It is conceivable that under similar conditions the Crown might, by dismissing a ministry, force a dissolution, and appeal to the electorate. Such an event, though highly improbable, cannot be said to be impossible. The dismissal of a ministry must, of course, be carefully distinguished from the dismissal of an individual minister. This would be done, as in the case of Lord Palmerston,--the last of the kind that has occurred,--at the request of the Premier, and therefore not contrary to, but in accordance with, the advice of the person chiefly responsible for the acts of the Crown. The other way in which a change of ministry could be brought about by the Crown would be by a refusal to consent to some act which the ministry deemed essential to their remaining in office. Some cases of the exercise of such a right by the representative of the Crown have taken place in the self-governing colonies, but they are not such as are likely to occur in England. A request, for example, by the ministry to be allowed to dissolve a colonial legislature has on several occasions been refused by the governor, usually on the ground that a general election had recently been held, or that there was no important issue pending between the parties which the people could properly be called upon to decide.[33:1] In England, on the other hand, such a request by a ministry has never been refused since William Pitt in 1784 invented the principle that a government faced by a hostile majority in the House of Commons may appeal to the electorate instead of resigning; nor is it probable that it will be refused, because the rules of political fair play are so thoroughly understood among English statesmen that the power is not likely to be misused for party purposes. An interesting discussion on the right of a colonial governor to reject the advice of his ministers was raised in the case of Governor Darling of Victoria in 1865. The story has been often told. It grew out of a quarrel between the Assembly and the Legislative Council, which were both elective, but happened to be on opposite sides in politics. The Assembly, wishing to enact a protective tariff, to which a majority of the Council was known to be opposed, tacked it to the annual appropriation bill; and the Council, unable to amend such a bill, rejected it altogether. Thereupon the Governor, yielding to the pressure of his ministers, sanctioned the levy of the new duties, the issue of a loan, and the payment of official salaries, without the authority of any act regularly passed by both branches of the legislature. For permitting, on the advice of his ministers, such a violation of law, Governor Darling was rebuked, and finally dismissed by the Secretary of State for the Colonies.[34:1] It is needless to say that no such situation has ever arisen, or is likely to arise, in England. [Sidenote: Selection of a New Premier.]