21. Instead, paramountcy can only be invoked when then compliance with one means the breach of the other. 22. The principle of the paramountcy of African interests was entirely rejected by the majority of Northern Rhodesian settlers. 23. The report said there is no constitutional way to guarantee political paramountcy of any race without compromising democratic ideals. 24. The modern use of the paramountcy doctrine was articulated in " Multiple Access v . McCutcheon ". 25. He found that the paramountcy doctrine was more appropriate as there was a clear double aspect in the law. 26. The Mthethwa Paramountcy was superseded by the Zulu Kingdom under Shaka, a former lieutenant in the Mthethwa army. 27. This, however, is subject to any claim that may be raised relating to paramountcy of federal legislation. 28. Therefore, paramountcy should only be invoked where there is a conflict between the federal and provincial laws in question. 29. The Court held that there must be an " operational incompatibility " between the laws in order to invoke paramountcy . 30. The Court found that statutory duplication does not invoke paramountcy as the court had the discretion to prevent double penalties.
