A couple of dictionary checks suggest some set of:

- Ruler who is unrestrained by law or constitution

- A usurper of sovereignty

- Ruler who uses power oppressively or unjustly

Obviously b) is not applicable as per GP. He has also been constrained by the supreme court and others multiple times in this term, which suggests a) is a stretch. c) probably a fair accusation, though I'm not sure I would agree.