cuap, 11] THE COMMONWEALTH OF AUSTRALIA 931 
that case there was no referendum at all, in only one instance 
was a general election held, and the assent of the Parliaments 
was considered sufficient authority for the formation of the 
union of the provinces and the abandonment by the pro- 
vinces of their autonomy. In the case of Australia, on the 
other hand, as has been seen above, the greatest care was 
taken to secure the fullest consultation of the people. The 
Constitution was drafted by a convention elected by popular 
vote ; it was ratified by referenda in every Colony of the 
proposed Commonwealth. 
In the case of the Union of South Africa the model of 
Canada was followed as regards the Transvaal, the Orange 
River Colony, and the Cape ; affirmative votes of Parliament 
were there the acceptance of the new Constitution. In Natal 
matters were otherwise, for a considerable opposition de- 
veloped itself, and the Government decided that it would be 
advisable to have a poll, which was accordingly taken, with 
the somewhat unexpected result that the majority in favour 
of the acceptance of the Union was overwhelming. The 
figures were : for, 11,121; against, 3,701 ; majority, 7,420. 
(2) The ordinary Colony has full power to alter its Consti- 
tution, subject, in some cases, to certain formalities. This 
principle, however, obviously cannot be applied to cases of 
a federation proper; a federation is a quasi treaty, and to 
allow the federal authority to vary the Constitution would 
be unacceptable to the states which are federating. In the 
case of Canada so strongly is this recognized that the Consti- 
tution as a whole, and in particular the distribution of 
powers between the provinces and the Dominion, cannot be 
altered except by an Act of the Imperial Parliament, and 
no such Act, as was authoritatively stated in 1907, would be 
passed unless the Imperial Government were satisfied that 
1t was desired by not only the Federal Government, but also 
the Governments of the provinces concerned. The only 
alteration which substantially affects the provinces was 
made at the request of the federation and of all the provinces 
except British Columbia in 1907, when the federal subsidies 
were readjusted by 7 Edw. VII. c. 11. 
In the case of the Commonwealth of Australia it was 
desired by the framers of the Constitution, who based 
themselves somewhat exclusively upon United States 
models, that it should be in the power of the Commonwealth 
itself to alter its Constitution, and accordingly a clause was 
inserted in the Constitution for that purpose. The terms 
of the provision as embodied in s. 128 of the Commonwealth 
rh?