438 PARLIAMENTS OF THE DOMINIONS [PART III 
Validity Act, 1865. It has been held in New Zealand, as, 
for example, during the discussions of the possibility of 
rendering the Upper Chamber elective ! and of changing the 
title of ‘ General Assembly’ to ‘ Parliament’, that no altera- 
tion can be made in these sections as the law at present 
stands. It would seem doubtful whether this doctrine is 
strictly correct. The Act of 1865 is general in its terms, 
and it would appear to give a right of alteration of the 
constitution subject only to the observation of such forms 
as may be prescribed. It is true that the existence of the 
express provisions of the Act of 1857 may be held to mitigate 
against this restriction, but the argument is not decisive? 
and it may seriously be doubted whether if the power were 
exercised the exercise would be held to be invalid by any 
Court. The question is obviously of more than theoretic 
interest, since alteration of the Upper House has been often 
discussed, though hitherto vainly, and it would seem per- 
fectly possible that the question may in the future cease to 
be merely academic if Mr. Seddon’s idea of a single chamber 
revives. Bills altering the Governor’s salary or the appro- 
priation for native affairs still require reservation under 
8. 65 of the Act of 1852. 
$4. THE ALTERATION OF THE SOUTH AFRICAN 
CONSTITUTIONS 
In the case of the Cape there were no restrictions under 
the Constitution Ordinance of 1852 as to the alteration of 
the constitution; alterations could therefore be made by 
a simple Act, which would no doubt have been reserved in 
the case of important changes as in the case of Bill No. 1 
of 1872 to establish responsible government, although re- 
servation was not legally requisite. 
The case in Natal was precisely the same under the Act 
' Parliamentary Debates, 1907, cxxxix. 276. 
* Cf. Dicey, Law of the Constitution’, p. 106, note. 
* In the case of Cape and Natal alike the rule before responsible govern- 
ment was that alteration required reservation; this was law in Natal by 
5. 51 of the letters patent of July 15, 1856.