never again grant a certificate of appeal. On non-constitutional matters, the Privy Council regularly heard appeals against High Court decisions. In some cases the Council acknowledged that the Australian common law had developed differently from English law and thus did not apply its own principles. Other times it followed English authority, and overruled decisions of the High Court. This arrangement led to tensions between the High Court and the Privy Council. In Parker v R (1964), Owen Dixon CJ led a unanimous judgment rejecting the authority of the House of Lords decision in DPP v Smith, writing: "I shall not depart from the law on this matter as we have long since laid it down in this Court and I think that Smith's case should not be used in Australia as authority at all". The Privy Council overturned this by enforcing the UK precedent upon the High Court the following year. Thirteen High Court judges have heard cases as part of the Privy Council. Sir Isaac Isaacs is the only judge to have sat on an appeal from the High Court, in 1936 after his retirement as Governor-General. Sir Garfield Barwick insisted on an amendment to Privy Council procedure to allow dissent; however he exercised that only once. The appeals mostly related to decisions from other Commonwealth countries, although they occasionally included appeals from a State Supreme Court. Abolition of privy council appeals Section 74 allowed parliament to prevent appeals to the Privy Council. It did so in 1968 with the Privy Council (Limitation of Appeals) Act 1968, which closed off all appeals to the Privy Council in matters involving federal legislation. In 1975, the Privy Council (Appeals from the High Court) Act 1975 was passed, which closed all routes of appeal from the High Court; excepting for those in which a certificate of appeal would be granted by the High Court. In 1986, with the passing of the Australia Act by both the UK Parliament and the Parliament of Australia (with the request and consent of the Australian States), appeals to the Privy Council from state Supreme Courts were closed off, leaving the High Court as the only avenue of appeal. In 2002, Chief Justice Murray Gleeson said that the "combined effect" of the legislation and the announcement in Kirmani "has been that s 74 has become a dead letter, and what remains of s 74 after the legislation