722 THE FEDERATIONS AND THE UNION [PART 1V
affect all locally within is as clear! as the lack of power to
affect what is without, for, as the doctrine mobilia sequentur
personam is not to be taken as depriving the provinces of
legislative power over goods inside the province in fact, but
outside in law, so also it does not confer upon them a power
to affect goods outside the province because a testator is
domiciled in the province ;2 Manitoba by Acts, 1910, c. 20, and
1911, c. 26, has recognized this fact and amended its death
duties Act so as not to claim to affect property situated out-
side Manitoba, but taxes property in Manitoba on a scale
determined by the amount outside.
There seems to be no real ground for the view expressed by
Todd? that under the powers in s. 92 the Provincial Legisla-
tures can legislate so as to affect the exclusive powers of the
Parliament in 8. 91. The cases merely show that a Provincial
Act may deal with matters which might come under Dominion
control in a different aspect : in Bennett v. The Pharmaceutical
Association of the Province of Quebec * it was held that it was
valid to require qualifications on the part of sellers of drugs
and medicines, though it might interfere in some degree with
the sales of drugs and medicines in the provinces.
The principles of interpretation which can be derived from
the judgements of the Privy Council are simple, and resolve
themselves into the view that the Act must be so interpreted
as not to make the provisions contained in it of no effect or
directly contradictory. Thus with regard to the reservation
to the provinces of civil rights the principle is not to allow
the fullest play to these rights and restrict the powers of the
Federal Parliament accordingly, which is the view taken by
the High Courtof the Commonwealth, but to allow the Federal
Parliament full power to regulate the matters entrusted
1 Lefroy, op. cit., pp. 752-70. Cf. Cowan v. Wright, (1876) 23 Gr, 416;
Attorney-General of Ontario v. Attorney-General for the Dominion of Canada,
[1894] A. C. 189, overruling Clarkson v. The Ontario Bank. 15 0. A. R. 166.
at p. 190,
* Woodruff v. Attorney-General for Onlario, [1908] A. C. 508; Bank of
Toronto v. Lambe, 12 App. Cas. 575, at pp. 584, 585.
3 Parliamentary Government in the British Colonies, p. 436,
4 (1881) 1 Dor. Q. A. 336; ex parte Laveillé, 2 Steph. Dig. 445, at p. 446
Lefroy, op. cit., pp. 456 seq.