ratification do not, of themselves, make treaties operate domestically. In the absence of legislation, treaties cannot impose obligations on individuals nor create rights in domestic law. Nevertheless, international law, including treaty law, is a legitimate and important influence on the development of the common law and may be used in the interpretation of statutes." Treaties can be implemented by executive action, and often, existing laws are sufficient to ensure a treaty is honored. Australian treaties generally fall under the following categories: extradition, postal agreements and money orders, trade and international conventions. Brazil The federal constitution of Brazil states that the power to enter into treaties is vested in the president of Brazil and that such treaties must be approved by the Congress of Brazil (Articles 84, Clause VIII, and 49, Clause I). In practice, that has been interpreted as meaning that the executive branch is free to negotiate and sign a treaty but that its ratification by the president requires the prior approval of Congress. Additionally, the Supreme Federal Court has ruled that after ratification and entry into force, a treaty must be incorporated into domestic law by means of a presidential decree published in the federal register for it to be valid in Brazil and applicable by the Brazilian authorities. The court has established that treaties are subject to constitutional review and enjoy the same hierarchical position as ordinary legislation (leis ordinárias, or "ordinary laws", in Portuguese). A more recent ruling by the Supreme Court of Brazil in 2008 has altered that somewhat by stating that treaties containing human rights provisions enjoy a status above that of ordinary legislation, subject to only the constitution itself. Additionally, the 45th Amendment to the constitution makes human rights treaties approved by Congress by a special procedure enjoy the same hierarchical position as a constitutional amendment. The hierarchical position of treaties in relation to domestic legislation is of relevance to the discussion on whether and how the latter can abrogate the former and vice versa. The constitution does not have an equivalent to the supremacy clause in United States Constitution, which is of interest to the discussion on the relation between treaties and legislation of the states of Brazil. India In India, subjects are divided into three lists: union, state and concurrent. In the normal legislation process, the subjects on the union list must be legislated by the Parliament of India. For subjects