Dawn Oliver’s article draws from the case of YL v. Birmingham City Council to explore the implications that would flow from giving ‘horizontal effect’ to European Convention rights. She looks at the controversial YL decision and its interpretation of section 6 of the Human Rights Act, arguing that the position of the majority was the correct one. She then surveys the approach to ‘horizontal effect’ of fourteen countries around the world, concluding that ‘the problems about horizontal effect are the same as those encountered in deciding whether something is a ‘function of a public nature’ under the Human Rights Act… it is for Parliament to decide these matters. The courts will develop the law, including private law, towards creating indirect horizontal effect of Convention rights, but they will be rightly concerned not to disturb the operation of ordinary law or to create over complex balancing exercises for themselves, with negative unintended consequences.’