We have spoken of these episodes chiefly to complete our record of conciliar 
activity, but they may be said also to possess some significance regarding the 
Council's conception of its powers of nullification. Apparently none of these 
cases involved a conflict with an act of Parliament extending to the Channel 
Islands, and the vacating of the acts was consequently an exercise of prerogative. 
Such a course would not have been prudent for dealings with the 
dominions farther overseas. Hence we find that numerous provincial statutes 
which were viewed as contrary to the laws of England were merely disallowed 
and not declared null and void ab initio. s<is In certain instances, it is true, 
there was no conflict with the provisions of 7 & 8 Wm. 111, c. 22, or later acts of 
Parliament extending to the plantations, 360 but there are other cases in which 
such repugnancy existed, yet the colonial acts were merely disallowed. 370 
368 Acts disallowed as contrary or repugnant 
to the "laws of England" are to be found in 
the case of the Leeward Islands (CSP, Col., 
1701, #816; 2 APC, Col., p. 846), New 
York (CSP, Col., 1702-3, #100; 2 APC, 
Col, p. 850), New Hampshire (CSP, Col, 
1706-8, #369), Pennsylvania (2 Stat, at 
Large Pa., 524-25, 529-30; 5 APC, Col, 
#298) and Virginia (4 ibid., #155). A South 
Carolina act was disallowed as "repugnant 
to the common law of England" (3 ibid., 
#285). A New Hampshire act disallowed in 
1764 was termed "contrary to law" (4 ibid., 
#560 [Act #s]). Colonial acts disallowed 
as contrary or repugnant to acts of Parliament 
are found for Jamaica (4 ibid., $422), Massachusetts 
(2 ibid., p. 843; 1 Acts and Res. Prov. 
Mass. Bay, 287), New Hampshire (5 APC, 
Col, #82), New Jersey (3 ibid., p. 849; CSP, 
Col, 1732, #134; 5 APC, Col, #116), New 
York (3 ibid., #304), Pennsylvania (3 Stat, at 
Large Pa., 439-40, 465), Prince Edward Island 
(5 APC, Col, #327), South Carolina (5 ibid., 
#202), Virginia (CSP, Col, 1716-17, #610, 
625, 687; 3 APC, Col, #171), West Florida 
(5 ibid., #228). In other cases the repugnancy 
appears to have been measured against a vaguer 
standard. Disallowances reached acts "contrary 
to the spirit" of acts of Parliament in the case 
of Nova Scoda (5 ibid., #63) and Virginia 
(5 ibid., #83, 247). A Virginia act concerning 
servants and slaves was disallowed as "contrary 
to the design of the laws of tills Kingdom 
relating to felons" (4 ibid., p. 140). A North 
Carolina act was disallowed as "contrary to the 
spirit and principle of the British laws" (5 ibid., 
p. 38). A Bahamas act suffered disallowance as 
"contrary to the principles of the English laws" 
(5 ibid., #281). A disallowed New York act 
was termed "contrary to the genius of the laws 
of this country" (5 ibid., #299). Natural law 
philosophy raises its head in the disallowance 
of a Montserrat act as "contrary to the principles 
of natural justice" (5 ibid., $196). 
In some cases instead of "repugnant" or "contrary" 
we find "inconsistent," "not conformable," 
or "not agreeable." Whether the latter 
phrases were regarded as equivalent to the 
former does not appear. Acts were disallowed 
as not conformable to acts of Parliament in 
New Hampshire (CSP, Col., 1700, #825; 2 
APC, Col., p. 846), New Jersey (5 ibid., #80), 
and Virginia (3 ibid., #245). A disallowed 
Georgia act was termed "not conformable to 
the laws of this kingdom" (4 ibid., p. 407). A 
Nordi Carolina act met disallowance as hot 
consonant to reason or agreeable to the laws 
and customs of England (2 ibid., p. 832; CSP, 
Col., 1706-8, #1189). A Georgia act "inconsistent 
with the principles of justice" (4 APC, 
Col., #379) and a West Florida act "little conformable 
to the British principles of justice" 
(5 ibid., #193) were disallowed. 
The phrase "consonant to reason" seems to 
have been the equivalent of "not repugnant or 
contrary to the laws of England"; see Charter 
and Laws Prop. Pa., 84. Acts were disallowed 
as unreasonable inter alia in Pennsylvania (2 
Stat, at Large Pa., 449, 495-97), Massachusetts 
(1 Acts and Res. Prov. Mass. Bay, 316-22), 
New Hampshire (4 APC, Col., #560 [Acts 
#12, 15]), and North Carolina (4 ibid., #59, 
465). 
3G9 g ee su p ra> p. j 2 6. 
370 See a 1697 Massachusetts act for establishing 
courts which was "looked upon to be 
directly contrary to the intention" of 7 and 8 
William 111, c. 22 (1 Acts and Res. Prov. Mass.