analogy does not appear to have been presented in the conciliar argument, and it appears to us that affirmance was the result of the full impact of the various legal arguments presented of which the previous confirmation of the 1692 act was only a single though telling point. 258 The possible effect of the royal confirmation in Philips v. Savage can scarcely be appraised without some inquiry into the state of current doctrine respecting such confirmation, a subject which affords material for much interesting speculation. First let us inquire into the matter of the legal force of a confirmed colonial law. In 1703 the Board of Trade, considering monetary conditions in the plantations, questioned the Attorney General whether the Queen by proclamation could alter the rates of foreign coins in the plantations. In Massachusetts a rate higher than in other colonies prevailed by virtue of An Act for Ascertaining the Value of Coyns Currant within This Province, an act which had been confirmed by the Queen in Council. 259 Northey was of the opinion that the confirmation having been absolute the rate established would continue until repealed by another act of the General Assembly, "the passing of an act there with the absolute confirmation of Her Majesty having the force of an Act of Parliament made in England." 260 If Northey's position is correct, the Privy Council, had it declared the Massachusetts act null and void ab initio upon appeal, would have been declaring void an act having the force of a parliamentary enactment. And despite the statements in Bonham's or disaffirmed as unlawful by the law. The sole benefit which the corporation obtains by such allowance is, that they shall not incur the penalty of mentioned in the Act, if they put in use any ordinances which are against the King's prerogative, or the common profit of the people, etc." See also The Stationers in the City of London v. Salisbury (Comb. 221), where to the assertion of counsel that "this by-law was signed by die Lord Chancellor Finch," the court replied, " 'Tis never the better for that, for that is done of course. So we use to do in the circuits, but if the orders be not good, let the parties look to that at their peril." Compare Lord Ellesmere that "the true meaning of the statute of 19 H. 7 was that such ordinances made by corporations and allowed by the great judges of the realm should stand confirmed by Act of Parliament" (Observations on Lord Coke's Reports [n.d.], 12). Cf. Davenant v. Hurdis (Moore K.B. 576); Norris v. Staps (Hobart 210). - 5S Although counsel for the province was not heard, Wilks was of the opinion that without provincial intervention success would have been doubtful; as a private cause the appeal would not have been as well attended or considered (52 MS Mass. Archives [Letters, 1724-38], 465). Wilks had been with "most of the Lords that attended the Council that night and apprized them of the consequence and engaged their attendance. My Lord President was pleased not to appoint the hearing till my Lord Chancellor could attend." 259 CSP, Col., 1702-3, #656. For the act see 1 Acts and Res. Prov. Mass. Bay, 296. 260 CSP, Col., 1702-3, #765. Solicitor General Raymond also stated later that acts of colonial assemblies were "of the same effect there, as an Act of Parliament here" (ibid., 1712-14, #457). Cf. the statement of Holt, C. J., that "every by-law is a law, and as obligatory to all persons bound by it, that is, within its jurisdiction, as any Act of Parliament, only with dris difference, that a by-law is liable to have its validity brought in question, but an Act of Parliament is not; but when a by-law is once adjudged to be a good and reasonable by-law, it is to all intents as binding to drose that it extends to as an Act of Parliament can be" (City of London v. Wood [12 Mod. 669, 678]). Perhaps the