Yeah, maybe that stretches the analogy too far. I think it is distinct from ministers governing in their own right (or in the right of the semi-fictional unitary 'Secretary of State') though. Most statutory instruments, for example, are issued by and in the name of a minister. Obviously the appointment of the minister is an act of the Crown, and so is the passing of the original Act which authorises the order-making power. But the power is used directly from their own ministerial user account, IYSWIM.