(dissenting) :
The majority opinion upholds the constitutionality of all provisions of the statutes in question, except the provisions of Act No. 283 (Section 14 — 3701 et seq., Code Supplement) which create Form 5, the board of commissioners form of county government. I agree with the result of the majority opinion, except as to the conclusion reached relative to Form 5, and as to that, I dissent.
The contention that Act 283 is unconstitutional because of the inclusion of the board of commissioners form of government as one of the five forms to be submitted to the electorate is, in my opinion, without merit. The powers extended to the county governing body under this form are not as ex*349tensive as those granted to the governing body of those counties selecting one of the other alternative forms. Code Sections 14 — 3703 and 14 — 3785.2. The General Assembly retains the power to approve the county budget and the power of taxation is not given to the board of commissioners. In addition, the members of the board are appointed by the Governor with the consent of the county legislative delegation.
It is argued that the withholding of the foregoing powers makes the board of commissioners form inconsistent with the purpose and intention of Article VIII, Section 7. This contention is without merit.
Article VIII is silent as to the form, structure, organization, powers, duties, functions, and responsibilities of the forms of government to be established, and there is nothing in the language which evidences an intention to prevent the inclusion of the form of county government in existence prior to the amendment as one of the alternate forms to be presented to the electorate.
The Constitution of this State prior to the adoption of Article VIII, contained no provision “Establish [ing] a uniform or definite form of county government,” Lillard v. Melton, 103 S. C. 10, 87 S. E. 421; and it is apparent that the main purpose of Article VIII was to establish definite forms of county government, not to exceed five, in order to achieve a degree of uniformity where none previously existed. This is indicated both by the language of Article VIII and the Final Report of the Constitutional Study Committee, pages 87 (Sections G and H) and 89 (Section L).
The General Assembly concluded, no doubt, that there were counties in South Carolina whose needs would best be served by the county board of commissioners form of government. This form is clearly consistent with the establishment of classes of county government. It is not forced upon any county but may be adopted in any county only where the electorate chooses to do so.
*350The fact that the members of the board of commissioners are appointed violates no provision of Article VIII. This provision is applicable to the class of counties adopting that form and there is no reason why the General Assembly may not exercise these powers so long as uniformity is maintained within 'the class.
The fact that certain powers are withheld from the board of commissioners while they are extended to the other forms of government does not in itself render the board of commissioners form unconstitutional. The General Assembly is given the discretion to specify which powers shall be extended to the county governing body under each alternate form of government.
The very fact that Article VIII made provision for alternate forms of county government implies an intention to allow for different powers under the several forms to meet the diverse needs of the counties of this State. The board of commissioners form is entirely consistent with that purpose of Article VIII, Section 7.
It is argued however that the failure to grant the taxing power to the board of commissioners form of government violates Article VIII, Section 7. This argument is based upon the premise that Article VIII, Section 7, requires that the power to impose local county taxes must be vested in the local governing bodies by directing that “the General Assembly shall provide by general law for the . . ., powers, ... of counties, including the power to tax different areas at different rates of taxation . . .” This interpretation would, of necessity, have the effect of overruling by implication other provisions of the Constitution.
It is well settled that the General Assembly has full power over matters of taxation, subject only to express constitutional limitations. Ward v. Cobb, 204 S. C. 275, 28 S. E. (2d) 850.
*351The above provision from Section 7 of Article VIII must be construed in connection with Article X, Sections 5 and 6. Section 5 provides that “The corporate authorities of counties . . . may be vested with power to assess and collect taxes for corporate purposes; such taxes to be uniform in respect to persons and property within the jurisdiction of the body imposing the same.” (Emphasis added). Section 6 states that “the General Assembly shall not have power to authorize any county or township to levy a tax or issue bonds for any purpose except for” certain enumerated purposes. (Emphasis added). It cannot be argued that Article VIII invalidates Article X, Section 6, because Section 6 was amended in 1973 along with Article VIII and the quoted portion of Section 6 was left intact.
The provision of Article VIII, Section 7, relating to' the taxing power was clearly designed to explicitly remove the restrictions of Article X which required uniform assessment and represents a departure from past practices in regard to the creation and support of special purpose districts. Article VIII does not constitute a grant of the constitutional power of county-wide taxation, which Article X provides may be vested in county governments.
Thus interpreted the provisions of the Constitution are harmonized, which, under settled principles, we are required to do, if possible.
While the majority states that Article VIII, Section 7, “can be harmonized” with Article X, Sections 5 and 6, the only attempt to point out how they may be harmonized is the statement that “Article X deals in generalities, while Article VIII is a specific mandate.” This bald statement fails completely to come to grips with the patent conflict between Article X and Article VIII which the interpretation by the majority clearly creates.
It is further contended that the exercise of the powers retained by the General Assembly under the board of com*352missioners form will require laws for a specific county in violation of the provisions of Article VIII, Section 7, which prohibits the enactment of “laws for a specific county.”
The State Constitution is not a grant but a limitation of legislative power; thus, the General Assembly may enact any law not expressly, or by clear implication, prohibited by the Constitution. Elliott v. McNair, 250 S. C. 75, 156 S. E. (2d) 421. The prohibition against laws for a specific county applies only to laws relating to those powers, duties, functions and responsibilities, which under the mandated forms of government are set aside for counties. Kleckley v. Pulliam, 265 S. C. 177, 217 S. E. (2d) 217.
Since counties are not autonomous and all-powerful but may exercise only those powers granted by the General Assembly under the selected form of government, it is readily apparent that the powers not extended to the counties under a particular form of government remain in the General Assembly to be exercised consistent with Article III, Section 34, which prohibits a special law if a general law could be made applicable.
I would uphold the constitutionality of the provisions of Act 283 creating the board of commissioners form of government. To the extent stated, I dissent from the majority opinion ; but otherwise concur in the result.
Gregory, J., concurs.