commodity.[82] Although such an order was not explicitly authorized by
statute, it was sustained as being a reasonable measure for effecting a
fair allocation of fuel oil, rather than as a means of punishment for an
offender. In another OPA case, the Court ruled that in a criminal
prosecution, a price regulation was subject to the same rule of strict
construction as a statute, and that omissions from, or indefiniteness
in, such a regulation, could not be cured by the Administrator's
interpretation thereof.[83]


Congressional Investigations


INVESTIGATIONS IN AID OF LEGISLATION

No provision of the Constitution expressly authorized either house of
Congress to make investigations and exact testimony to the end that it
may exercise its legislative function effectively and advisedly. But
such a power had been frequently exercised by the British Parliament and
by the Assemblies of the American Colonies prior to the adoption of the
Constitution.[84] It was asserted by the House of Representatives as
early as 1792 when it appointed a committee to investigate the disaster
to General St. Clair and his army in the Northwest and empowered it to
"call for such persons, papers, and records, as may be necessary to
assist their inquiries."[85]


CONDUCT OF EXECUTIVE DEPARTMENT

For many years the investigating function of Congress was limited to