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5.1 This chapter deals with the interaction between Commonwealth laws and the laws of the States and Territories. Its focus is on State and Territory laws as the primary protection of heritage and on the problems that arise for the Commonwealth, for Aboriginal people and others where those laws do not provide effective protection, and where there is duplication and delay due to lack of clear procedures at State, Territory and Commonwealth level. It asks what can be done by the Commonwealth to encourage more effective State and Territory laws, by developing minimum standards and by introducing accreditation and recognition procedures. It also discusses other steps to be taken by the Commonwealth to improve the interaction between Commonwealth laws and processes and those of the States and Territories.
5.2 The terms of reference ask the Review to consider the effectiveness of interaction between Commonwealth and State and Territory indigenous heritage protection legislation. One of the objectives of the review process has been to seek greater co-operation between Commonwealth and State and Territory Governments in addressing indigenous heritage issues.
5.3 The 1984 Act was introduced to provide a remedy of last resort, when State and Territory laws are not effective to protect a site or area from the threat of injury or desecration. When the Bill was introduced into Parliament in 1984 it was explained that State laws would operate concurrently with the Commonwealth Act wherever possible:
The Commonwealth is not attempting to cover the legislative field in this area of heritage protection. The Bill expresses an intention not to exclude or limit the operation of a law of a State or Territory that is capable of operating concurrently with it. In practice the Commonwealth sees this as legislation to be used as a last resort. The processes for the making and continuation of declarations will ensure that full recognition will be given to relevant State and Territory laws, and co-operation will be sought from State and Territory Governments.[2]
In keeping with this objective, the Commonwealth Act requires that the Minister consult the State or Territory Minister as to whether the laws of the relevant jurisdiction provide effective protection of the area or object in question before making a declaration under the Commonwealth Act.[3] The basis of the Commonwealth Act is that primary protection will be provided under State and Territory laws.
5.4 The Review has proceeded on the basis that the primary role of State and Territory laws is to be maintained, with the Commonwealth law continuing to act as a last resort mechanism. Most submissions did not challenge the respective roles of State/Territory and Commonwealth laws in heritage protection,[4] though almost universally they wanted the interaction of those laws to be improved,[5] areas of overlap to be clarified, and better co-operation between the State level and the Commonwealth level.
It is accepted that there also needs to be an established mechanism for co-operation between State and Commonwealth agencies providing for referral of a matter under the Commonwealth Act (where necessary) after procedure under the relevant State legislation has been completed.[6]
5.5 The main threat to Aboriginal cultural heritage (areas) comes from development and other changes in land use, for example, mining, building, agricultural or grazing purposes. Land management is the primary responsibility of the States and Territories and is governed by State and Territory laws about planning, development and land use, not by Commonwealth laws.
5.6 The most effective way to protect Aboriginal cultural heritage would be to integrate consideration of heritage issues in the planning process, alongside issues such as the environment and general heritage. In principle, States and Territories are better placed than the Commonwealth to ensure that Aboriginal concerns about significant areas and sites are taken into account in the planning and development stage and to enforce compliance with heritage protection laws.
In practice, site protection issues involve diverse matters many of which turn on the details of highly particular, local contexts. An agency organised at the national level would find it difficult to sustain the required grasp of local detail. The primary legislative responsibilities for Aboriginal sacred site protection should remain with the States and Territories.[7]
The key policy and planning processes impacting on Aboriginal heritage are State focused issues, for example, resource and land management, the management of cultural property and infrastructure development. The States are best placed to give Aboriginal heritage an appropriate place in policy and planning processes.[8]
5.7 Virtually all submissions from the Aboriginal community complained of the inadequacy of State and Territory laws to protect their heritage. Analysis of the heritage protection laws of the States and Territories[9] shows that there are wide differences in the laws and procedures, and in the level of protection provided. The deficiencies most often complained of, and which are apparent in several jurisdictions, are these:
5.8 There have been changes in the practice and procedures adopted by some States and Territories to overcome the gaps in their legal protection.[17] Links have been established between heritage and planning and environmental processes so that the current procedures need to be understood to measure the level of protection, as well as legislation. These procedures sometimes involve consultation processes to seek the views of Aboriginal communities about activities and developments which may affect Aboriginal sites.[18] The Review was informed of proposals which would, if implemented, affect the constitution of Aboriginal heritage bodies in Western Australia and South Australia and improve their effectiveness. But these changes have not yet been incorporated in legislative measures. Because of the developments mentioned, the level of legal protection in some States is difficult to assess. Nevertheless the consistent pattern of submissions from the Aboriginal community was that the laws are inadequate and in some cases they were seen as discriminatory.[19]
5.9 There are great differences in the level of legal protection provided by State and Territory laws. They do not conform to a single pattern, either as regards their subject matter (what is protected) or as regards their procedures and mechanisms. This causes problems to some Aboriginal communities whose sites run across borders.[20] It also makes the level of legal protection difficult to assess.
5.10 The problems encountered in the application of State laws mean that there is a continuing need for the Commonwealth legislation to provide a final recourse where State and Territory laws fail to provide adequate protection of Aboriginal cultural heritage.[21] It would not only show a total disregard of Aboriginal concerns to remove the protection of the Commonwealth law from cultural heritage, it would also leave the protection of that heritage to State and Territory laws which are inconsistent and in need of reform.
5.11 Ineffective State protection also places a greater burden on the Commonwealth Act. Its `last resort' approach depends on the existence of an appropriate primary level of protection. If that primary level of protection is ineffective or uncertain, resort may be had to the Commonwealth Act, in effect, to replace the State or Territory regimes. As submissions pointed out, the failings of State laws contribute to the problems of interaction.
Problems with interaction between State or Commonwealth Acts is in large measure a consequence of inadequate State Acts. The current Federal legislation operates with the heterogeneous schemes applying to Aboriginal sites and heritage in different States and Territories. In this context, the Federal scheme becomes more an additional agency for site protection than an agency of last resort for custodians.[22]
The diversity of the laws, and the inadequacies of both laws and procedures mean that a greater burden falls on the Commonwealth process and that the parties concerned undergo additional delays and costs.[23]
5.12 It should be noted that applications under the Commonwealth Act are far more frequent from some States than from others. The great majority of matters have come from three States: Queensland, NSW and Western Australia. However, when the proportion of the Aboriginal population is considered in relation to the number of applications it appears that Western Australia and Queensland are somewhat over-represented. The sources of applications, by State are outlined in the following table.
| State/Territory |
Number of areas |
per cent of
Aboriginal people |
| Queensland |
33 |
26 |
| New South Wales |
28 |
27 |
| Western Australia |
21 |
16 |
| South Australia |
8 |
6 |
| Northern Territory |
6 |
15 |
| Tasmania |
2 |
2 |
| Victoria * |
1 |
6 |
| ACT |
- |
1 |
| Total |
99 |
* In Victoria there are legal obstacles to the use of the Commonwealth Act.
5.13 The impact of the Commonwealth Act on Commonwealth/State relationships has given rise to a number of political differences.[24] Since, in practice, applicants are expected to go through the State process before applying to the Commonwealth, most applicants seeking action at Commonwealth level have not been satisfied by the State or Territory process.[25] The Commonwealth is asked to take a view different from that taken by the State or Territory government and, in effect, to override State law. The potential for both legal and political clash is obvious.[26] State and Territory Governments have expressed concern that their decisions are subject to `appeal' to the Commonwealth Minister. As the Federal Court said:
The Broome Crocodile Farm case and the Hindmarsh Island (Kumarangk) case are examples of open political conflict between the Commonwealth and the States on heritage issues. The case of the Old Swan Brewery was marked not only by Commonwealth/State conflict but also by political conflict within the State. The existence of the Commonwealth last resort safety net and the political nature of the exercise of discretion make conflict of this kind inevitable. Reforms should aim to reduce the potential for such conflict.
5.14 Other interaction problems arise from the actual processes under the Commonwealth Act. Procedural and other inadequacies of the Commonwealth law, and unclear, uncertain boundaries between the State and Territory process and the Commonwealth process have caused delays and other problems for applicants, developers and the States. The potential for duplication of procedures is seen by some as divisive and as having potential to create hostility between Aboriginal communities and landowners /developers.[28] The availability of a further process under the Commonwealth Act can extend the time for approving development and adds to the cost.[29] Matters may go to court, which compounds these difficulties.[30]
5.15 The need for a review of the interaction between Commonwealth State and Territory laws protecting Aboriginal cultural heritage has been a matter of concern for some time.
The Prime Minister suggested in his One Nation statement of 26 February 1992 that there was scope for improved integration of State/Territory and Commonwealth decision making in this area. He indicated that the Government would initiate action to obtain intergovernmental agreements on the joint development of co-operative mechanisms to streamline the process for assessment of Aboriginal heritage concerns. There was a very poor response from the States and Territories to this Commonwealth proposal.[31]
In the second reading of the Native Title Bill, in 1993, the Prime Minister said that the Commonwealth would over the next two years review heritage protection laws and ask the States and Territories to do the same.[32]
5.16 The Ministerial Council on Aboriginal and Torres Strait Islander Affairs (MCATSIA) recognised the need for close co-operation on these issues when it set up a Working Party of officers in 1994. The terms of reference of the Working Party covered the interaction of the Commonwealth Act with State and Territory laws and the development of a national framework of standards and processes for adoption as a bilateral agreement. This was to be done in consultation with Aboriginal and Torres Strait Islander communities. The Review notes, however, the concern of Aboriginal organisations and communities that they so far have been excluded from participation in that process.[33]
5.17 The Report of the Working Party recommends that a detailed examination of the relevant legislation within each jurisdiction be undertaken, taking into account the agreed national framework of guidelines, principles and processes outlined in the report (referred to in this report as `the Guidelines').[34]
5.18 Some States have been working on the reform of their heritage protection laws. A major report on the reform of Western Australia law by Clive Senior was made available to the Review.[35] New South Wales has a current review process, based on the Report of a Ministerial Task Force in 1989;[36] this may lead to reform of its laws. South Australia has informed the Review, in a late submission, that it intends to introduce a Bill to reform its legislation later in 1996.[37] The Bill would lie on the table for consultation for some months. Tasmania is expecting to publish a Discussion Paper in the near future.
5.19 In none of the cases mentioned are the details of the Government proposals available to the Review. Few States and Territories have shown any great willingness to move forward on these issues during the period of this Review. For example, the discussion papers envisaged for NSW and Tasmania have not yet been published. There has been no indication as to whether the Western Australian Government will implement the Senior Report. There are as yet no proposals for reform in Queensland. Few States were able to provide the Review with an analysis of their laws against the Guidelines.[38] The projected meeting of the Working Party on Interaction which had been arranged during the Review was cancelled at short notice.
5.20 Reform of State and Territory laws is a necessary part of improving the system of heritage protection in which the Commonwealth Act plays the role of last resort. Improving State and Territory laws and procedures would help to increase confidence of Aboriginal people in the State and Territory protection system and reduce the need to invoke the Commonwealth legislation.
The Land, Heritage and Environment Branch considers that the most effective long term strategy to reduce the recourse to the Commonwealth's Act is improving the confidence of Aboriginal people in State processes. The degree of change required to achieve more confidence differs from jurisdiction to jurisdiction.[39]
We consider that this [greater co-operation] can be achieved primarily by State and Territory governments acting to improve their legal, administrative and decision making processes in relation to indigenous heritage protection in such a way that indigenous people will have greater confidence in using those processes rather than appealing to the Commonwealth.[40]
5.21 Because of its national and international obligations to indigenous people, the Commonwealth has an obligation to take appropriate steps to ensure that State and Territory laws are as effective as possible. Its own laws should be reformed in a way that does not undermine State and Territory processes or discourage their use. But at the same time it needs to be made clear that amending the Commonwealth Act in isolation will not achieve the goals of effective heritage protection. Ideally, the Commonwealth and the States and Territories would co-operate in establishing complementary regimes based on common standards and with consistent procedures.[41]
From the number of applications received since the enactment of the Heritage Protection Act in 1984 it is evident that greater co-operation is needed between Commonwealth and State and Territory governments in addressing indigenous heritage issues if conflicts, such as the one at Hindmarsh Island, are to be avoided in future.[42]
From the viewpoint of a resource company that operates nationally the ideal would be uniform law in all jurisdictions with the Commonwealth providing a safety net.[43]
5.22 The Commonwealth should actively encourage States and Territories to revise and up-date their Aboriginal heritage protection laws in accordance with agreed standards, so that they can fulfill their proper role as the primary means of protecting Aboriginal cultural heritage.
5.23 The Working Party on Interaction had been asked by the Ministerial Council to report on "a national framework of guidelines to promote the co-operation of State, Territory and Commonwealth heritage legislation and decision making processes."[44] Its terms of reference asked it to:
The consultations undertaken by this Review revealed that with few exceptions,[45] there was strong support for a reform of State and Territory laws and for the adoption by the States and Territories of minimum standards.[46] The Guidelines of the Working Party are a first step in this process.[47]
5.24 Discussions concerning Guidelines and model laws have, up to this point, been limited to the government administrators. The terms of reference of the Working Party called for involvement of the Aboriginal community in this process.[48] They should, as envisaged, play a leading role in developing the Guidelines and model laws.[49] It is understood that the Working Party will be replaced with a new committee comprising representatives from each Commonwealth, State and Territory agency administering indigenous cultural heritage legislation. Its objectives will be to recommend best practice and co-ordination of functions.
5.25 The Commonwealth should contribute to the reform of State and Territory laws by actively supporting the process begun by the Working Party on Interaction to develop agreed minimum standards as the basis for model or uniform heritage protection laws. It should also ensure that Commonwealth law conforms with these standards.
5.1 A goal of Commonwealth heritage protection law and policy should be the reform of State and Territory laws. This goal should be pursued by legal and political means.
5.2 The Commonwealth Government should support and encourage the process of developing, in consultation with State and Territory governments, the Aboriginal community, and other interested parties, agreed minimum standards as the basis for uniform or model laws on Aboriginal cultural heritage protection, for adoption by the States and Territories and by the Commonwealth, where relevant. Resources should be allocated to support this process.
Elements which should be incorporated in minimum standards are considered in the next chapter.
5.26 The NSW Government submission drew attention to the Intergovernmental Agreement on the Environment of May 1992, which provides for the Commonwealth and the States to approve or accredit their respective environmental impact assessment processes and to give full faith and credit to the results of such processes when exercising their responsibilities.[50] In 1996 the Commonwealth agreed to change its administrative procedures to allow the accreditation of State processes which satisfy agreed requirements. Where a proposal is subject to assessment legislation of both the Commonwealth and a State or Territory, the normal means of assessment would be through a State assessment process accredited by the Commonwealth. The Commonwealth would retain final decision making for any accredited process. An analogy can be made with section 43 of the Native Title Act, under which the Commonwealth Minister may give effect to laws of a State or Territory dealing with the right to negotiate provided that the Minister is satisfied that those laws comply with specified standards.
5.27 Accreditation procedures could be adopted in the area of heritage protection. For example the question whether a site is significant according to Aboriginal tradition arises under both State law and Commonwealth law. Where that issue is substantially the same under State law as under the Commonwealth Act, and has been determined at State or Territory level by an approved process, it would be an unnecessary duplication for the question to be reconsidered by the Commonwealth. The minimum standard for such a decision might require that it be made by an independent, adequately resourced body constituted solely or almost exclusively by Aboriginal people nominated by and representative of Aboriginal communities. Where that standard is met and the criteria for the law are compatible with the Commonwealth standards, the Commonwealth could accept the decision on significance made by the State body. If an application were made for protection under the Commonwealth Act, the question for the Minister would then be limited to the balancing of competing interests in the exercise of an essentially political discretion.
5.28 This approach would be consistent with s 7, which preserves the law of a State or Territory which is capable of concurrent operation, but would take it one step further by, in effect, adopting the State process for the purposes of the Commonwealth Act. The proposal is in keeping with the original intentions of the Commonwealth legislation to encourage the reform of State and Territory laws.
The Commonwealth wants to encourage States and Territories to use such legislation as they have in the interests of the Aboriginal and Islander people for whose benefit it was passed. Where that legislation is inadequate the Commonwealth will, through this legislation, encourage changes to be made.[51]
Recognition of this kind would be an added encouragement to States and Territories to bring their laws and practices into conformity with minimum standards.[52]
5.29 Accrediting State/Territory laws and processes would also be consistent with the "bilateral agreed joint approval processes" mentioned when the Working Party on interaction was established, and with the co-operative approach underlying that exercise.[53] It was supported in submissions.[54]
Consideration could be given to accrediting State processes (in a similar manner to that contemplated under the Intergovernmental Agreement on the Environment) where State legislative mechanisms are capable of meeting Commonwealth requirements and obligations imposed under the Act. This may involve the development of State and Federal heritage agreements, or may require the development of a national agreement of Aboriginal heritage management principles ... [55]
5.30 Another option would be for the Commonwealth to refer an issue to the relevant State/Territory agency for determination if the matter comes to the Commonwealth before that agency has dealt with the issue. For example, the question of significance may not have been determined, or the Aboriginal persons with authority to speak for a site may need to be established. The Commonwealth could also recognise or accredit State/Territory consultation or mediation processes which met established standards. The possibility of referring matters to accredited State/Territory bodies would be an added incentive to reform State and Territory laws, and to establish Aboriginal cultural heritage bodies whose decisions could be recognised for the purposes of State and Commonwealth laws.
5.3 The Commonwealth should accredit for the purposes of the Act determinations and procedures under State/Territory laws which comply with minimum standards. It should provide, where appropriate, for the referral of matters to State/Territory agencies or bodies which meet minimum standards.
5.4 The Commonwealth should accredit or recognise for the purposes of the Act decisions concerning the significance of a site by State/Territory Aboriginal cultural heritage bodies that meet the required standards and which apply definitions comparable with the Commonwealth definition.
5.31 Some submissions called for the introduction of Commonwealth laws which would operate as an alternative, rather than as a back-up, to State and Territory processes where they do not meet required standards. Others called for the Commonwealth to legislate to impose minimum standards of protection of cultural heritage which would override State and Territory laws which do not conform to those standards.[56] Another view, along similar lines, was that indigenous people should have the option to seek site protection under Commonwealth legislation without having first to employ deficient State/Territory legislation.[57] Indigenous peoples might use this option where they felt more comfortable with that than with the State process, especially in situations where they fear that the State government will not be impartial to a site protection request.
Indigenous Peoples should be able to have a choice as to which process they feel would be most beneficial in achieving the protection of their site or object. This can be crucial where the State government have a direct interest in a development.[58]
It was suggested that comprehensive legislation of the kind proposed could be regarded as a special measure under the Racial Discrimination Act, and would be consistent with international instruments concerning the protection of religion and culture.
5.32 A difficulty with the proposal is that, unless the States co-operated by enacting complementary laws, the Commonwealth would have to set up comprehensive machinery to deal with all aspects of development where Aboriginal heritage was an issue. The Commonwealth would become the main regulator of that heritage;[59] this would have wide ranging effects, not considered here.
5.33 At this stage the proposals for the Commonwealth to take over primary responsibility for heritage protection must be considered incompatible with the role of the Commonwealth as a last resort mechanism in the protection of Aboriginal heritage. It would undermine efforts at greater co-operation and consultation on these issues. The fact that the suggestion has been put forward is, however, a measure of the frustration that many Aboriginal people experience under the current situation in several States. The Commonwealth must meet these concerns by finding more effective ways to negotiate with States and to encourage them to reform their legislation.[60] This is an urgent concern. The proposal for the Commonwealth to `take over' should not be completely discounted in the longer term as a solution to the current difficulties if it ultimately proves impossible to gain the support of the States for necessary reform measures. The Commonwealth has a legal and moral responsibility to ensure that changes are implemented.
5.34 Although it is not recommended that the Commonwealth `take over' primary responsibility for heritage protection, there are certain standards which the Commonwealth could implement directly in certain situations, falling short of comprehensive heritage protection, to fill the gaps left by State and Territory laws. These are considered in the following chapter.
[1] Jull, P A Sea Change: Overseas Indigenous-Government Relations in the Coastal Zone 1993, p5.
[2] Hansard, 9 May 1984, 2131: see Annex II. Section 7 provides for concurrent operation. On the effect of s 7 see NSWALC, sub 43, p5.
[3] Section 13(2), (4) and (5). A declaration under the Commonwealth Act is to be revoked if the State or Territory law makes effective provision for the protection of an area.
[4] VicG, sub 68.
[5] AMEC, sub 48, p18.
[6] WAG, sub 34.
[7] AAPA, sub 49, p13.
[8] SAG, sub 65, p3.
[9] Annex VIII.
[10] Rose, sub 46; AAA, sub 61.
[11] du Cros, sub 17, pp9-10; Cribb, sub 23; AAA, sub 61; White, sub 22; Qld consultations.
[12] Hofman, sub 4.
[13] Cribb, sub 23; Rose, sub 46; FAIRA, sub 51; Goolburri, sub 13.
[14] Senior Report, p187, points out that resourcing is a key factor.
[15] Goolburri, sub 13; Grabb and Mancini, sub 14.
[16] FAIRA, sub 51.
[17] These are noted in Impact Evaluation, p9.
[18] Rose, sub 46, mentions the appointment of cultural officers by Aboriginal communities to work with organisations, such as Telstra.
[19] Goolburri, sub 13.
[20] WA consultations; CLC sub 47, p18 calls for a single regime to deal with this.
[21] This is strongly supported by ATSIC, sub 54, pp3, 7-8; and KLC sub 57.
[22] AAPA, sub 49, p13.
[23] ATSIC, sub 54, p4: the main concern is the ineffectiveness of State and Territory government legislation and processes.
[24] Senior Report, p194. The decision is inherently political: Goldflam, Russell "Between a Rock and a Hard Place: The Failure of Commonwealth Sacred Sites Protection Legislation" in Aboriginal Law Bulletin Vol 3 No 74 June 1995.
[25] Interaction 16.
[26] AAPA, sub 49, pp8-9 refers to the political context of the decision. Finlayson, sub 40, points to political volatility and political tensions.
[27] Tickner v Bropho (1993) 40 FCR 183 at 224; (1993) 114 ALR 409 at 450, per French J. He observed that the decision is of a political character and "subject to compliance with the requirements of lawfulness, fairness and rationality, is not amenable to judicial intervention". Carr J endorsed the views of French J in relation to the character of the Minister's decision: State of Western Australia v Minister for Aboriginal and Torres Strait Islander Affairs (1995) 37 ALD 633 at 659.
[28] WA consultations.
[29] AMEC expressed concern about cost and delay, not so much about protection: WA consultations.
[30] Palyga, sub 1, complains that claimants have "two bites of the cherry" and calls for a single process.
[31] ATSIC sub 54, p8.
[32] Hansard 119, col 2882. See Annex II.
[33] CLC, sub 47, p23.
[34] The Report, Interaction, was presented to the meeting of Aboriginal and Torres Strait Islander Affairs Ministers, 20 October 1995.
[35] Senior Report.
[36] NSW Ministerial Task Force on Aboriginal Heritage and Culture Report on Aboriginal Heritage and Culture 1989.
[37] SAG, sub 65.
[38] Victoria and the ACT were notable exceptions, although the submissions to the Review from Victoria and Queensland were too late for detailed consideration.
[39] Interaction, Appendix E p5.
[40] ATSIC, sub 54, p7.
[41] SAG, sub 65, p3; NSWG, sub 55, p2; Jones, sub 6.
[42] ATSIC, sub 54, p 7.
[43] CRA, sub 9.
[44] Interaction p35, "Broad Guidelines for Aboriginal Heritage Legislation": these are reprinted in Annex VI.
[45] SAG, sub 65, p3, says that in view of the diversity of history, culture and identity of Aboriginal people, uniform national or state Aboriginal heritage legislation is not likely to be the most effective way to pursue protection objectives.
[46] NSWG, sub 55, p4; FAIRA, sub 51, p22; AAPA, 49, p1; AHC, sub 52, attachment 2, p3. Exploring for Common Ground also made proposals for national standards: p32; Jones, sub 6; Goolburri, sub 13; ALSWA, sub 56.
[47] See Annex VI.
[48] See Interaction, p3, term 4: Ensure that appropriate representatives of the Aboriginal and Torres Strait Islander communities are involved in addressing the above issues, in particular formulating the recommended national framework of guidelines.
[49] Goolburri, sub 13 calls for this.
[50] NSWG, sub 55. The Federal Minister should be able to recognise administratively the adequacy of State legislation thus removing the Commonwealth from the process in those jurisdictions.
[51] Hansard, 9 May 1984, 2132. See Annex II.
[52] AAPA, sub 49.
[53] Interaction, p3.
[54] CLC, sub 47, p24.
[55] NSWG, sub 55.
[56] MNTU, sub 17, p7 calls for mandatory protection; ALRM, sub 11, p1; PWYRC, sub 12; Qld consultations; CLC, sub 47, p24; PC, sub 28, p 8; ALSWA, sub 56; NT consultations; Recognition, Rights and Reform para 6.20.
[57] Recognition, Rights and Reform, para 6.20; ATSIC sub 54, p8.
[58] FAIRA, sub 51.
[59] CLC, sub 47, p18.
[60] Goolburri, sub 13.
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