smap. 1] THE UNION OF SOUTH AFRICA 973 
that to accomplish its ends it may deem that separate laws 
for each province are necessary. The Union Parliament 
can therefore legislate in any case on the same topics as the 
Provincial Councils, and such legislation is paramount (s. 86), 
and the Councils are at once placed in a hopeless state of 
inferiority as compared with the Canadian Provinces or 
the Australian States. It is true that the former, like the 
Councils, are liable to have their legislation disallowed on 
grounds of federal interest, but the provinces possess in 
many matters exclusive powers of legislation, and even if 
the Dominion can prevent their legislation having effect it 
cannot itself legislate on these topics. Struggles like that 
of Manitoba and the Dominion cannot conceivably occur 
between the Union and the provinces. The Australian 
States, again, are independent of the Commonwealth as 
regards the allowance or otherwise of their Acts, and the 
Commonwealth has as a rule only a definite sphere of 
legislative activity, the residuary legislative power belonging 
to the state, which maintains a right to legislate on almost 
every topic which falls within the power of the Common- 
wealth, though such legislation is superseded by Common- 
wealth legislation to the extent to which it is actually 
in conflict with such legislation. 
Further, the provinces have a more limited sphere of 
power than the Provinces of Canada or the States of Australia. 
The Canadian Provinces have exclusive powers in such 
important matters as the alteration of the Constitutions of 
the provinces, the management of public lands (though this 
privilege has been in part denied to Manitoba, Alberta, and 
Saskatchewan), the incorporation of provincial companies, 
the solemnization of marriage, the administration of justice, 
property and civil rights, &c. It is true that many of these 
matters may be delegated to the Provincial Councils or may 
be declared by the Governor in Council to be of a local or 
private nature, but for these powers the Councils are depen- 
dent on the goodwill of Parliament. Even the control of 
and the appointment of officers for provincial purposes is 
made subject to the rules laid down by Parliament, whereas