[BouriNor] A STUDY IN COMPARATIVE POLITICS 89 
and the influence of the American example is seen in the very language 
setting forth the powers of these judicial bodies—the “state” govern- 
ments are to have full jurisdiction over the “state” courts. The federal 
judges can be removed, as in Canada, only by successful impeachment in 
parliament and on address of the two houses to the governor-general in 
council, and as long as the present constitutions of the Australian colonies 
remain unchanged the “state” judges can be removed only by the action 
of the “state” parliament. The Canadian constitution in this respect 
appears to give greater security for an independent and stable judiciary, 
since a government operating on a large sphere of action is likely to make 
better appointments than a small and less influential body within the range 
of provincial jealousies, rivalries and faction. Indeed, it is not going too 
far to suppose that, with the progress of democratic ideas—already rife in 
Australia—we may have repeated the experience of the United States and 
elective judges make their appearance in “states” at some time when a 
wave of democracy has swept away all dictates of prudence and given 
unbridled licence to professional political managers only anxious for the 
success of party. 
As respects any amendment of the constitution after its adoption, the 
Australians have also copied the constitutional provision of the American 
republic—that whenever two-thirds of the houses of congress or of the 
several states shall deem amendment necessary, it will be submitted to a 
convention and form part of the constitution when ratified by the legis- 
latures or conventions of three-fourths of the states, as congress may deter- 
mine. The Australian bill permits an amendment to be proposed by the 
two houses of the parliament of the commonwealth, and then submitted 
to conventions of the several states ; but it must be ratified by conventions 
of a majority of the states, who represent a majority of the people of the 
federation, before it can be submitted to the governor-general for the 
queen’s assent. The Canadian constitution may be amended in any par- 
ticular, where power is not expressly given for that purpose to the parlia- 
ment or legislatures, by an address of the Canadian senate and commons 
to the queen—in other words, by the English parliament that enacted 
the original act of union—and without any reference whatever to the 
people voting at an election or assembled in a convention. Of course, it 
may be said that the reference to the imperial authorities will not be much 
of a restraint on amendment, inasmuch as it is not likely that a parliament, 
already overburdened by business, will show any desire to interfere with 
the expression of the wishes of the Canadian houses on a matter immedi- 
ately affecting the Canadians themselves. So far there have been only 
three amendments made by the imperial parliament to the British North 
America Act in twenty-seven years, and these were simply necessary to 
clear up doubts as to the powers of the Canadian houses. ‘This fact says 
much for the satisfactory operation of the Canadian constitution, as well 
