IN Collins v Secretary of State [2016] EWHC 33 (Admin), the High Court refused to declare that Criminal Justice and Immigration Act 2008, s. 76(5A) – the so-called “householder's defence” – was incompatible with the right to life enshrined in Article 2 of the ECHR, in that it failed to protect the lives of attackers sufficiently. Section 76(5A) was inserted into the 2008 Act by Crime and Courts Act 2013, s. 43, and came into force in April 2013.