The standard is based on the 1985 decision of the House of Lords in "Gillick v West Norfolk and Wisbech Area Health Authority". The case is binding in England and Wales, and has been adopted to varying extents in Australia, Canada and New Zealand. Similar provision is made in Scotland by the Age of Legal Capacity (Scotland) Act 1991. In Northern Ireland, although separate legislation applies, the then Department of Health and Social Services stated that there was no reason to suppose that the House of Lords' decision would not be followed by the Northern Ireland courts.