cap. 11] LIMITATION OF LEGISLATION 375 
down that, whatever might be the power of the Imperial 
Parliament, no Colonial Legislature could bind persons 
resident outside the territory, and he instanced the fact 
that difficulty had always arisen when it was sought to 
establish a Colonial navy because of the limited extent of 
Colonial jurisdiction. It was decided by the Supreme Court 
of New Zealand in re Gleick! that the Colonial Legislature 
had no power to authorize the conveyance on the high 
sea to another Colony, and the detention outside its own 
jurisdiction of any person whatsoever, such power requiring 
Imperial authority. On the other hand, Higinbotham J., 
in the Victorian case of Regina v. Call, ex parte Murphy? 
declared that though as a matter of abstract speculation the 
Legislature of Victoria might have no authority outside 
the Colonial limits, still its enactments were binding on all 
Colonial Courts in Victoria. 
Other early cases on this question affect the attempt to 
give effect to criminal laws of a Colony beyond the territorial 
limits. Thus in Regina v. Brierly 3 it was held by the Chancery 
Division of Ontario that a Canadian law was valid which 
made it an offence for a British subject resident in Canada 
to commit bigamy anywhere, provided that he had left 
Canada in order to commit the offence. But this case was 
overruled or dissented from by the Queen’s Bench of Ontario 
in Regina v. Plowman, on the strength of Macleod v. Attorney- 
General for New South Wales’ and it is impossible to follow 
Mr. Lefroy ® in his ingenious attempt to distinguish the 
cases by the fact that the enactment of New South Wales 
did not restrict its operation to British subjects resident in 
that Colony as did the Act of Canada. 
The whole question was elaborately considered by the 
10. B. &F. S.C. 79; New Zealand Parl. Pap., 1880, A. 6. 
* 7V. L. R. 113, at p. 123; cf. also Reg. v. Pearson, 6 V.L R. 333; 
Lefroy, op. cit., p. 263, note 1; above, p. 170, note 1. : 
1 (1887) 14 O. R. 525; 4 Cart. 665. Cf. Reg. v. Giles, 15 C. L. J. 178. 
} (1894) 25 O. R. 656. 
5 [1891] A. C. 455. Cf. Reg. v. Mount, 6 P. C. 283; Low v. Routledge, 
1 Ch. App. 42; Reg. v. Keyn, 2 Ex. D. 63. ¢ Op. cit., pp. 336-8.