<P> However, the Practice Statement has been seldom applied by the House of Lords, usually only as a last resort . As of 2005, the House of Lords has rejected its past decisions no more than 20 times . They are reluctant to use it because they fear to introduce uncertainty into the law . In particular, the Practice Statement stated that the Lords would be especially reluctant to overrule themselves in criminal cases because of the importance of certainty of that law . The first case involving criminal law to be overruled with the Practice Statement was Anderton v Ryan (1985), which was overruled by R v Shivpuri (1986), two decades after the Practice Statement . Remarkably, the precedent overruled had been made only a year before, but it had been criticised by several academic lawyers . As a result, Lord Bridge stated he was "undeterred by the consideration that the decision in Anderton v Ryan was so recent . The Practice Statement is an effective abandonment of our pretension to infallibility . If a serious error embodied in a decision of this House has distorted the law, the sooner it is corrected the better ." Still, the House of Lords has remained reluctant to overrule itself in some cases; in R v Kansal (2002), the majority of House members adopted the opinion that R v Lambert had been wrongly decided and agreed to depart from their earlier decision . </P> <P> A precedent does not bind a court if it finds there was a lack of care in the original "Per Incuriam". For example, if a statutory provision or precedent had not been brought to the previous court's attention before its decision, the precedent would not be binding . </P> <P> One of the most important roles of precedent is to resolve ambiguities in other legal texts, such as constitutions, statutes, and regulations . The process involves, first and foremost, consultation of the plain language of the text, as enlightened by the legislative history of enactment, subsequent precedent, and experience with various interpretations of similar texts . </P> <P> A judge's normal aids include access to all previous cases in which a precedent has been set, and a good English dictionary . </P>

Which of the following uses precedents or earlier rulings as the basis for law