736 THE FEDERATIONS AND THE UNION [PART IV 
adopted by the Dominion in 1871 in the famous case of the 
Ontario Goodhue Estate Act of that year to confirm and 
validate the settlement of property under a will, but at 
variance with the intention of the testator. The Act was 
petitioned against, but the Dominion left it to operate, 
though the Ontario Court of Error and Appeal decided later 
that it was, though not wlirg vires, inoperative on account of 
the defects and omissions of its drafting! In 1876 also they 
consented to leave in operation the excellent Act (c. 28) passed 
by the Province of Manitoba in that year to get rid of the need- 
less and useless Second Chamber which the Dominion Parlia- 
ment had created for it in 1870. The Lieutenant-Governor 
pointed out what he thought legal and other objections to 
it, arising from the curious wording of the Imperial Act of 
1871, but the Dominion Government were then of opinion 
that it would be contrary to the spirit in which the power of 
disallowance had been exercised to interfere with the opera- 
tion of the Act. They suggested, however, that it would be 
for the Legislature of Manitoba, if necessary, to petition the 
Crown for the validation of the Act by Imperial legislation. 
This was not done, nor does it seem to have been necessary, 
and in 1891 (c. 9) New Brunswick, and in 1893 (c. 21) Prince 
Edward Island removed their second Houses, though in the 
case of the latter province, in which the Second Chamber had 
been since 1862 elective, a compromise was made by which 
half the members were elected on a property basis, and half 
not. In 1892 a similar Bill was reserved and not assented to, 
because on principle it should not have been reserved. During 
the same period the Courts of Canada declared the powers of 
the legislatures absolute as to choice of methods within 
their own province,® and the Supreme Court of the Dominion 
actually laid it down in a judgement 4 that the assertion of 
19 Gr. 366; 1 Cart. 560. 
* Canada Sess. Pap., 1877, No. 89, pp. 148-51, 
* Cf. re Goodhue, 19 Gr., at pp. 386 (per Draper C.J.), 418 (per Spragge C.), 
152 (per Strong V.C.); Cowan v. Wright, 23 Gr., at P. 623 (per Blake V.C.), 
and see 4 0. A. R., at p. 100; 28. C. RB. 70, at p. 81. 
* Severn v. The Queen, 28. C. R. 70, at Pp- 96 (per Richards C.J.), 131 (per 
Fournier J.). Cf. Canada House of Commons Debates, 1889, pp. 822. 823.