D6 THE EXECUTIVE GOVERNMENT [PART I 
statute has been considered to be of doubtful validity by so 
distinguished a lawyer as the Chief Justice of South Australia, 
so that it cannot be said to be free from doubt. But it 
does seem quite within the powers of the Governor when he 
is authorized to do it by letters patent: it is clear that 
without such authority he could not do it.2 There is no 
case where any act done by a deputy has been held to be 
invalid by the Courts, and this is a case where persistent 
practice would seem to answer adequately theoretic doubts 
as to the validity of acts so done? On the other hand, the 
validity of acts done by a Governor when outside his Colony 
has not been determined in any case, and the custom has 
not yet had much time to establish itself as valid. It may 
also be noted that a deputy Governor, if he is trusted 
with the full control of the Government, may be an officer 
administering the Government within the meaning of the 
letters patent, and so may receive privileges, e.g. exemption 
from customs dues normally granted only to Governors. 
§4. THE SALARY OF THE (GOVERNOR 
The salary of a Colonial Governor is paid in every case 
of the responsible-government Colonies by the Colony of 
which he is Governor. In every case also the amount is 
provided by a permanent Act, and is not voted annually. 
Moreover, it is established by law or custom that the salary 
of a Governor shall not be diminished during his tenure of 
office : if Parliament decides to reduce the amount it will 
take effect only when the new Governor comes into office. 
The practice was illustrated by the case of Sir Fowell Buxton, 
L Cf. South Australia Legislative Council Debates, 1910, pp. 530 seq. A 
Bill to legalize the exercise of statutory powers by a deputy was passed in 
1910 by South Australia, but was reserved. 
* Forsyth, Cases and Opinions on Constitutional Law, p. 80. 
* Moreover the Interpretation Acts of the Colonies constantly recognize 
the fact of the administration of the Government by persons appointed 
other than the Governor. The special grant of power in the case of a 
federation is due merely to the fact that the Crown could not constitute 
a federation without parliamentary sanction. For a case of a deputy, see 
RB. v. Amer. 1 Cart. 718.