The age was raised to deter forced marriages.The Court held that there was insufficient evidence that the change in the rules would have a substantial deterrent effect on forced marriages. ‘On any view the measure was a sledgehammer but the Secretary of State has not attempted to identify the size of the nut’. In AXA General Insurance v the Lord Advocate, the Court held that the Scottish Parliament had lawfully passed an Act which provided that asbestos-related pleural plaques constituted personal injuries which is actionable in Scottish law, thus reversing a 2007 decision of the House of Lords, Rothwell v Chemical and Insulating Co. Ltd which held that the mere presence of pleural plaques did not constitute injury which could give rise to a claim for damages.  The Parliament had acted ‘not without reasonable foundation’ and the Act was not incompatible with the Human Rights Act.