cmap. 1] THE POWERS OF THE GOVERNOR 135 
plified by the case of Phillips v. Eyre, which arose out 
of Governor Eyre’s action in putting down with needless 
violence the revolt of the negroes of Jamaica. The Governor 
pleaded in his defence the passing of an Act of Indemnity 
in the Colony to which he himself had assented, and the 
Court upheld the contention, though efforts were made to 
establish that he was not entitled to rely upon an Act which 
he himself had secured the passing of. 
In the case of a self-governing Colony the responsibility 
of the Governor for his official actions may no doubt seem 
anomalous. In the case of the Crown in the United Kingdom 
the position is simple, because it is clear that the legal 
maxim that the King can do no wrong results in the trans- 
ference of responsibility to his real advisers. The responsi- 
bility of the Governor might, it may be argued, be thrown 
apon his advisers. But the rule of law grew up at a time 
when the Governor of a Colony was, to all intents and pur- 
poses, the Executive, and when he was responsible, as he still 
is in a Crown Colony, for the administration. In 1869 there- 
fore the Government of New Zealand desired the repeal of 
those Acts so far as they concerned a self-governing Colony. 
This was then not accepted, and even now it would hardly 
be possible to insist on ministerial responsibility unless the 
doctrine of complete ministerial responsibility for all actions 
wereestablished asin England, and that isnot yet true, and pro- 
bably never can be true of a Colony so long as it remains such. 
There are certain difficulties about the doctrine which show 
themselves occasionally in practice. When, for example, 
the Governor of South Australia was served with a mandamus 
in a matter arising out of a Commonwealth election, to 
which reference will be made below, he was not supplied 
with counsel or legal advice by the Commonwealth, and 
had to rely on the kindness of his ministers, who hardly 
had any direct interest in the proceeding and who might 
have refused to pay, thus involving the Governor in a serious 
difficulty, for the Imperial Government would certainly have 
-4Q.B.225; 6Q.B. 1. 
See Parl. Pap., H. C. 307, 1869, p. 400; C. 83, pp. 33, 191.