[1] At the 1871 election the central issue put forward to electors by the Premier James McCulloch was a proposal to introduce a secular education bill.

[4] In June 1871 McCulloch and his Treasurer, James Francis attempted to introduce a property tax as a means of financing new government responsibilities, a proposal which was overwhelmingly defeated in the Legislative Assembly.

[6] Lacking a parliamentary majority, Duffy put aside his free-trade convictions to enter into an uneasy alliance with a faction of protectionist liberals led by Graham Berry.

[6] In May 1872 a motion was debated in the Legislative Assembly concerning Duffy's appointment of the Irish journalist John Cashel Hoey to the position of Secretary to the Victorian Agent-General's Office in London.

The Governor then invited James Francis to form a new ministry, as the leading figure of the parliamentary opposition after McCulloch resigned his seat in March 1872.