Deputy Prime Minister of the United Kingdom is not recognised in United Kingdom law, so any post-holder must be given an additional title in order to have legal status and to be paid a salary additional to the parliamentary one. The last Deputy Prime Minister, Nick Clegg, was appointed Lord President of the Council, a minister who presides over meetings of Her Majesty's Most Honourable Privy Council and has few other formal responsibilities, for this reason. On some occasions the post of First Secretary of State has been used; when John Prescott lost his departmental responsibilities in a reshuffle in 2005, he was given the office to
Council of Civil Service Unions v Minister for the Civil Service Rights Act, there is a significant difference in that Orders in Council are an executive product, and lack the "representative character" that comes with Parliamentary authority and approval. As such, the Lords saw "no reason why prerogative legislation should not be subject to review on ordinary principles of legality, rationality and procedural impropriety in the same way as any other executive action". Council of Civil Service Unions v Minister for the Civil Service Council of Civil Service Unions v Minister for the Civil Service [1984] UKHL 9, or the "GCHQ case", is a UK constitutional law and UK labour law