450 PARLIAMENTS OF THE DOMINIONS [PART III 
in Victoria two cases have been decided which show the very 
full nature of the power which the Parliaments are able to 
confer upon themselves; it was held in Dill v. Murphy? 
that the Parliament could commit the appellant in that 
case for a libel upon one of its members, and in the case of 
the Speaker of the Legislative Assembly of Victoria v. Glass? 
it was held that the Assembly could exercise the power 
of committing for contempt without specifying the nature of 
the contempt, which in England is the supreme example of 
the power of the House of Commons, as it makes it in theory 
able to commit any person whatever for an unspecified con- 
tempt, although, were the contempt alleged to be specified, 
it is clear that, if not really a contempt, the Courts would 
interfere and release the person committed on a habeas corpus. 
In Canada the case has been of some interest because of 
the view firmly held for a long time by Canadian ministers 
of justice that provincial legislatures were very humble 
bodies and need not be allowed to arrogate to themselves 
high powers. The Parliament of Canada itself was given 
such privileges as might be appointed by law, but so as that 
such privileges should never exceed those enjoyed by the 
House of Commons in England at the date of the passing 
of the British North America Act. In 1868 an Act of the 
Federal Parliament conferred power upon committees of 
the Senate to examine witnesses on oath, and was not, by 
inadvertence, disallowed, for it was clearly wlira vires as 
giving a power not possessed by the House of Commons 
committees in 1867. In 1873 the matter came more pro- 
minently forward with regard to an Act of that year giving 
power to both Houses and their committees to examine 
witnesses on oath. The Governor-General assented to the 
Act, though aware that its validity was doubtful, but asked 
the Imperial Government to consider the matter carefully, 
with the result that, while the Act was disallowed, the 
Imperial Parliament in 1875 altered the provisions of s. 18 
of the British North America Act by making the limitation 
on the power of the Dominion Parliament merely that of 
not passing any Act which gave privileges greater than those 
* 1 Moo. P. C. (N.S.) 487; 1 W. & W. L.3342, #3 P. C. 560,