Literal construction of the Constitution
Amalgamated Society of Engineers v Adelaide Steamship Co Ltd (1920) 28 CLR 129 (http://www.austlii.edu.au/au/cases/cth/HCA/1920/54.html) (Engineers Case) ushered in a period of literal interpretation of the Constitution.
Sir Owen Dixon did not accept a reading of Engineers that precluded doctrine based on an implication from the text or structure of the Constitution. In Melbourne Corporation (1947) 74 CLR 31 at 78 his Honour said:
Earlier he had written: "We should avoid pedantic and narrow constructions in dealing with an instrument of government and I do not see why we should be fearful about making implications." (The Airways Case (1945) 71 CLR 29, 85