Gardbaum continues by claiming that IHRL is quickly becoming a constitutional entity in its own right. This is due to the fact that having IHRL and domestic protection enables a dual system of rights which in turn secures the same rights protection amongst many countries. Also, the vertical effect that IHRL enjoys is akin to a ‘bill of rights’ in a domestic system and so is a constitutional entity.However, a significant difference arises, enforcement. In the UK, we can see the impact of the Human Rights Act 1998 and the increasing use of judicial review that the emergence of ‘juridification’. International human rights on the other hand have much less power and even more so at a global level and there is no single international human rights system, only regional and global systems. These systems can overlap and cause complexity. Gardbaum states that IHRL has no single source and this leads to further overlapping and confusion. Much of the IHRL has its source in customary laws rather than incorporated treaties.