreme Court decision in the AXA case clarified that the traditional grounds of illegality and unreasonableness did not apply to Acts of the Scottish Parliament, save in exceptional circumstances.1 AXA General Insurance Ltd v Lord Advocate, AXA General Insurance Ltd v HM Advocate. (2011). [2011] UKSC 46 [2012] 1 A.C. 868; [2011] 3 W.L.R. 871; 2012 S.C.