Head of the Church time of the English Reformation, Henry VIII took for himself the title of Supreme Head of the Church of England, which was theologically problematic; his daughter Elizabeth I changed this to Supreme Governor of the Church of England. The Presbyterian system, codified in the Westminster Standards, outlines teaching elders (Ministers) and ruling elders, and courts presided over by Moderators sitting "primus inter pares", and gives practical effect to the concept of the equal status of all believers behind the one and only head of the church - Jesus Christ. This gives rise to the famous (or infamous) section of the
Governor-General of Australia by Royal authority, but by statutory authority". This view was also held by Senior Judge of the Supreme Court of Tasmania Andrew Inglis Clark, who, with W. Harrison Moore (a contributor to the first draft of the constitution put before the 1897 Adelaide Convention and professor of law at the University of Melbourne), postulated that the letters patent and the royal instructions issued by Queen Victoria were unnecessary "or even of doubtful legality". The monarch chose not to intervene during the 1975 Australian constitutional crisis, in which Governor-General Sir John Kerr dismissed the Labor government of Gough Whitlam, on the