CHAP, 1] THE DOMINION OF CANADA 735
that up to 1878 inclusive, out of 4,606 Acts passed by the
seven provinces existing up to that date there had been
disallowed only three in Ontario, two in Quebec, four in
Nova Scotia, six in Manitoba, and twelve in British
Columbia, while in Prince Edward Island and in New
Brunswick no Acts had been disallowed. The proportion
did not, however, diminish after that date, and in one
respect it may be said to have been substantially increased,
for it is in the administration of Sir John Macdonald that
we find the clearest examples of the interference by the
Dominion with Provincial Acts simply because they transgressed
 Dominion policy : with the advent of the Ministry
of Sir Wilfrid Laurier, which was returned to power, for
One reason among others, owing to the attempt of the Con-Servative
 Government to coerce the Province of Manitoba,
the practice of disallowing Acts on other than legal and
constitutional grounds, or on grounds of wide public and
Imperial policy, may be said to have come almost to a stop.
Some of the cases of the exercise of the power have been
proved subsequently to have been based on quite inadequate
legal grounds ; for example, the absurd doctrine of the Provincial
 Legislature as a municipal council resulted in the
disallowance of the Act of Ontario to define its privileges
ln 1868-9. The law officers of the Crown in England shared
0. the opinion as to that Act being wlira vires, and it was
disallowed. But a Quebec Act of 1870 was not disallowed,
and a subsequent Act of Ontario in 1876 was allowed to
stand as being at any rate, if invalid, open to being overruled
 by the Courts, and in 1878 a decision in the Supreme
Court of Canada! incidentally affirmed the legitimacy of such
Acts. Cases of similar action regarding the pardon power
and the executive government have been seen above.? This
Principle of leaving to the Courts the decision of such cases was

Teserved and not assented to, 6 in Quebec, 2 in Nova Scotia (one assented
L), 4 in New Brunswick (all assented to), 14 in Manitoba (5 assented to),
0 in British Columbia (5 assented to), and 5 in Prince Edward Island
(3 assented to). Landers v. Woodworth, 2 8. C. R. 158. at p. 192.
* Cf. Biggar. Sir Oliver Mowat. ii. 509 sed.