Things have changed from that point though; it would no longer be possible for anyone without a seat in the Commons to be appointed as PM.
Yes, but I was talking about strictly technically possibility.
Ah, but it is no longer even technically possible. That's how the British Constitution works.
I think Schroeder put it better than you, Al:
As far as the bare parliamentary system goes, nothing prevents the Prime Minister from being in the Upper House (...) But I think most constitutional scholars would say that by now, a convention has evolved (which in the British system can have the status of part of the Constitution) that the PM must come from the House.