In Skulski v. Nolan, 68 N.J. 179, 198, 343 A.2d 721 (1975), the Court developed the analysis regarding whether the governmental action at issue was ultra vires in the primary sense or the secondary sense. The Skulski Court had observed: There is a distinction between an act utterly beyond the jurisdiction of a municipal corporation and the irregular exercise of a basic power under the legislative grant in matters not in themselves jurisdictional. The former are ultra vires in the primary sense and void; the latter, ultra vires only in a secondary sense which does not preclude ratification or the application of the doctrine of estoppel in the interest of equity and essential justice. Skulski, 68 N.J. at 198, 343 A.2d 721.