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HIGH COURT DECISION ON MABO - THE "PATRIMONY OF THE NATION" BASIS OF THE PROPOSITION OF ABSOLUTE CROWN OWNERSHIP

In Williams v. Attorney-General for New Sooth Wales (103) and in The Commonwealth v. Tasmania. The Tasmanian Dam Case (104), there are references to the importance of the revenue derived from exercise of the power of sale of colonial land. The funds derived from sales of colonial land were applied to defray the cost of carrying on colonial government and to subsidize emigration to the Australian colonies. Further, the power to reserve and dedicate land for public purposes was important to the government and development of the Commonwealth and the Sates and Territories. Therefore it is right to describe the powers which the Crown - at first the Imperial Crown and later the Crown in right of the respective Colonies - exercised with respect to colonial lands as powers conferred for the benefit of the nation as a whole (105), but it does not follow that those were proprietary as distinct from political powers. nor does it follow that a combination of radical title to land and a power of sale or dedication of that land was not a valuable asset of the Colonies. it can be acknowledged that the nation obtained its patrimony by sales and dedications of land which dispossessed its indigenous citizens and that, to the extent that the patrimony has been realized, the rights and interests of the indigenous citizens in land have been extinguished. But that is not to say that the patrimony was realized by sales and dedications of land owned absolutely by the Crown. What the Crown acquired was a radical title to land and a sovereign political power over land, the sum of which is not tantamount to absolute ownership of land. Until recent times the political power to dispose of land in disregard of native title was exercised so as to expand the radical title of the Crown to absolute ownership but, where that has not occurred, there is no reason to deny the law's protection to the descendants of indigenous citizens who can establish their entitlement to rights and interests which survived the Crown's acquisition of sovereignty. Those rights and interests which may now claim the protection of s.10 (1) of the Racial Discrimination Act 1975 (Cth) which "clothes the holders of traditional native title who are of the native ethnic group with the same immunity from legislative interference with their enjoyment of their human right to own and inherit property as it clothes other persons in the community": Mabo v. Queensland (106).



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