In 1974 the Court in Wolff v. McDonnell appeared to repudiate its longstanding policy of avoiding interference with the management of prisons by ruling that the disciplinary procedures of a Nebraska prison violated the Constitution. Five years later the British judiciary established the principle of judicial review of prison discipline in its decision in R. v. Hull Prison Board of Visitors, ex parte St. Germain (No. 2). The Wolff decision rested its application of the due process clause on a novel analysis of an inmates interest in liberty. In contrast, the British decision focused on natural justice. However, the Supreme Court has pursued a policy of wide-ranging deference to prison officials, and the Wolff decision has not prevented abuses of power by prison tribunals. Therefore, the Supreme Court should give the due process clause a broader application that is the equal of English natural justice. 508 footnotes.