As early as New South Wales v Commonwealth ("The Wheat Case"), the High Court decided that the strict insulation of judicial power was a fundamental principle of the Constitution. This also applies to tribunals and commissions set up by Federal Parliament which, unlike some of their equivalents in the states, can only recommend consequences. The Federal Parliament itself has the rarely used privilege of being able to act as a court in some circumstances, primarily where it may regard a non-member as acting "in contempt" of parliament.