Editing Commonwealth realm (section)

===Statute of Westminster 1931===
{{main|Statute of Westminster 1931}}

These new developments were explicitly codified in 1931 with the passage of the ''Statute of Westminster'', through which Canada, the Union of South Africa, and the Irish Free State all immediately obtained formal legislative independence from the UK, while in the other dominions adoption of the statute was subject to ratification by the dominion's parliament. Australia and New Zealand did so in 1942 and 1947, respectively, with the former's ratification back-dated to 1939, while Newfoundland never ratified the bill and reverted to direct British rule in 1934. As a result, the [[parliament at Westminster]] was unable to legislate for any dominion unless requested to do so,<ref name=Heard/> although the [[Judicial Committee of the Privy Council]] was left available as the last court of appeal for some dominions.<ref>{{cite book| last=Baker| first=Philip Noel| title=The Present Juridical Status of the British Dominions in International Law| publisher=Longmans| year=1929| location=London| page=231}}</ref> Specific attention was given in the statute's preamble to royal succession, outlining that no changes to that line could be made by the parliament of the United Kingdom or that of any dominion without the assent of all the other parliaments of the UK and dominions, an arrangement a justice of the Ontario Superior Court in 2003 likened to "a treaty among the Commonwealth countries to share the monarchy under the existing rules and not to change the rules without the agreement of all signatories".<ref>{{cite court| litigants =O'Donohue v. Canada| opinion=J. Rouleau| pinpoint=33| court=Ontario Superior Court of Justice| date=17 April 2013| url=http://www.canlii.org/en/on/onsc/doc/2003/2003canlii41404/2003canlii41404.html}}</ref>
[[File:King Edward VIII and Mrs Simpson on holiday in Yugoslavia, 1936.jpg|thumb|[[Edward VIII]] and [[Wallis Simpson]] in 1936. His proposal to marry her led to [[Edward VIII abdication crisis|his abdication]], an act that required the consent of the dominions.]]

This was all met with only minor trepidation, either before or at the time,{{NoteTag|P.E. Corbett in 1940 questioned whether there were any existing terms that could be used to describe any or all of the "possessions of the British Crown,"<ref name=corbett1/> while Scottish constitutional lawyer [[Arthur Berriedale Keith]] warned before 1930 that "the suggestion that the King can act directly on the advice of dominion ministers is a constitutional monstrosity, which would be fatal to the security of the position of the Crown".<ref>{{cite book| last=Keith| first=Arthur Berriedale| title=Responsible Government in the Dominions| publisher=Clarendon Press| year=1928| location=Oxford| page=xviii| volume=1| edition=2| isbn=978-0-665-82054-0}}</ref>|name=Anti}} and the government of the [[Irish Free State]] was confident that the relationship of these independent countries under the Crown would function as a [[personal union]],<ref name=murdoch1>{{cite journal| url = http://www.murdoch.edu.au/elaw/issues/v9n3/cox93.html | journal=Murdoch University Electronic Journal of Law | date=September 2002|title= Black v Chrétien: Suing a Minister of the Crown for Abuse of Power, Misfeasance in Public Office and Negligence| volume=9| issue=3| access-date=2 October 2008|url-status=dead|archive-url=https://web.archive.org/web/20030428063329/http://www.murdoch.edu.au/elaw/issues/v9n3/cox93.html|archive-date=28 April 2003|last1=Cox|first1=Noel}}</ref> akin to that which had earlier existed between the United Kingdom and [[Hanover]] (1801 to 1837), or between England and Scotland (1603 to 1707). Its first test came, though, with the [[abdication of King Edward VIII]] in 1936,<ref name=Heard/> for which it was necessary to gain the consent of the governments of all the dominions and the request and consent of the Canadian government, as well as separate legislation in South Africa and the Irish Free State, before the resignation could take place across the Commonwealth.<ref>{{cite book| last=Williams| first=Susan| year=2003| title=The People's King: The True Story of the Abdication| page=130| publisher=Penguin Books Ltd.| location=London| isbn=978-0-7139-9573-2}}</ref> At the height of the crisis, press in South Africa fretted about the Crown being the only thing holding the empire together and the bond would be weakened if Edward VIII continued "weakening kingship". Afterward, [[Francis Floud]], Britain's high commissioner to Canada, opined that the whole affair had strengthened the connections between the various nations; though, he felt the Crown could not suffer another shock.<ref name=Murphy29>{{citation| url=https://books.google.com/books?id=OkYXAgAAQBAJ&dq=%22commonwealth+realm%22&pg=PA29| last=Murphy| first=Philip| title=Monarchy and the End of Empire| pages=29–30| publisher=Oxford University Press| location=Oxford| year=2013| isbn=978-0-19-921423-5| accessdate=28 April 2023}}</ref> As the various legislative steps taken by the dominions resulted in Edward abdicating on different dates in different countries, this demonstrated the division of the Crown post-Statute of Westminster.<ref name=Murphy29/>

The civil division of the [[Court of Appeal of England and Wales]] later found in 1982 that the British parliament could have legislated for a dominion simply by including in any new law a clause claiming the dominion cabinet had requested and approved of the act, whether that was true or not.<ref>{{Cite court| litigants=Manuel et al. v. Attorney General| vol=822| pinpoint=p. 830| court=Court of Appeal of England and Wales| year=1982}}</ref> Further, the British parliament was not obliged to fulfil a dominion's request for legislative change. Regardless, in 1935 the British parliament refused to consider the result of the [[1933 Western Australian secession referendum]] without the approval of the Australian federal government or parliament. In 1937, the Appeal Division of the [[Supreme Court of South Africa]] ruled unanimously that a repeal of the ''Statute of Westminster'' in the United Kingdom would have no effect in South Africa, stating: "We cannot take this argument seriously. Freedom once conferred cannot be revoked."<ref>{{Cite court| litigants=Ndlwana v. Hofmeyer| vol=229| pinpoint=p. 237| court=Supreme Court of South Africa| year=1937}}</ref> Others in Canada upheld the same position.<ref name=Heard/>