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38. However, the principle of "strict scrutiny" or "proportionality" and primary review came to be explained in R. V. Secy. of State for the Home Deptt. ex p Brind. That case related to directions given by the Home Secretary under the Broadcasting Act, 1981 requiring BBC and IBA to refrain from broadcasting certain matters through persons who represented organizations which were proscribed under legislation concerning the prevention of terrorism. The extent of prohibition was linked with the direct statement made by the members of the organizations. It did not however, for example, preclude the broadcasting by such persons through the medium of a film, provided there was a 'voice-over' account, paraphrasing what they said. The applicant's claim was based directly on the European Convention of Human Rights. Lord Bridge noticed that the Convention rights were not still expressly engrafted into English law but stated that freedom of expression was basic to the Common (7 of 14) [CW-1042/1999] law and that, even in the absence of the Convention, English Courts could go into the question (see p. 748-49).