England's senior judge turned a page of his notes and read a carefully-drafted reply to the question he had been expecting. At one point he paused, looked up at at the glassy-eyed MPs and peers facing him, and said: "If this is difficult, believe me, I am finding it so too."

What we are all going to find difficult in the months and years ahead is the EU's "accession" to the ECHR. The Lisbon treaty, which has been in force since December 2009, commits the European Union to sign up to the human rights convention. Officials at the Council of Europe have now drafted an accession treaty.

Why should individuals be allowed to submit EU measures to what the draft calls "external control"? Put simply, it is because Brussels now plays so large a part in all our lives. There are many areas of law in which the UK has ceded powers to the EU. At present, they are not covered by the human rights convention.

Imagine that the EU issues some dodgy directive limiting freedom of expression and that the UK government has brought it into effect, as indeed it must. A writer complains that the new law breaches his rights under article 10 of the ECHR. He wants to take the British government to the human rights court. "Nothing to do with us," the minister replies. "You should be taking action against the European Commission." And that's just what you'll be able to do.

Hang on, I hear you say. Doesn't the EU have its own court in Luxembourg? How does that fit into the picture?