Sexual differentiation in eutherian mammals follows a simple governing paradigm: development proceeds in a female direction unless a masculinizing mechanism intervenes. Sexual development in fishes is much more plastic than in mammals. It permits the intervention of environmental factors and follows several different types of sequences that produce successive hermaphrodites and alternative pathways for the development of the same final sex. In spite of this plasticity, the primacy of female development is suggested by the initial ovarian phase in the development of gonads of both sexes in some gonochoristic fishes and by protogynous sex change. One barrier to the application of this principle to fishes generally is the existence of protandric hermaphrodites. Recent evidence suggests a reinterpretation of gonadal differentiation in a protandric anemonefish and a protandric sparid. In both cases, testicular development is both preceded and followed by ovarian development. These patterns are interpreted to mean that female development is primary and that male development is a temporary phase initiated by a masculinizing mechanism and terminated by its cessation.