a strict separation between the legislative and executive branches of government—indeed, government ministers are required to be members of parliament—but the federal judiciary strictly guards its independence from the other two branches. However, under influence from the U.S. constitution, the Australian constitution does define the three branches of government separately, which has been interpreted by the judiciary to induce an implicit separation of powers. State governments have a similar level of separation of power but this is generally on the basis of convention, rather than constitution. Austria The Constitution of Austria was originally written by Hans Kelsen, a prominent constitutional scholar in Europe at that time. Kelsen was to serve as a part of the judicial court of review for Austria as part of its tripartite government. Brazil The Constitution of Brazil, in its second article, establishes that there are three "powers of the Union, independent and harmonic, the Executive, the Legislative and the Judiciary". Canada The Constitution Act, 1867 provides that there shall be an executive, a legislature, and the judiciary. At the federal level, the executive power is assigned to the monarch of Canada, acting through their representative, the Governor General of Canada. The legislative function is assigned to the Parliament of Canada, composed of the monarch, the Senate and the House of Commons. The judicial powers are primarily assigned to the provincial superior courts, but provision was made for the creation of federal courts by Parliament. The federal courts now include the Supreme Court of Canada, the Federal Court of Appeal, and the Federal Court of Canada. The Supreme Court of Canada has repeatedly emphasised that the separation of powers is an important structural element of the Constitution of Canada. For example, in giving the majority judgment in Ontario v Criminal Lawyers' Association of Ontario, Justice Karakatsanis stated: Canada, like other parliamentary countries using the Westminster system, has a fusion between the executive and the legislative branches, with the Prime Minister and other Cabinet ministers being members of Parliament. However, the two branches have distinct roles, and in certain instances can come into conflict with each other. For example, in June 2021, the Speaker of the House of Commons directed a member of the public service to comply with an order of the House of Commons to share certain documents with the Commons, and the public servant refused to do so. The federal government announced that it