 Among other measures, the Chifley government passed legislation to establish universal health care modelled on the British National Health Service, including a free formulary of essential medicines.This was successfully opposed as unconstitutional in the High Court of Australia by the British Medical Association (precursor of the Australian Medical Association) in the "First Pharmaceutical Benefits case".Chifley then organised one of the few successful constitutional referenda to insert a new section 51xxiiiA which permitted federal legislation over pharmaceutical benefits.