The U.S. Supreme Court Pink (1942) found that international agreements, which were concluded in law, have the same legal status as treaties and do not require Senate approval. To Reid v. Concealed (1957), the Tribunal, while reaffirming the President`s ability to enter into executive agreements, found that such agreements could not be contrary to existing federal law or the Constitution. In November 1997, the Council of Australian Governments (COAG) approved the Principle of Heads of State and Government on the role and responsibility of the Commonwealth in the environment. Subsequently, all heads of government and the Australian Local Government Association signed the agreement. The implementation of executive agreements increased considerably after 1939. Prior to 1940, the U.S. Senate had ratified 800 treaties and presidents had concluded 1,200 executive agreements; From 1940 to 1989, during World War II and the Cold War, presidents signed nearly 800 treaties, but concluded more than 13,000 executive treaties. The rule that a Prime Minister who has lost the confidence of the House of Commons has lost the authority to insist that his council be accepted would also cover the problem of a Prime Minister losing an election and then seeking dissolution and new elections without being before Parliament.
This was never really done, although it was mentioned in Tasmania after the 1989 election, when the Liberal government lost its majority and the balance of power was maintained by five independent Greens. A strange series of events ensued, which was later the subject of a royal commission. There was an offer of a hundred thousand dollars, and perhaps the speakership, to a newly elected Labour MP to change sides; a secretly funded liberal advertising campaign calling for new elections; and legal advice to Prime Minister Gray that the governor should order a new election if the Prime Minister asks for a new election after his defeat in the Assembly.  The Governor, strengthened by a statement by a former Supreme Justice of the High Court, made it clear that he would not accept a dissolution unless it was impossible to form a government that had the confidence of the House of Commons. He insisted that the leader of the Labour opposition, who wanted to be appointed Prime Minister, provide clear evidence of his ability to form a government.