Robert Garren, one of the framers of the Constitution provided the following legal advice to the Prime Minister in 1905 in respect of the annexation of Norfolk Island. The Island could apparently be made a territory under the control of the Commonwealth by the joint operation of an Imperial Order in Council and a Commonwealth Act. The effect of this would be that the Parliament could make laws for its government, and that it would be a dependency of the Commonwealth, not a part of the Commonwealth itself.
