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The Crown

April 21, 2023

This article is about the term referring to the state in some nations. For the television series, see The Crown (TV series). For other uses, see Crown (disambiguation).

The crown is the state in all its aspects within the jurisprudence of the Commonwealth realms and their subdivisions (such as the Crown Dependencies, overseas territories, provinces, or states).[1] The term can be used to refer to the office of the monarch or the monarchy as institutions, to the rule of law, or to the functions of executive (the crown-in-council), legislative (the crown-in-parliament), and judicial (the crown on the bench) governance and the civil service.[2]

The image of a crown is included in the coat of arms of New Zealand, and located atop the escutcheon, to symbolize the New Zealand Crown as the institution from which all state authority flows.

The concept of the crown as a corporation sole developed first in England as a separation of the physical crown and property of the kingdom from the person and personal property of the monarch. It spread through English and later British colonisation and is now rooted in the legal lexicon of all 15 Commonwealth realms, their various dependencies, and states in free association with them. It is not to be confused with any physical crown, such as those of the British regalia.[3]

The term is also found in various expressions such as crown land, which some countries refer to as public land or state land; as well as in some offices, such as minister of the crown, crown attorney, and crown prosecutor.

Definition

The term the crown does not have a single definition. Legal scholars Maurice Sunkin and Sebastian Payne opined, "the nature of the crown has been taken for granted, in part because it is fundamental and, in part, because many academics have no idea what the term the crown amounts to".[4] Nicholas Browne-Wilkinson theorised that the crown is "an amorphous, abstract concept" and, thus, "impossible to define",[5] while William Wade stated the crown "means simply the Queen".[6] The Lord Simon of Glaisdale stated, "the crown is a piece of bejewelled headgear under guard at the Tower of London; but, one that symbolises the powers of government, which were formerly wielded by the wearer of the crown".[5] The Lord Diplock suggested the crown means "the government [and] all of the ministers and parliamentary secretaries under whose direction the administrative work of the government is carried out by the civil servants employed in the various government departments."[5] This interpretation was supported by Section 8 of the Pensions (Colonial Service) Act 1887, which set the terms "permanent civil service of the state", "permanent civil service of Her Majesty" and "permanent civil service of the Crown" as having the same meaning.[7]

Concept

 
Rideau Hall in Ottawa, Ontario; held in perpetuity by the Canadian monarch, presently Charles III
 
Balmoral Castle in Aberdeenshire, Scotland; the personal property of Charles III

The concept of the crown took form under the feudal system.[8] Though not used this way in all countries that had this system, in England, all rights and privileges were ultimately bestowed by the ruler. Land, for instance, was granted by the Crown to lords in exchange for feudal services and they, in turn, granted the land to lesser lords. One exception to this was common socage: owners of land held as socage held it subject only to the crown. When such lands become ownerless, they are said to escheat; i.e. return to direct ownership of the crown (crown lands). Bona vacantia is the royal prerogative by which unowned property, primarily unclaimed inheritances, becomes the property of the crown.[n 1][9]

As such, the physical crown and the property belonging to successive monarchs in perpetuity came to be separated from the person of the monarch and his or her personal property. After several centuries of the monarch personally exercising supreme legislative, executive, and judicial power, these functions decreased as parliaments, ministries, and courts grew through the 13th century.[10] The term the crown then developed into a means by which to differentiate the sovereign's official functions from his personal choices and actions.[11]

When the kingdom of England merged with those of Scotland and Ireland, the concept extended into the legal lexicons of the United Kingdom and its dependencies and overseas territories and, eventually, all of the independent Commonwealth realms. There are, thus, now many distinct crowns, as a legal concept, "worn by"—or many different offices of monarch occupied by—one person as sovereign of each country. However, the Crown can also mean the international institution shared by all 15 Commonwealth realms.[11]

 
King Charles III, the living embodiment of the crown in each of the Commonwealth realms

Given that, in each realm, and at its broadest, the crown now means the government or the polity known as the state and the monarch, in all realms, is the living embodiment of the crown,[12] the sovereign is regarded as the personification of the state.[n 2][26] The body of the reigning sovereign thus holds two distinct personas in constant coexistence: that of a natural-born human being and that of the state as accorded to him or her through law. The crown and the monarch are "conceptually divisible but legally indivisible [...] The office cannot exist without the office-holder".[n 3][28] The terms the state, the Crown,[29] the Crown in Right of [jurisdiction], His Majesty the King in Right of [jurisdiction],[30] and similar, are all synonymous and the monarch's legal personality is sometimes referred to simply as the relevant jurisdiction's name.[19][31] (In countries using systems of government derived from Roman civil law, the state is the equivalent concept to the crown.[32]) However, the terms the sovereign or monarch and the crown, though related, have different meanings: The crown includes both the monarch and the government. The institution and powers of the crown are vested in the king, but, generally, its functions are exercised in the sovereign's name by ministers of the crown drawn from and responsible to the elected chamber of parliament.[11]

Still, the king or queen is the employer of all government officials and staff (including the viceroys, judges, members of the armed forces, police officers, and parliamentarians),[n 4] the guardian of foster children (crown wards), as well as the owner of all state lands (crown land), buildings and equipment (crown-held property),[34] state-owned companies (crown corporations), and the copyright for government publications (crown copyright).[35] This is all in his or her position as sovereign, not as an individual; all such property is held by the crown in perpetuity and cannot be sold by the sovereign without the proper advice and consent of his or her relevant ministers.

 
The mace of the Parliament of Queensland, symbolising the power of the Australian Crown-in-Parliament

The crown also represents the legal embodiment of executive, legislative, and judicial governance. While the crown's legal personality is usually regarded as a corporation sole,[36] it can, at least for some purposes, be described as a corporation aggregate headed by the monarch.[37][38] Frederic William Maitland argued the crown in the UK is a corporation aggregate embracing the government and the "whole political community".[39] J.G. Allen preferred to view the crown as a corporation sole; one office occupied by a single person, enduring "through generations of incumbents and, historically, lends coherence to a network of other institutions of a similar nature."[40] Canadian academic Philippe Lagassé found the crown "acts in various capacities, as such: crown-in-council (executive); crown-in-parliament (legislative); crown-in-court (judicial). It is also an artificial person and office as a corporation sole. At its most basic, 'the crown' is in the UK what is most other countries is 'the state'."[41]

Divisibility of the crown

Further information: Commonwealth realm § The Crown in the Commonwealth realms
Further information: Monarchy in the Canadian provinces

Historically, the crown was considered to be indivisible.[42] Two judgments—Ex parte Indian Association of Alberta (EWCA, 1982) and Ex parte Quark (House of Lords, 2005)—challenged that view. Today, the crown is considered separate in every country, province, state, or territory, regardless of its degree of independence, that has the shared monarch as part of the respective country's government; though, limitations on the power of the monarch in right of each territory vary according to relevant laws, thus making the difference between full sovereignty, semi-sovereignty, dependency, etc. The Lords of Appeal wrote, "the Queen is as much the Queen of New South Wales and Mauritius and other territories acknowledging her as head of state as she is of England and Wales, Scotland, Northern Ireland, or the United Kingdom."[43]

The crown in each of the Commonwealth realms is a similar, but separate, legal concept. To distinguish the institution's role in one jurisdiction from its place in another, Commonwealth law employs the expression the Crown in Right of [place]; for example, the Crown in Right of the United Kingdom,[48] the Crown in Right of Canada, the Crown in Right of the Commonwealth of Australia, etc. Because both Canada and Australia are federations, there are also crowns in right of each Canadian province and each Australian state.[49] When referring to the Crown in multiple jurisdictions, wording is typically akin to "the Crown in right of [place], and all its other capacities".[50]

The powers of a realm's crown are exercised either by the monarch, personally, or by his or her representative on the advice of the appropriate local ministers, legislature, or judges, none of which may advise the crown in any other realm.

 
Elizabeth II, Queen of Canada, with her Cabinet in Rideau Hall, 1 July 1967
 
Elizabeth II, Queen of New Zealand, with her Cabinet, 1981
 
Governor-General Bill Hayden, representing Elizabeth II, Queen of Australia, with Cabinet outside Government House, 25 March 1994
 
Elizabeth II, Queen of the United Kingdom, with her Cabinet at 10 Downing Street, 18 December 2012
Queen Elizabeth II in her various capacities as sovereign of differnt countries, demonstrating the divisibility of the crown

New Zealand

In New Zealand, the term the Crown (Māori: te Karauna[51]) is used to mostly mean the authority of government; its meaning changes in different contexts.[52][53] In the context of people considering Treaty of Waitangi claims, professor of history Alan Ward defines the Crown as "the people of New Zealand—including Māori themselves—acted through elected parliament and government."[54]

Crown Dependencies

In the Bailiwick of Guernsey, legislation refers to the Crown in Right of the Bailiwick of Guernsey[55] or the Crown in Right of the Bailiwick[56] and the law officers of the Crown of Guernsey submitted that, "the Crown in this context ordinarily means the Crown in right of the république of the Bailiwick of Guernsey"[57] and that this comprises "the collective governmental and civic institutions, established by and under the authority of the monarch, for the governance of these islands, including the states of Guernsey and legislatures in the other islands, the royal court and other courts, the lieutenant governor, parish authorities, and the Crown acting in and through the Privy Council".[58]

 
The flag of Jersey, displaying the badge of Jersey surmounted by a Plantagenet crown

In the Bailiwick of Jersey, statements by the law officers of the Crown define the Crown's operation in that jurisdiction as the Crown in Right of Jersey,[59] with all Crown land in the Bailiwick of Jersey belonging to the Crown in Right of Jersey and not to the Crown Estate of the United Kingdom.[60] The Succession to the Crown (Jersey) Law 2013 defined the Crown, for the purposes of implementing the Perth Agreement in Jersey law, as the Crown in Right of the Bailiwick of Jersey.[61]

Legislation in the Isle of Man also defines the Crown in Right of the Isle of Man as being separate from the Crown in Right of the United Kingdom.[62]

British Overseas Territories

Following the Lords' decision in Ex parte Quark, 2005, it is held that the King, in exercising his authority over British Overseas Territories, does not act on the advice of the Cabinet of the United Kingdom, but, in his role as king of each territory, with the exception of fulfilling the UK's international responsibilities for its territories. To comply with the court's decision, the territorial governors now act on the advice of each territory's executive and the UK government can no longer disallow legislation passed by territorial legislatures.[63]

In the courts

In criminal proceedings, the state is the prosecuting party; the case is usually designated as R v [defendant],[64] where R can stand for either rex (if the current monarch is male) or regina (if the monarch is female). For example, a criminal case against Smith might be referred to as R v Smith and verbally read as "the crown against Smith".

The crown is, in general, immune to prosecution and civil lawsuits. So, R is rarely (albeit sometimes[n 5]) seen on the right hand side of the 'v' in the first instance. To pursue a case against alleged unlawful activity by the government, a case in judicial review is brought by the crown against a minister on the application of a claimant. The titles of these cases now follow the pattern of R (on the application of [X]) v [Y]", notated as R ([X]) v [Y], for short. Thus, R (Miller) v Secretary of State for Exiting the European Union is R (on the application of Miller and other) v Secretary of State for Exiting the European Union, where "Miller" is Gina Miller, a citizen. Until the end of the 20th century, such case titles used the pattern R v Secretary of State for Exiting the European Union, ex parte Miller. Either form may be abbreviated R (Miller) v Secretary of State for Exiting the European Union.

In Scotland, criminal prosecutions are undertaken by the lord advocate (or the relevant procurator fiscal) in the name of the Crown. Accordingly, the abbreviation HMA is used in the High Court of Justiciary for His/Her Majesty's Advocate, in place of rex or regina; as in, HMA v Al Megrahi and Fahima.

Most jurisdictions in Australia use R or the king (or the queen) in criminal cases. If the Crown is the respondent to an appeal, the words the king will be spelled out, instead of using the abbreviation R (i.e. the case name at trial would be R v Smith; if the defendant appeals against the Crown, the case name would be Smith v the King). In Western Australia and Tasmania, prosecutions will be brought in the name of the respective state instead of the Crown (e.g. the State of Western Australia v Smith). Victorian trials in the original jurisdiction will be brought in the name of the director of public prosecutions. The Commonwealth director of public prosecutions may choose which name to bring the proceeding in. Judges usually refer to the prosecuting party as simply "the prosecution" in the text of judgments. In civil cases where the Crown is a party, it is a customary to list the body politic (e.g. State of Queensland or Commonwealth of Australia) or the appropriate government minister as the party, instead. When a case is announced in court, the clerk or bailiff may refer to the Crown orally as our sovereign lord the king (or our sovereign lady the queen).

In reporting on court proceedings in New Zealand, news reports will refer to the prosecuting lawyer (often called a Crown prosecutor, as in Canada and the United Kingdom) as representing the Crown; usages such as, "for the Crown, Joe Bloggs argued," being common.

The crown can also be a plaintiff or defendant in civil actions to which the government of the Commonwealth realm in question is a party. Such crown proceedings are often subject to specific rules and limitations, such as the enforcement of judgments against the crown. Qui tam lawsuits on behalf of the crown were once common, but have been unusual since the Common Informers Act 1951 ended the practice of allowing such suits by common informers.

See also

Further reading

  • Sunkin, Maurice; Payne, Sebastian, eds. (1999). The Nature of the Crown: A Legal and Political Analysis. Oxford University Press. doi:10.1093/acprof:oso/9780198262732.001.0001. ISBN 9780198262732.

Notes

  1. ^ Jurisdictions in which this prerogative does not apply include Cornwall, where unowned property becomes the property of the duke of Cornwall, and Lancashire, where it becomes the property of the duke of Lancaster.
  2. ^ In the Canadian context, the monarch has been described by Eugene Forsey as the "symbolic embodiment of the people—not a particular group or interest or party, but the people; the whole people";[13] his daughter, Helen Forsey, said of his opinion on the crown, "for him, the essence of the monarchy was its impartial representation of the common interests of the citizenry as a whole, as opposed to those of any particular government."[13] The Department of Canadian Heritage said the Crown serves as the "personal symbol of allegiance, unity, and authority for all Canadians,"[14][15] a concept akin to that expressed by King Louis XIV: "L'État, c'est moi", or, "I am the state".[16] Robertson Davies stated in 1994, "the Crown is the consecrated spirit of Canada",[17] and past Ontario chairman of the Monarchist League of Canada Gary Toffoli opined, "the Queen is the legal embodiment of the state at both the national and the provincial levels [...] She is our sovereign and it is the role of the Queen, recognized by the constitutional law of Canada, to embody the state."[18]
  3. ^ As Peter Boyce put it, "the Crown as a concept cannot be disentangled from the person of the monarch, but standard reference to the Crown extends well beyond the Queen's person."[27]
  4. ^ The Supreme Court found in the 1980 case Attorney General of Quebec v. Labrecque that civil servants in Canada are not contracted by an abstraction called the state, but, rather, they are employed by the monarch, who "enjoys a general capacity to contract in accordance with the rule of ordinary law."[33]
  5. ^ For exceptions in the United Kingdom, see Crown Proceedings Act 1947.

References

  1. ^ Jackson, Michael D. (2013), The Crown and Canadian Federalism, ISBN 978-1-4597-0989-8
  2. ^ Carroll, Alex (2003). Constitutional and Administrative Law. Pearson/Longman. p. 7. ISBN 978-0-582-47343-0.
  3. ^ CharlotteDunn (4 June 2018). "Crown Dependencies". The Royal Family. Retrieved 1 September 2021.
  4. ^ Sunkin, Maurice; Payne, Sebastian (1999), The Nature of the Crown: A Legal and Political Analysis, Oxford: Oxford University Press
  5. ^ a b c Town Investments v Department for the Environment, Lord Morris of Borth-y-Gest, Lord Simon of Glaisdale, Lord Kilbrandon, Lord Edmund-Davies, 359 (House of Lords 1978).
  6. ^ Wade, William, "The Crown, Ministers, and Officials: Legal Status and Liability", in Sunkin, M.; Payne, S. (eds.), The Nature of the Crown, p. 24
  7. ^ Torrance 2023, pp. 9–10
  8. ^ Maitland, Frederic (1901). "The Crown as Corporation". Law Quarterly Review (17): 131–46.
  9. ^ Nguyen, Nam H. (18 March 2018). Essential 25000 English-Cebuano Law Dictionary. Nam H Nguyen.
  10. ^ Torrance, David (11 January 2023), The Crown and the Constitution (PDF), House of Commons Library, p. 8, retrieved 1 March 2023
  11. ^ a b c Torrance 2023, p. 7
  12. ^ Elizabeth II (2005), "46.1.b", Interpretation Act, Ottawa: Queen's Printer for Canada (published 1 April 2005), retrieved 7 August 2009
  13. ^ a b Forsey, Helen (1 October 2010). "As David Johnson Enters Rideau Hall..." The Monitor. Ottawa: Canadian Centre for Policy Alternatives. Retrieved 23 January 2011.
  14. ^ Department of Canadian Heritage, Ceremonial and Canadian Symbols Promotion > The crown in Canada, Queen's Printer for Canada, retrieved 19 February 2009
  15. ^ Department of Canadian Heritage (2010), Canada: Symbols of Canada (PDF), Ottawa: Queen's Printer for Canada, p. 3, retrieved 4 December 2016
  16. ^ Derwyn, Shea (10 April 1996), , Committee Transcripts: Standing Committee on the Legislative Assembly, Toronto: Queen's Printer for Ontario, archived from the original on 11 June 2011, retrieved 16 May 2009
  17. ^ Davies, Robertson (8 August 1996). Hunting Stuart and The Voice of the People. Toronto: Simon & Pierre. ISBN 978-0-88924-259-3.
  18. ^ Toffoli, Gary (10 April 1996), , Committee Transcripts: Standing Committee on the Legislative Assembly, Toronto: Queen's Printer for Ontario, archived from the original on 11 June 2011, retrieved 16 May 2009
  19. ^ a b Table Research Branch of the House of Commons (March 2008). "Compendium of Procedure" (PDF). Ottawa: Queen's Printer for Canada. p. 1. Archived (PDF) from the original on 28 October 2006. Retrieved 14 October 2009.
  20. ^ Cabinet Secretary and Clerk of the Executive Council (April 2004), Executive Government Processes and Procedures in Saskatchewan: A Procedures Manual (PDF), Regina: Queen's Printer for Saskatchewan, p. 10, retrieved 30 July 2009
  21. ^ The Royal Household, The Queen and the Commonwealth > Queen and Canada > The Queen's role in Canada, Queen's Printer, retrieved 15 May 2009
  22. ^ MacLeod, Kevin S. (2012), (PDF) (2 ed.), Ottawa: Queen's Printer for Canada, p. 51, ISBN 978-0-662-46012-1, archived from the original (PDF) on 4 February 2016, retrieved 28 November 2012
  23. ^ Marleau, Robert; Montpetit, Camille (2000), "1. Parliamentary Institutions > Institutional Framework > The Crown", , Ottawa: Queen's Printer for Canada, ISBN 2-89461-378-4, archived from the original on 8 October 2012
  24. ^ Citizenship and Immigration Canada (2009), Discover Canada (PDF), Ottawa: Queen's Printer for Canada, p. 2, ISBN 978-1-100-12739-2, retrieved 3 December 2009
  25. ^ Tidridge, Nathan (2011), Canada's Constitutional Monarchy: An Introduction to Our Form of Government, Toronto: Dundurn Press, p. 17, ISBN 9781459700840
  26. ^ [19][20][21][22][23][24][25]
  27. ^ Boyce, Peter John (2008a), The Queen's Other Realms: The Crown and Its Legacy in Australia, Canada and New Zealand, Sydney: Federation Press, p. 81, ISBN 978-1-86287-700-9
  28. ^ Bowden, James; Philippe, Lagassé (6 December 2012), "Succeeding to the Canadian throne", Ottawa Citizen, archived from the original on 10 January 2013, retrieved 6 December 2012
  29. ^ Elizabeth II (9 October 2012), "83.1", Financial Administration Act, Queen's Printer for Canada, retrieved 6 December 2012
  30. ^ Elizabeth II (21 May 2004). "Memorandum for Understanding of Cooperation on Addressing Climate Change" (PDF). Toronto: Queen's Printer for Canada. p. 1. Retrieved 16 May 2009.
  31. ^ Elizabeth II (2004). (PDF). 1. Ottawa: Assembly of First Nations. p. 3. Archived from the original (PDF) on 6 October 2005. Retrieved 29 September 2009.
  32. ^ Jackson, Michael D. (2013), The Crown and Canadian Federalism, Toronto: Dundurn Press, p. 20, ISBN 978-1-4597-0989-8
  33. ^ Smith, David E. (1995), The Invisible Crown, Toronto: University of Toronto Press, p. 79, ISBN 0-8020-7793-5
  34. ^ Department of National Defence. . Queen's Printer for Canada. Archived from the original on 28 August 2009. Retrieved 16 May 2009.
  35. ^ (PDF) (Map). Queen's Printer for Canada. 2006. Archived from the original (PDF) on 26 March 2009. Retrieved 16 May 2009.
  36. ^ George V (9 April 1925), "s. 180", Law of Property Act 1925, London: King's Printer
  37. ^ Maitland, Frederic (1901), "The Crown as Corporation", Law Quarterly Review (17): 131–46
  38. ^ The Law Commission (November 1996), "Paper 143: The execution of deeds and documents by or on behalf of bodies corporate" (PDF), Halsbury's Laws of England (Affidavit) (4 ed.), Lincoln County, Nevada (published 1974), 9, 1206
  39. ^ Maitland, Frederic William (1908), The Constitutional History of England, Cambridge: Cambridge University Press, p. 418
  40. ^ Allen, J.G. (July 2018), "The Office of the Crown", Cambridge Law Journal, Cambridge, 77 (2): 300, doi:10.1017/S0008197318000338, S2CID 149843556
  41. ^ Lagassé, Philippe (2 November 2021), The State, The Crown, and Parliament, lecture given at Carleton University, Ottawa
  42. ^ Saunders, Cheryl (2015). "The Concept of the Crown". Melbourne University Law Review. 38: 883.
  43. ^ Lords of Appeal, Ex parte Quark, 2005
  44. ^ Lauterpacht, E.; Greenwood, C. J. (1992). International Law Reports. Vol. 87. Cambridge: Cambridge University Press. pp. 286, 713. ISBN 978-0-949009-99-9.
  45. ^ Royal Institute of International Affairs (1983). The British Year Book of International Law. Vol. 53. British Institute of International Affairs. Oxford: H. Frowde. pp. 253, 257, 258.
  46. ^ Bourne, C.B. (1986). Canadian Yearbook of International Law. Vol. 23. Vancouver: UBC Press. ISBN 978-0-7748-0259-8.
  47. ^ The Australian law journal. Vol. 52. North Ryde: Law Book Co. of Australasia Ltd. 1978. pp. 58, 203, 207. 3910867.
  48. ^ [44][45][46][47]
  49. ^ Ministry of Natural Resources (24 January 2006), Disposition of Public Land to Other Governments and Agencies (PDF), Toronto: Queen's Printer for Ontario, p. 2, at 3.2.B, retrieved 25 April 2010, When public land is required by the federal government or one of its departments, or any provincial ministry, the land itself is not transferred. What is transferred is the responsibility to manage the lands on behalf of Her Majesty the Queen (HMQ). This is accomplished by an Order-in-Council or a Minister's Order that transfers management of land either from HMQ in right of Ontario to HMQ in right of Canada as represented by a department or to HMQ in right of Ontario as represented by another ministry. The Crown does not transfer ownership to itself.
  50. ^ Clayton Utz. . Clayton Utz. Archived from the original on 14 July 2022. Retrieved 14 April 2023.
  51. ^ "Karauna". Te Aka Māori Dictionary. Retrieved 20 January 2023.
  52. ^ Shore, Cris; Kawharu, Margaret (17 June 2014). "Thr Crown in New Zealand: Anthropological Perspectives on an Imagined Sovereign". Sites: A Journal of Social Anthropology and Cultural Studies. 11 (1): 17–38. doi:10.11157/sites-vol11iss1id267. ISSN 1179-0237.
  53. ^ "Definition of 'the Crown' a difficult matter". New Zealand Law Society | Te Kāhui Ture o Aotearoa. 15 November 2019. Retrieved 12 May 2021.
  54. ^ The Waitangi Tribunal–Te Roopu Whakamana i te Tiriti o Waitangi. Janine Hayward, Nicola R. Wheen. Wellington, N.Z.: Bridget Williams Books. 2004. ISBN 1-877242-32-2. OCLC 60361482.{{cite book}}: CS1 maint: others (link)
  55. ^ (PDF). Archived from the original (PDF) on 22 November 2011. Retrieved 7 November 2011.
  56. ^ . Archived from the original on 21 July 2011. Retrieved 7 November 2011.
  57. ^ "Review of the Roles of the Jersey Crown officers" (PDF). Retrieved 7 November 2011.
  58. ^ . Guernsey Press. 21 June 2010. Archived from the original on 10 June 2011. Retrieved 7 November 2011.
  59. ^ "Review of the Roles of the Crown Officers" (PDF). Retrieved 7 November 2011.
  60. ^ . Archived from the original on 27 September 2011. Retrieved 7 November 2011.
  61. ^ "Succession to the Crown (Jersey) Law 2013". States of Jersey. Retrieved 6 October 2021.
  62. ^ "The Air Navigation (Isle of Man) Order 2007 (No. 1115)". Retrieved 7 November 2011.
  63. ^ Overseas Territories: Seventh Report of Session 2007–08, Vol. 2: Oral and Written Evidence. London, UK: The Stationery Office, 6 July 2008, pp. 49, 296–297
  64. ^ "The Queen v Brenton Harrison Tarrant" (PDF). In the High Court of New Zealand Christchurch Registry. Retrieved 22 July 2022.

April 21, 2023
crown, this, article, about, term, referring, state, some, nations, television, series, series, other, uses, crown, disambiguation, crown, state, aspects, within, jurisprudence, commonwealth, realms, their, subdivisions, such, crown, dependencies, overseas, te. This article is about the term referring to the state in some nations For the television series see The Crown TV series For other uses see Crown disambiguation The crown is the state in all its aspects within the jurisprudence of the Commonwealth realms and their subdivisions such as the Crown Dependencies overseas territories provinces or states 1 The term can be used to refer to the office of the monarch or the monarchy as institutions to the rule of law or to the functions of executive the crown in council legislative the crown in parliament and judicial the crown on the bench governance and the civil service 2 The image of a crown is included in the coat of arms of New Zealand and located atop the escutcheon to symbolize the New Zealand Crown as the institution from which all state authority flows The concept of the crown as a corporation sole developed first in England as a separation of the physical crown and property of the kingdom from the person and personal property of the monarch It spread through English and later British colonisation and is now rooted in the legal lexicon of all 15 Commonwealth realms their various dependencies and states in free association with them It is not to be confused with any physical crown such as those of the British regalia 3 The term is also found in various expressions such as crown land which some countries refer to as public land or state land as well as in some offices such as minister of the crown crown attorney and crown prosecutor Contents 1 Definition 2 Concept 3 Divisibility of the crown 3 1 New Zealand 3 2 Crown Dependencies 3 3 British Overseas Territories 4 In the courts 5 See also 6 Further reading 7 Notes 8 ReferencesDefinition EditThe term the crown does not have a single definition Legal scholars Maurice Sunkin and Sebastian Payne opined the nature of the crown has been taken for granted in part because it is fundamental and in part because many academics have no idea what the term the crown amounts to 4 Nicholas Browne Wilkinson theorised that the crown is an amorphous abstract concept and thus impossible to define 5 while William Wade stated the crown means simply the Queen 6 The Lord Simon of Glaisdale stated the crown is a piece of bejewelled headgear under guard at the Tower of London but one that symbolises the powers of government which were formerly wielded by the wearer of the crown 5 The Lord Diplock suggested the crown means the government and all of the ministers and parliamentary secretaries under whose direction the administrative work of the government is carried out by the civil servants employed in the various government departments 5 This interpretation was supported by Section 8 of the Pensions Colonial Service Act 1887 which set the terms permanent civil service of the state permanent civil service of Her Majesty and permanent civil service of the Crown as having the same meaning 7 Concept Edit Rideau Hall in Ottawa Ontario held in perpetuity by the Canadian monarch presently Charles III Balmoral Castle in Aberdeenshire Scotland the personal property of Charles III The concept of the crown took form under the feudal system 8 Though not used this way in all countries that had this system in England all rights and privileges were ultimately bestowed by the ruler Land for instance was granted by the Crown to lords in exchange for feudal services and they in turn granted the land to lesser lords One exception to this was common socage owners of land held as socage held it subject only to the crown When such lands become ownerless they are said to escheat i e return to direct ownership of the crown crown lands Bona vacantia is the royal prerogative by which unowned property primarily unclaimed inheritances becomes the property of the crown n 1 9 As such the physical crown and the property belonging to successive monarchs in perpetuity came to be separated from the person of the monarch and his or her personal property After several centuries of the monarch personally exercising supreme legislative executive and judicial power these functions decreased as parliaments ministries and courts grew through the 13th century 10 The term the crown then developed into a means by which to differentiate the sovereign s official functions from his personal choices and actions 11 When the kingdom of England merged with those of Scotland and Ireland the concept extended into the legal lexicons of the United Kingdom and its dependencies and overseas territories and eventually all of the independent Commonwealth realms There are thus now many distinct crowns as a legal concept worn by or many different offices of monarch occupied by one person as sovereign of each country However the Crown can also mean the international institution shared by all 15 Commonwealth realms 11 King Charles III the living embodiment of the crown in each of the Commonwealth realms Given that in each realm and at its broadest the crown now means the government or the polity known as the state and the monarch in all realms is the living embodiment of the crown 12 the sovereign is regarded as the personification of the state n 2 26 The body of the reigning sovereign thus holds two distinct personas in constant coexistence that of a natural born human being and that of the state as accorded to him or her through law The crown and the monarch are conceptually divisible but legally indivisible The office cannot exist without the office holder n 3 28 The terms the state the Crown 29 the Crown in Right of jurisdiction His Majesty the King in Right of jurisdiction 30 and similar are all synonymous and the monarch s legal personality is sometimes referred to simply as the relevant jurisdiction s name 19 31 In countries using systems of government derived from Roman civil law the state is the equivalent concept to the crown 32 However the terms the sovereign or monarch and the crown though related have different meanings The crown includes both the monarch and the government The institution and powers of the crown are vested in the king but generally its functions are exercised in the sovereign s name by ministers of the crown drawn from and responsible to the elected chamber of parliament 11 Still the king or queen is the employer of all government officials and staff including the viceroys judges members of the armed forces police officers and parliamentarians n 4 the guardian of foster children crown wards as well as the owner of all state lands crown land buildings and equipment crown held property 34 state owned companies crown corporations and the copyright for government publications crown copyright 35 This is all in his or her position as sovereign not as an individual all such property is held by the crown in perpetuity and cannot be sold by the sovereign without the proper advice and consent of his or her relevant ministers The mace of the Parliament of Queensland symbolising the power of the Australian Crown in Parliament The crown also represents the legal embodiment of executive legislative and judicial governance While the crown s legal personality is usually regarded as a corporation sole 36 it can at least for some purposes be described as a corporation aggregate headed by the monarch 37 38 Frederic William Maitland argued the crown in the UK is a corporation aggregate embracing the government and the whole political community 39 J G Allen preferred to view the crown as a corporation sole one office occupied by a single person enduring through generations of incumbents and historically lends coherence to a network of other institutions of a similar nature 40 Canadian academic Philippe Lagasse found the crown acts in various capacities as such crown in council executive crown in parliament legislative crown in court judicial It is also an artificial person and office as a corporation sole At its most basic the crown is in the UK what is most other countries is the state 41 Divisibility of the crown EditFurther information Commonwealth realm The Crown in the Commonwealth realms Further information Monarchy in the Canadian provinces Historically the crown was considered to be indivisible 42 Two judgments Ex parte Indian Association of Alberta EWCA 1982 and Ex parte Quark House of Lords 2005 challenged that view Today the crown is considered separate in every country province state or territory regardless of its degree of independence that has the shared monarch as part of the respective country s government though limitations on the power of the monarch in right of each territory vary according to relevant laws thus making the difference between full sovereignty semi sovereignty dependency etc The Lords of Appeal wrote the Queen is as much the Queen of New South Wales and Mauritius and other territories acknowledging her as head of state as she is of England and Wales Scotland Northern Ireland or the United Kingdom 43 The crown in each of the Commonwealth realms is a similar but separate legal concept To distinguish the institution s role in one jurisdiction from its place in another Commonwealth law employs the expression the Crown in Right of place for example the Crown in Right of the United Kingdom 48 the Crown in Right of Canada the Crown in Right of the Commonwealth of Australia etc Because both Canada and Australia are federations there are also crowns in right of each Canadian province and each Australian state 49 When referring to the Crown in multiple jurisdictions wording is typically akin to the Crown in right of place and all its other capacities 50 The powers of a realm s crown are exercised either by the monarch personally or by his or her representative on the advice of the appropriate local ministers legislature or judges none of which may advise the crown in any other realm Elizabeth II Queen of Canada with her Cabinet in Rideau Hall 1 July 1967 Elizabeth II Queen of New Zealand with her Cabinet 1981 Governor General Bill Hayden representing Elizabeth II Queen of Australia with Cabinet outside Government House 25 March 1994 Elizabeth II Queen of the United Kingdom with her Cabinet at 10 Downing Street 18 December 2012Queen Elizabeth II in her various capacities as sovereign of differnt countries demonstrating the divisibility of the crown New Zealand Edit In New Zealand the term the Crown Maori te Karauna 51 is used to mostly mean the authority of government its meaning changes in different contexts 52 53 In the context of people considering Treaty of Waitangi claims professor of history Alan Ward defines the Crown as the people of New Zealand including Maori themselves acted through elected parliament and government 54 Crown Dependencies Edit In the Bailiwick of Guernsey legislation refers to the Crown in Right of the Bailiwick of Guernsey 55 or the Crown in Right of the Bailiwick 56 and the law officers of the Crown of Guernsey submitted that the Crown in this context ordinarily means the Crown in right of the republique of the Bailiwick of Guernsey 57 and that this comprises the collective governmental and civic institutions established by and under the authority of the monarch for the governance of these islands including the states of Guernsey and legislatures in the other islands the royal court and other courts the lieutenant governor parish authorities and the Crown acting in and through the Privy Council 58 The flag of Jersey displaying the badge of Jersey surmounted by a Plantagenet crown In the Bailiwick of Jersey statements by the law officers of the Crown define the Crown s operation in that jurisdiction as the Crown in Right of Jersey 59 with all Crown land in the Bailiwick of Jersey belonging to the Crown in Right of Jersey and not to the Crown Estate of the United Kingdom 60 The Succession to the Crown Jersey Law 2013 defined the Crown for the purposes of implementing the Perth Agreement in Jersey law as the Crown in Right of the Bailiwick of Jersey 61 Legislation in the Isle of Man also defines the Crown in Right of the Isle of Man as being separate from the Crown in Right of the United Kingdom 62 British Overseas Territories Edit Following the Lords decision in Ex parte Quark 2005 it is held that the King in exercising his authority over British Overseas Territories does not act on the advice of the Cabinet of the United Kingdom but in his role as king of each territory with the exception of fulfilling the UK s international responsibilities for its territories To comply with the court s decision the territorial governors now act on the advice of each territory s executive and the UK government can no longer disallow legislation passed by territorial legislatures 63 In the courts EditThis article needs additional citations for verification Please help improve this article by adding citations to reliable sources Unsourced material may be challenged and removed Find sources The Crown news newspapers books scholar JSTOR December 2021 Learn how and when to remove this template message In criminal proceedings the state is the prosecuting party the case is usually designated as R v defendant 64 where R can stand for either rex if the current monarch is male or regina if the monarch is female For example a criminal case against Smith might be referred to as R v Smith and verbally read as the crown against Smith The coat of arms of the sovereign of the United Kingdom on the Westminster Magistrates Court building in London England The crown is in general immune to prosecution and civil lawsuits So R is rarely albeit sometimes n 5 seen on the right hand side of the v in the first instance To pursue a case against alleged unlawful activity by the government a case in judicial review is brought by the crown against a minister on the application of a claimant The titles of these cases now follow the pattern of R on the application of X v Y notated asR X v Y for short Thus R Miller v Secretary of State for Exiting the European UnionisR on the application of Miller and other v Secretary of State for Exiting the European Union where Miller is Gina Miller a citizen Until the end of the 20th century such case titles used the patternR v Secretary of State for Exiting the European Union ex parte Miller Either form may be abbreviatedR Miller v Secretary of State for Exiting the European Union In Scotland criminal prosecutions are undertaken by the lord advocate or the relevant procurator fiscal in the name of the Crown Accordingly the abbreviation HMA is used in the High Court of Justiciary for His Her Majesty s Advocate in place of rex or regina as in HMA v Al Megrahi and Fahima Most jurisdictions in Australia use R or the king or the queen in criminal cases If the Crown is the respondent to an appeal the words the king will be spelled out instead of using the abbreviation R i e the case name at trial would be R v Smith if the defendant appeals against the Crown the case name would be Smith v the King In Western Australia and Tasmania prosecutions will be brought in the name of the respective state instead of the Crown e g the State of Western Australia v Smith Victorian trials in the original jurisdiction will be brought in the name of the director of public prosecutions The Commonwealth director of public prosecutions may choose which name to bring the proceeding in Judges usually refer to the prosecuting party as simply the prosecution in the text of judgments In civil cases where the Crown is a party it is a customary to list the body politic e g State of Queensland or Commonwealth of Australia or the appropriate government minister as the party instead When a case is announced in court the clerk or bailiff may refer to the Crown orally as our sovereign lord the king or our sovereign lady the queen In reporting on court proceedings in New Zealand news reports will refer to the prosecuting lawyer often called a Crown prosecutor as in Canada and the United Kingdom as representing the Crown usages such as for the Crown Joe Bloggs argued being common The crown can also be a plaintiff or defendant in civil actions to which the government of the Commonwealth realm in question is a party Such crown proceedings are often subject to specific rules and limitations such as the enforcement of judgments against the crown Qui tam lawsuits on behalf of the crown were once common but have been unusual since the Common Informers Act 1951 ended the practice of allowing such suits by common informers See also Edit Monarchy portalCrown CourtFurther reading EditSunkin Maurice Payne Sebastian eds 1999 The Nature of the Crown A Legal and Political Analysis Oxford University Press doi 10 1093 acprof oso 9780198262732 001 0001 ISBN 9780198262732 Notes Edit Jurisdictions in which this prerogative does not apply include Cornwall where unowned property becomes the property of the duke of Cornwall and Lancashire where it becomes the property of the duke of Lancaster In the Canadian context the monarch has been described by Eugene Forsey as the symbolic embodiment of the people not a particular group or interest or party but the people the whole people 13 his daughter Helen Forsey said of his opinion on the crown for him the essence of the monarchy was its impartial representation of the common interests of the citizenry as a whole as opposed to those of any particular government 13 The Department of Canadian Heritage said the Crown serves as the personal symbol of allegiance unity and authority for all Canadians 14 15 a concept akin to that expressed by King Louis XIV L Etat c est moi or I am the state 16 Robertson Davies stated in 1994 the Crown is the consecrated spirit of Canada 17 and past Ontario chairman of the Monarchist League of Canada Gary Toffoli opined the Queen is the legal embodiment of the state at both the national and the provincial levels She is our sovereign and it is the role of the Queen recognized by the constitutional law of Canada to embody the state 18 As Peter Boyce put it the Crown as a concept cannot be disentangled from the person of the monarch but standard reference to the Crown extends well beyond the Queen s person 27 The Supreme Court found in the 1980 case Attorney General of Quebec v Labrecque that civil servants in Canada are not contracted by an abstraction called the state but rather they are employed by the monarch who enjoys a general capacity to contract in accordance with the rule of ordinary law 33 For exceptions in the United Kingdom see Crown Proceedings Act 1947 References Edit Jackson Michael D 2013 The Crown and Canadian Federalism ISBN 978 1 4597 0989 8 Carroll Alex 2003 Constitutional and Administrative Law Pearson Longman p 7 ISBN 978 0 582 47343 0 CharlotteDunn 4 June 2018 Crown Dependencies The Royal Family Retrieved 1 September 2021 Sunkin Maurice Payne Sebastian 1999 The Nature of the Crown A Legal and Political Analysis Oxford Oxford University Press a b c Town Investments v Department for the Environment Lord Morris of Borth y Gest Lord Simon of Glaisdale Lord Kilbrandon Lord Edmund Davies 359 House of Lords 1978 Wade William The Crown Ministers and Officials Legal Status and Liability in Sunkin M Payne S eds The Nature of the Crown p 24 Torrance 2023 pp 9 10 Maitland Frederic 1901 The Crown as Corporation Law Quarterly Review 17 131 46 Nguyen Nam H 18 March 2018 Essential 25000 English Cebuano Law Dictionary Nam H Nguyen Torrance David 11 January 2023 The Crown and the Constitution PDF House of Commons Library p 8 retrieved 1 March 2023 a b c Torrance 2023 p 7 Elizabeth II 2005 46 1 b Interpretation Act Ottawa Queen s Printer for Canada published 1 April 2005 retrieved 7 August 2009 a b Forsey Helen 1 October 2010 As David Johnson Enters Rideau Hall The Monitor Ottawa Canadian Centre for Policy Alternatives Retrieved 23 January 2011 Department of Canadian Heritage Ceremonial and Canadian Symbols Promotion gt The crown in Canada Queen s Printer for Canada retrieved 19 February 2009 Department of Canadian Heritage 2010 Canada Symbols of Canada PDF Ottawa Queen s Printer for Canada p 3 retrieved 4 December 2016 Derwyn Shea 10 April 1996 Bill 22 Legislative Assembly Oath of Allegiance Act 1995 gt 1720 Committee Transcripts Standing Committee on the Legislative Assembly Toronto Queen s Printer for Ontario archived from the original on 11 June 2011 retrieved 16 May 2009 Davies Robertson 8 August 1996 Hunting Stuart and The Voice of the People Toronto Simon amp Pierre ISBN 978 0 88924 259 3 Toffoli Gary 10 April 1996 Bill 22 Legislative Assembly Oath of Allegiance Act 1995 gt 1620 Committee Transcripts Standing Committee on the Legislative Assembly Toronto Queen s Printer for Ontario archived from the original on 11 June 2011 retrieved 16 May 2009 a b Table Research Branch of the House of Commons March 2008 Compendium of Procedure PDF Ottawa Queen s Printer for Canada p 1 Archived PDF from the original on 28 October 2006 Retrieved 14 October 2009 Cabinet Secretary and Clerk of the Executive Council April 2004 Executive Government Processes and Procedures in Saskatchewan A Procedures Manual PDF Regina Queen s Printer for Saskatchewan p 10 retrieved 30 July 2009 The Royal Household The Queen and the Commonwealth gt Queen and Canada gt The Queen s role in Canada Queen s Printer retrieved 15 May 2009 MacLeod Kevin S 2012 A Crown of Maples PDF 2 ed Ottawa Queen s Printer for Canada p 51 ISBN 978 0 662 46012 1 archived from the original PDF on 4 February 2016 retrieved 28 November 2012 Marleau Robert Montpetit Camille 2000 1 Parliamentary Institutions gt Institutional Framework gt The Crown House of Commons Procedure and Practice Ottawa Queen s Printer for Canada ISBN 2 89461 378 4 archived from the original on 8 October 2012 Citizenship and Immigration Canada 2009 Discover Canada PDF Ottawa Queen s Printer for Canada p 2 ISBN 978 1 100 12739 2 retrieved 3 December 2009 Tidridge Nathan 2011 Canada s Constitutional Monarchy An Introduction to Our Form of Government Toronto Dundurn Press p 17 ISBN 9781459700840 19 20 21 22 23 24 25 Boyce Peter John 2008a The Queen s Other Realms The Crown and Its Legacy in Australia Canada and New Zealand Sydney Federation Press p 81 ISBN 978 1 86287 700 9 Bowden James Philippe Lagasse 6 December 2012 Succeeding to the Canadian throne Ottawa Citizen archived from the original on 10 January 2013 retrieved 6 December 2012 Elizabeth II 9 October 2012 83 1 Financial Administration Act Queen s Printer for Canada retrieved 6 December 2012 Elizabeth II 21 May 2004 Memorandum for Understanding of Cooperation on Addressing Climate Change PDF Toronto Queen s Printer for Canada p 1 Retrieved 16 May 2009 Elizabeth II 2004 A First Nations Federal Crown Political Accord PDF 1 Ottawa Assembly of First Nations p 3 Archived from the original PDF on 6 October 2005 Retrieved 29 September 2009 Jackson Michael D 2013 The Crown and Canadian Federalism Toronto Dundurn Press p 20 ISBN 978 1 4597 0989 8 Smith David E 1995 The Invisible Crown Toronto University of Toronto Press p 79 ISBN 0 8020 7793 5 Department of National Defence DCBA 414 011759Z Apr 09 MFSI Annual Rates for the Fiscal Year 2009 2010 Queen s Printer for Canada Archived from the original on 28 August 2009 Retrieved 16 May 2009 Canada PDF Map Queen s Printer for Canada 2006 Archived from the original PDF on 26 March 2009 Retrieved 16 May 2009 George V 9 April 1925 s 180 Law of Property Act 1925 London King s Printer Maitland Frederic 1901 The Crown as Corporation Law Quarterly Review 17 131 46 The Law Commission November 1996 Paper 143 The execution of deeds and documents by or on behalf of bodies corporate PDF Halsbury s Laws of England Affidavit 4 ed Lincoln County Nevada published 1974 9 1206 Maitland Frederic William 1908 The Constitutional History of England Cambridge Cambridge University Press p 418 Allen J G July 2018 The Office of the Crown Cambridge Law Journal Cambridge 77 2 300 doi 10 1017 S0008197318000338 S2CID 149843556 Lagasse Philippe 2 November 2021 The State The Crown and Parliament lecture given at Carleton University Ottawa Saunders Cheryl 2015 The Concept of the Crown Melbourne University Law Review 38 883 Lords of Appeal Ex parte Quark 2005 Lauterpacht E Greenwood C J 1992 International Law Reports Vol 87 Cambridge Cambridge University Press pp 286 713 ISBN 978 0 949009 99 9 Royal Institute of International Affairs 1983 The British Year Book of International Law Vol 53 British Institute of International Affairs Oxford H Frowde pp 253 257 258 Bourne C B 1986 Canadian Yearbook of International Law Vol 23 Vancouver UBC Press ISBN 978 0 7748 0259 8 The Australian law journal Vol 52 North Ryde Law Book Co of Australasia Ltd 1978 pp 58 203 207 3910867 44 45 46 47 Ministry of Natural Resources 24 January 2006 Disposition of Public Land to Other Governments and Agencies PDF Toronto Queen s Printer for Ontario p 2 at 3 2 B retrieved 25 April 2010 When public land is required by the federal government or one of its departments or any provincial ministry the land itself is not transferred What is transferred is the responsibility to manage the lands on behalf of Her Majesty the Queen HMQ This is accomplished by an Order in Council or a Minister s Order that transfers management of land either from HMQ in right of Ontario to HMQ in right of Canada as represented by a department or to HMQ in right of Ontario as represented by another ministry The Crown does not transfer ownership to itself Clayton Utz Retail Leases Comparative Analysis The Act Binds the Crown Clayton Utz Archived from the original on 14 July 2022 Retrieved 14 April 2023 Karauna Te Aka Maori Dictionary Retrieved 20 January 2023 Shore Cris Kawharu Margaret 17 June 2014 Thr Crown in New Zealand Anthropological Perspectives on an Imagined Sovereign Sites A Journal of Social Anthropology and Cultural Studies 11 1 17 38 doi 10 11157 sites vol11iss1id267 ISSN 1179 0237 Definition of the Crown a difficult matter New Zealand Law Society Te Kahui Ture o Aotearoa 15 November 2019 Retrieved 12 May 2021 The Waitangi Tribunal Te Roopu Whakamana i te Tiriti o Waitangi Janine Hayward Nicola R Wheen Wellington N Z Bridget Williams Books 2004 ISBN 1 877242 32 2 OCLC 60361482 a href Template Cite book html title Template Cite book cite book a CS1 maint others link Review of the Roles of the Jersey Crown officers PDF Archived from the original PDF on 22 November 2011 Retrieved 7 November 2011 The Unregistered Design Rights Bailiwick of Guernsey Ordinance 2005 Archived from the original on 21 July 2011 Retrieved 7 November 2011 Review of the Roles of the Jersey Crown officers PDF Retrieved 7 November 2011 It s a power thing Guernsey Press 21 June 2010 Archived from the original on 10 June 2011 Retrieved 7 November 2011 Review of the Roles of the Crown Officers PDF Retrieved 7 November 2011 Written Question to H M Attorney General Archived from the original on 27 September 2011 Retrieved 7 November 2011 Succession to the Crown Jersey Law 2013 States of Jersey Retrieved 6 October 2021 The Air Navigation Isle of Man Order 2007 No 1115 Retrieved 7 November 2011 Overseas Territories Seventh Report of Session 2007 08 Vol 2 Oral and Written Evidence London UK The Stationery Office 6 July 2008 pp 49 296 297 The Queen v Brenton Harrison Tarrant PDF In the High Court of New Zealand Christchurch Registry Retrieved 22 July 2022 Retrieved from https en wikipedia org w index php title The Crown amp oldid 1150517238, wikipedia, wiki, book, books, library,

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