566 PARLIAMENTS OF THE DOMINIONS [PART III 
good. There remains in each case the fact that the nominee 
House might throw out a Bill for the general supply, and 
could easily be tempted in a crisis to reject a Bill for some 
particular supply, though the action of the Lords in 1909 in 
the United Kingdom, and its sequel, are a significant warn- 
ing against unconstitutional conduet, and the rejection of 
a whole Appropriation Bill is unthinkable in Canada, New 
Zealand, New South Wales, and Queensland. In 1878 the 
Upper House in Quebec threw out the Supply Bill in order 
to embarrass the Government of M. Joly, but that was 
exceptional in two ways : in the first place, M. Joly held 
office on a most insecure tenure, and the province had been 
much moved by the proceedings in the case of M. Letellier ; 
in the second place, it was the case of a nominee House, which 
could not be swamped as the numbers were limited. So 
boo in Natal, the Upper House in 1905 declined to accept 
a native-tax Bill proposed by the Government as a means 
of raising revenue: the Bill was not exactly a desirable 
measure, and the gravamen of the charge against it was 
mainly that it was unfair to increase native taxation even 
with the usual requirement of the reservation of the Bill 
under the royal instructions and the consequent necessity of 
securing the assent of the Imperial authorities. 
In the case of the Transvaal an interesting dispute arose 
in 1908 as to what constituted a Money Bill! When the 
Public Service and Pensions Bill came before the Legislative 
Council the President of the Council ruled that as some of 
the clauses of the Bill dealt with appropriations the whole 
Bill was, within the meaning of the letters patent establishing 
the Legislature, a Money Bill, and while it could be rejected 
it could not be altered by the Upper House. Several of the 
members of the Council disputed his ruling, and eventually 
the Government referred home to the Secretary of State for 
an opinion on the matter. The Secretary of State replied in 
a dispatch, No. 104 of March 25, 1909, conveying the views 
of the law officers of the Crown on the question, and also 
sending a copy of a letter from the Clerk of the House of 
' Transvaal Legislative Assembly Debates, 1909, Pp. 691 seq., 898 seq.