 Among the most influential of contemporary democratic critics is Jeremy Waldron. Waldron is, to put it mildly, no fan of constitutional review. Nor is he enamored of the grandiose constitutional charters and bills of rights which serve as the most contentious ground in terms of which that power is often exercised by courts. According to Waldron and his fellow democratic critics, constitutional review under an entrenched charter or bill of rights is fraught with both theoretical and practical difficulty. It threatens democracy and is both fundamentally unfair and politically dangerous. It also relies on outmoded views about the nature of moral rights—that there are objective, universal rights of political morality to which charters or bills of rights make reference, upon which there is widespread agreement within democratic communities, and to which judges can sensibly and justifiably be asked to appeal in protecting citizens against recalcitrant exercises of government power. While it is true that constitutional review need not be based on an appeal to abstract rights of political morality—it could, for example, be restricted to questions such as whether Congress or a provincial legislature has followed proper procedure—and true that it need not include the ability actually to strike down legislation, the main focus of democratic critics has been on strong-form constitutional review which exemplifies these two features.