Before proceeding to discuss how this statute was executed, it will be useful 
to mention certain determinations antecedent to this important pronouncement 
that serve to illustrate how the supremacy of Parliament was conceived. 
There was in the first place the provision of the Bill of Rights declaring void 
all dispensations of statutes and non obstantes. ls At the same session the proceedings 
of the Irish Parliament were similarly declared void, 16 and in 1690 
an act was passed reversing, annulling, and making void the judgment in the 
quo warranto against the city of London. 17 Apart from the general political 
significance of this sort of legislative interference with hitherto established 
executive right (viz., the non obstante) and the finality of judgments, these 
acts, being declarations of nullity respecting matter outside the normal control 
of Parliament, tended to promote ideas theretofore limited to judicial proceedings. 

The ninth section of the Act for Preventing Frauds was thus not an isolated 
instance of Parliamentary experimentation ls with nullification, but because it 
applied without exception to all the plantations and purported to fix a longterm 
future policy it was the most important. Seemingly the section was 
inserted at the suggestion of Chief Justice Holt, for he "was heard as to the 
laws interfering concerning navigation and offered a clause drawn by him 
to be added to the bill." 10 It is entirely possible that this clause is the one before 
us; for it was Holt who only a few years later expressed judicially 
approval of the doctrine of Bonham's Case that acts of Parliament were void 
which ran counter to basic common law principles. "An Act of Parliament," 
said he, "can do no wrong though it may do several things that look pretty 
odd; —for it may discharge one from his allegiance to the government he lives 
under and restore him to the state of nature; but it cannot make one that 
lives under a government Judge and Party." 20 What is, of course, apposite 
here is Holt's conception that given a basic legal rule, dispositions contrary 
thereto could be declared void. 21 
For our purposes it is the prevalence of such a conception which is important; 
the source of the basic rule is immaterial, for a single agency (viz., the 
King in Council) was exercising all types of supervisory enforcing authority 
and was concerned simply with the application of English standards to the 
acts of inferior jurisdictions. There is evidence of this viewpoint long before 
15 1 Wm. & M., 2 sess., c. 2, and compare 3 
Wm. & M., c. 2, s. 17 (Oath for Ireland) re 
dispensation by warrant or letters patent under 
the Great Seal of either England or Ireland. 
16 1 Wm. & M., 2 sess., c. 9. 
17 2 Wm. & M., 2 sess., c. 8. 
18 See also 6 Geo. I, c. 5, re appeals to the Irish 
House of Lords. 
19 2 Stock, Proceedings and Debates of the 
British Parliaments Respecting North America, 
170. 
20 City of London v. Wood (1701) (8 Mod. 
669, 687). 
21 See Holt's argument in East India Company 
v. Sandys that "if any law be made 
against any point of the Christian religion, that 
law is ipso facto void" (10 Howell, State 
Trials, 375).