The government's controversial plan to scrap the Human Rights Act and replace it by a British Bill of Rights has been delayed again, according to the Justice Secretary, Michael Gove.

Gove told peers yesterday when he appeared before the House of Lords constitution committee that the planned consultation on the measure had been put back until 2016.

He said it was because of the possibility of "complex" constitutional changes involving the UK's highest court.

The new issue, he said, was "whether or not we should use the British bill of rights to create a constitutional longstop, similar to Germany's constitutional court, and whether the Supreme Court should be that body".

The Conservatives pledged at the last election to scrap the Human Rights Act, which was brought in with all-party support under the Blair government. It also campaigned to cut the link between the European Court of Human Rights and British courts to make British judges freer to disregard rulings from Strasbourg.

Among the pressure points leading to Conservative antipathy to the ECHR are the latter's judgment that some prisoners should be given the right to vote, so far resisted by the government.

Asked whether the UK's defiance on that issue was damaging Britain's international reputation and "unworthy of the Conservative party", Gove replied: "I would argue that our parliament should not accept a change to the law to grant prisoners the vote.

"We have a conflict between two principles: respect for the ECHR judgment and for parliamentary sovereignty. I would err on the side of democratic sovereignty."

Critics of the government's policy say that scrapping the Human Rights Act will weaken protection for UK citizens and weaken the force of the European Convention on Human Rights in the eyes of other European governments.