Reconciliation and Social Justice Library

[RSJ Home] [Global AustLII Search] [RSJ Database Search]
[Table of Contents] [Previous] [Next] [Download]

HIGH COURT DECISION ON MABO - (II) NATURE OF THE OBLIGATION

To say that, where traditional title exists, it can be dealt with and effectively alienated or extinguished only by the Crown, but that it can be enjoyed only by traditional owners, may be tantamount to saying that the legal interest in the traditional rights is in the Crown whereas the beneficial interest in the rights is in that indigenous owners. In that case the kind of fiduciary obligation imposed on the Crown is that of a constructive trustee. In any event, the Crown's obligation as a fiduciary is in the nature of, and should be performed by reference to, that of a trustee.

In Guerin Dickson J. said (623), referring to the Crown's duty towards the Musqueam Indians:

" This obligation does not amount to a trust in the private law sense. It. is rather a fiduciary duty. If, however, the Crown breaches this fiduciary duty it will be liable to the Indians in the same way and to the same extent as if such a trust were in effect."

Thus, the fiduciary obligation on the Crown, rooted in the extinguishability of traditional title, is in the nature of the obligation of a constructive trustee (624).



[RSJ Home] [Global AustLII Search] [RSJ Database Search]
[Table of Contents] [Previous] [Next] [Download]