672 THE FEDERATIONS AND THE UNION [part iv 
most important judgements regarding these cases. It is 
that the British North America Act is to be regarded as 
a British statute and to be interpreted as such a statute, 
that is, to give all its parts their natural sense when read in 
conjunction, and not to limit the interpretation of the whole 
by any theory of federal government. It is all the more 
important to lay stress on this principle, because exactly 
the opposite principle has, as we shall see, been accepted 
by the High Court of Australia for the interpretation of the 
Commonwealth Constitution, and the majority of that Court 
maintain their views despite the reasoned dissent of the 
Privy Council in the case of Webb v. Outtrim. It is charac- 
teristic that while that case has been disregarded by the 
majority of the High Court of the Commonwealth it has been 
followed in Canada, and has been used to upset the decisions 
often repeated in the Ontario Courts? and, by a curious 
irony of fate, quoted by the Chief Justice of the Common- 
wealth as being an accepted part of the law of Canada, that 
no municipal or provincial authority could tax the salary 
of a federal officer, as that would be to interfere with a federal 
instrumentality, a course forbidden, not indeed by the ex- 
press terms of the Act, but by the nature of a federation. 
But a federation which has a rigid constitution and is a 
sovereign power must be interpreted in a very different way 
from one which is a dependency, and in which, moreover, 
the federal government possesses what the federal power in 
the United States has not—the power of disallowing the 
Acts of the provinces. It is true that the Commonwealth 
Court has recognized the latter difference, and used that 
as their justification for disregarding the cases decided as 
regards Canada, on the ground that the Commonwealth 
[1907] A. C. 81, dissenting from I’ Emden v. Pedder, 1 C. L. R. 91, and 
Deakin v. Webb, 1 C. L. R. 585. For the rejection of the Privy Council's 
view, see 4 C. L. R. 1087 ; below, pp. 824 seq. For the general principles 
of interpretation, see Lefroy, Legislative Power tn Canada, pp- 21 seq. 
* Leprohon v. City of Ottawa, 40 U. C. Q. B. 478; 2 0. A. R. 522. As 
Lefroy, p. 671, pointed out, it was inconsistent with Bank of Toronto v. 
Lambe, 12 App. Cas. 575, and the Supreme Court reversed it in Abbott 
v. City of St. John, 40 S, C. R. 597. See also Lefroy, pp. xliii-lxx.