The Crown is not bound by statute except by express words or necessary implication. In Province of Bombay v Municipal Corporation of the City Bombay [1947] AC 58, the Privy Council reaffirmed and elaborated upon this principle. Lord du Parcq stated as follows:

'If ... it is manifest from the very terms of the statute, that it was the intention of the legislature that the Crown should be bound, then the result is the same as if the Crown had been expressly named. It must then be inferred that the Crown, by assenting to the law, agreed to be bound by its provisions.'

Emphasising the strictness of the test, Lord du Parcq further stated that the agreement of the Crown to be bound could be inferred where it was apparent from the terms of the statute that 'its beneficent purpose must be wholly frustrated unless the Crown were bound'.