Reports SC 39 per Prendergast CJ at p.42. Subsequent cases have made clear that some degree of extra-territorial operation may well be necessary for the peace, order and good government of the dependent territory, for example, in relation to deportation (Attorney General for Canada v Cain [1906] AC 542 PC, a decision to the opposite effect to In re Gleich), or to the better enforcement of customs laws of the territory (Croft v Dunphy [1933] AC 156 Privy Council on appeal from Canada).

Cases in which statutes of dependent territories were held to be ultra vires because of their extra-territorial operation, and the absence of any sufficient connection with the good government of the territory, include

- Macleod v Attorney-General for New South Wales [1891] AC 455 PC concerning a bigamous marriage which took place in the USA.

- Royal Bank of Canada v R [1913] AC 283 PC in which the Province of Alberta had legislated in respect of a debt payable in the Province of Quebec.

- Johnson v Commissioner of Stamp Duties [1956] 1 All ER 502 in which the Privy Council held that a New South Wales statute (by which it was sought to impose death duties on a deceased's property outside that State on the basis that the deceased was domiciled in that State) was outside the powers of the New South Wales legislature.