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Introduction Traditionally, State Parliaments have not been inhibited by the separation of powers doctrine.1 Indeed, State Parliaments have generally been considered to have plenary legislative power over Statecourts/ enabling them to confer non judicial functions on such courts. Although State legislative power is granted by State constitutions, in Kable v Director ofPublic Prosecutions (Kable),3 a High Court majority held that power was limited by the Commonwealth Constitution.4 Kable declared a New South WalesAct invalid because it conferred non judicial functions on the NSW Supreme Court which were incompatible with Chapter III of the Commonwealth Constitution.5 Kable's constraint represents a significant diminution of State legislative power. This paper examines the source and nature of the implication extrapolated from the Commonwealth Constitution in Kable.
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