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Craven, Greg --- "The Developing Role of the Governor-General: The Goldenness of Silence" [2004] FedLawRw 12; (2004) 32(2) Federal Law Review 281

  • INTRODUCTION
  • COMMENT

    THE DEVELOPING ROLE OF THE GOVERNOR-GENERAL: THE GOLDENNESS OF SILENCE

    Greg Craven[*]

    INTRODUCTION

    In arguing for a relatively conservative understanding of the role of the Governor-General, this piece proceeds upon three background assumptions. The first is that Australia will remain a monarchy in the near to mid-term, and that the role of the Governor-General must be considered in this context. The second is that, nevertheless, Australia is moving leisurely towards becoming a republic, and presumably will eventually arrive at that point, though within no particular time frame.[1] The third assumption is that even when Australia does become a republic, it will enjoy substantially similar constitutional arrangements to those subsisting under the existing monarchy. By this is meant, chiefly, that the executive apparatus of the Commonwealth will continue to operate within a framework of parliamentary democracy, embodying a symbolic head of state — however chosen — and a politically powerful head of government.[2]

    It is, of course, inevitable that there will be development in any constitutional office, and from this inevitability the office of Governor-General is not immune. Indeed, it is a commonplace that the office already has evolved, along with that of the State Governors, away from any role as a representative of the British Government within the local administration, to comprising a true representative of the monarch within the Commonwealth.[3] Beyond this, the recent republican debate has itself provoked intense discussion of the role of the Governor-General as a surrogate Australian head of state.[4] This notion of the Governor-General as a 'head of state' manqué inevitably involves in a nebulous but real way recognizing the office as reflective of the Australian polity — whatever this might be thought to involve — as opposed to viewing its occupant merely as the 'representative' of the Queen.[5] Of course, so long as Australia remains a monarchy, the Governor-General can never be more than a surrogate, but even a surrogate head of state is more than a mere monarchical proxy.

    Indeed, in the context of the republican debate, the office of Governor-General has somewhat paradoxically assumed a whole new significance. Far from being dismissed as a soon to be discarded colonial relic, the Governor-General now demands considerable respect as the President-in-waiting. Under the 1999 referendum proposal, the incumbent would have been transmogrified into a republican President,[6] and under almost any plausible model, the office of Governor-General will be the immediate ancestor of that of President. There thus can be no real surprise that the office is the subject of renewed interest.

    Within this proto-republican climate of interest and discussion, it is highly likely that the office will continue to expand, if only psychologically. The tendency of some more recent incumbents to enter important and controversial public debates will operate to the same effect. All this being said, much of the debate concerning the role of the Governor-General has been relatively shallow. Thus, as it touches upon the issue of an expanded role for the Governor-General, this debate tends to turn upon the approval of the particular commentator for the persona of the particular incumbent, or the support of the commentator for the views expressed by that incumbent. We often seem to support an enhanced role for Governors-General whose views we like, but are deeply suspicious of such a role being conferred on Governors-General we mistrust.[7]

    Clearly, this is wrong, and indeed unprincipled. In discussing the future directions of the office of Governor-General, it is crucially necessary to consider the development of that office in light of its own fundamental functions, not the character of its incumbent, and to ask whether or not any envisaged role is consistent with those functions. With this stricture in mind, the general approach adopted here will be to argue that the office of Governor-General, and particularly the public role attached to that office, should be kept within relatively modest bounds, although it will be suggested that some of the former public profile of the Governor-General in respect of state and national occasions, increasingly usurped by political figures, should be restored.

    THE OFFICE OF GOVERNOR-GENERAL — PRACTICAL

    Often, the office of Governor-General under the Australian Constitution is considered in a somewhat narrow and unilluminating way.[8] Two common approaches are particularly unhelpful: the 'catalogue' approach, and the 'compendium' approach.

    Under the first, the office of Governor-General is understood essentially as the repository of a list of constitutional powers and functions (to be exercised in accordance with accompanying constitutional conventions), and all that is required to understand that office is to exhaustively note and elucidate the exercise and operation of each of these powers: assenting to laws,[9] setting the times for sessions of Parliament,[10] acting as commander in chief[11] and so forth. This approach provides a necessary technical itemisation of the office, but hardly promotes an insightful appreciation of any wider significance that it may have. Under the 'compendium' approach, the tendency is to state sonorously that the Governor-General is the 'representative of the Queen', but the broader implications of this statement in 21st century Australia — those that go beyond the obvious fact of constitutional appointment, and the ability to exercise the relevant list of constitutional powers — remain unexplored.

    Yet as Australia moves inevitably towards another round of republican debate, we do need to consider whether there is anything more to the office of Governor-General than being a basket of specific constitutional powers (constitutional and conventional) and the representative of a rapidly waning constitutional monarchy. We also need to ponder carefully what implications the answer to this question might have for the creation of the office of head of state in any future Australian republic.

    Ironically, given that this is the protracted eve of an Australian republic, the starting point here must be an attempt to tease out any wider significance in the Governor-General's representative role by reference to the wider role played by the Queen in the United Kingdom. Thus, impending republic or not, the Governor-General constitutionally is expressed to be the representative of the Queen in Australia, and it therefore hardly can be a surprising proposition that his or her role in this country bears a strong analogy with that of the Queen in the United Kingdom. This line of inquiry involves less thinking about the constitutional law of monarchy (or vice-regality) than pondering the constitutional philosophy that underlies that law. This is a somewhat murky pond of monarchical metaphysics, more likely to be plumbed by Dicey[12] or Bagehot[13] than the Commonwealth Government website.

    In so thinking about the role of the Governor-General by monarchical analogy, it is critical we appreciate that this will involve talking not merely about the legal and constitutional role of the Governor-General, but also the broader symbolic role of that office. This should not be surprising. The monarchy quintessentially is a creature of symbol, and the existing office of Governor-General equally is a creature of monarchy: in thinking about heads of state, their surrogates and republican successors, symbolism is squarely on the table. Even an avowed republican can admit that this exercise will entail seriously pondering the nature of constitutional monarchy in Australia, as mediated by the Governor-General, and may even involve wondering whether there are some significant advantages in our monarchical constitutional arrangements that should be preserved within an Australian republic.

    THE OFFICE OF GOVERNOR-GENERAL — MYSTICAL

    What is attempted here is a consideration of the office of Governor-General, not as an amalgam of the relevant sections of the Constitution, but as a broad surrogate of the British monarchy. Unavoidably, therefore, we are contemplating here some of the higher constitutional functions of that monarchy as expressed in an Australian idiom. This can be regarded as elevated constitutional theory or eccentric constitutional necromancy according to taste and perspective.

    The starting point in this consideration is to note that one of the basic and perennial issues of constitutional design is the separation of power from what might be termed legitimacy. By way of very loose definition, 'power' in this context means the capacity to command and direct, to ordain outcomes, quite independently of whatever feelings — positive or negative — the populace at large might have towards the repository of that capacity. Classically, Prime Ministers and ministers are creatures of power. Legitimacy is entirely more nebulous. It involves no particular claim to capacity or potency, but an entitlement to respect, to deference, to esteem and even, in particular circumstances, to affection.[14] The chief point about these two commodities is that while each in its own context is admirable, the combination potentially is deadly.

    The straightforward reason for this is that when power and legitimacy reside in the same organ, one is confronted with a figure or institution that possesses practical political potency, but which also is a natural object of respect, deference and adulation: or in simple terms, something with the capacity to do what it likes, and to be loved for doing it. The parable outcomes usually pointed to as illustrating the explosive potential of this constitutional nitroglycerine are Bonapartism or fascism, or perhaps more prosaically, the spectacle of American Presidents who enjoy ex officio not only practical power but the trappings of national glory.

    The notion of legitimacy is not one much used in Australia, where we ordinarily are more interested in separating one cohesive power — executive, legislative or judicial — from the other. Yet, legitimacy, the entitlement to public respect, is an important and potentially extraordinarily valuable commodity within any constitutional order, and one that may be used for good or ill. Fundamentally, a politician who makes an atrocious decision, but whose actions are then routinely debated, reviled and loathed, will be a very different creature from a politician who takes a similar decision in an atmosphere where the population is programmed to accord his or her actions respect and deference.[15]

    Crucially, it has been a major feature of the Australian and the British constitutional monarchies that they have operated with some success to promote a practical separation between legitimacy and power. Notably, under these monarchies, powerful politicians — and especially the institutionally powerful Prime Minister — while fully entitled to the exercise of their political prerogatives, enjoy minimal legitimacy. As mere politicians, little institutional respect attaches to their person or their office, and there is only the most limited psychology of automatic popular deference towards their doings. In fact, listening to them being routinely booed at major sporting events, one suspects rather the opposite.

    Rather, the chief repository of legitimacy (if any) in these systems has tended to be the Crown, represented in the United Kingdom by the Queen, and in Australia by the Governor-General. These organs, by way of contrast to the parliamentary executive, have minimal independent power,[16] and certainly no serious political base.[17] Yet in the case of the Queen in the United Kingdom, at least while the monarchy is functioning relatively well, the person-institution enjoys considerable respect, deference and even affection. It was this sort of legitimacy that used to be a source of international comfort during the reign of Margaret Thatcher, when apocryphal tales would circulate of Her Majesty failing to invite her Imperial Prime Minister to sit in her presence.

    An analogous position applies in Australia. One hardly can pretend that the Governor-General enjoys quite the same prestige as the British monarch, and he or she in theory enjoys rather more constitutional power,[18] but the position is fundamentally similar on the point of legitimacy. The Governor-General classically is a figure of dignity and respect, operating in the full knowledge — his or her own, and that of others — that no degree of political power attaches to the office. Yet a Governor-General enjoys the deference and respect due to what is acknowledged to be an office above and beyond politics. This legitimacy accorded to the office of Governor-General is, of course, most easily detected during the office of strongly respected Governors-General such as Hasluck, Cowen, Stephen, Deane and, to all appearances now, Jeffery.

    Historically, the basic effect of all this has been a marked contribution towards the substantial divorce between power and legitimacy. Put simply, while we may fear and obey our Prime Ministers, we do not feel ourselves to be under any obligation to love and respect them, and while we occasionally may take our politician-hating a little too far,[19] this is a fundamentally healthy state of affairs. Another way of putting it would be to say that our constitutional arrangements inhibit political functionaries from too successfully identifying themselves with the state and its interests. A fundamental prop of this is that basic legitimacy within our system is vested in a politically powerless, politically unattached symbolic office, that of Governor-General.[20]

    There is a further important consequence of these arrangements. Precisely because they promote the existence of an apolitical, power-free figure of national respect, the office of Governor-General provides a natural point of apolitical identification for all Australians on issues of national concern. It is precisely because the Governor-General is not in politics, and politics is not in the Governor-General, that Australians can identify with that office, especially at points of national success and tragedy. Crucially, because the Governor-General enjoys no political dimension and no political power, he or she is not the source of division inevitably encountered in political figures. This is what might be referred to as the 'unity dimension' of the office so often advanced by commentators and incumbents.[21]

    EVOLUTION OF THE OFFICE — CONSISTENCY WITH FUNCTION

    The most obvious mooted expansion of the office of Governor-General involves a widening of the Governor-General's public role, most specifically through him or her speaking more broadly on more controversial topics. This has been the subject of considerable recent debate. Traditionally, Governors-General are thought to confine their utterances to relatively uncontroversial subjects. A change may be detected during the time of Sir Zelman Cowan and Sir Ninian Stephen, when it began to be asserted that it was the role of the Governor-General to interpret the nation to itself.[22] It is not entirely clear what this nostrum involves, but it can be understood as positing that the Governor-General should take part in the fundamental public debates of the day, and perhaps that he or she should be a sort of public moral force in Australia. Certainly, this was the role adopted by Sir William Deane, who entered into a number of fields of public controversy, most notably that relating to reconciliation with aboriginal people.

    In assessing the appropriateness of these sallies, it is not a question of whether one likes a particular Governor-General or their comments. The real question is how consistent this expanded idea of the Governor-General's office is with its fundamental role as a repository of apolitical legitimacy, as outlined above. It is, of course, quite clear that the mere fact that the Governor-General is required to act as an apolitical depository of legitimacy will not prevent him or her from talking on a wide variety of subjects, including those which are of significant national importance. This particularly will be the case where the comments thus made are relatively general in nature: for example, the need for education, for respect for the law, to live in harmony with one's neighbours regardless of issues of race, and so forth. Nevertheless, serious difficulties may be encountered in relation to the traditional role of the Governor-General where an incumbent strays into topics of real political controversy. Some few areas of concern may be noted.

    First, it is obvious that the legitimacy of the Governor-General and his or her status as a figure of national unity depend critically upon the incumbent of that office maintaining an apolitical character. As soon as the Governor-General becomes 'political' he or she will lose that character, and become, in effect, merely another politician. Importantly, this will be relatively easy to do. Public statements on controversial topics upon which there are at least two strongly held views within the community inevitably will polarize views of the Governor-General concerned.

    As already has been noted, there is a tendency in this context to judge the propriety of a public intervention by a Governor-General simply on the basis of whether one agrees or disagrees with his or her statements. This is quite wrong. Whether or not an intervention is appropriate depends not upon whether one agrees with a statement, but whether or not such a statement is essentially political, and therefore inconsistent with the discharge of the office. The true test here is to ask, if one finds a controversial statement by a Governor-General to be congenial, whether one would have supported the Governor-General's right to make an exactly opposite statement on the same subject. In this sense, the question with Sir William Deane was not whether he was substantively correct about reconciliation — he was — but whether this was a suitable subject for intervention by a Governor-General, the ultimate test of which would be whether we would have been comfortable had his comments been negative, rather than positive.

    A second difficulty that arises when a Governor-General moves determinedly into a field of public controversy is the potential for serious conflict with the political arm, as represented by the parliamentary executive. There are two potential consequences of an excessively active Governor-General in this connection. The first and most obvious is the prospect of ongoing, destabilising warfare with the Prime Minister and his or her government on the grounds of a major policy dispute. This would be highly undesirable in terms of the logic of the office of Governor-General. A less obvious, but arguably more problematic development might be that, were Prime Ministers to believe that Governors-General unavoidably were to be viewed as garrulous fronts of political comment, they necessarily would appoint congenial and attractive Governors-General to support the relevant government positions. This would be particularly dangerous, as what effectively would be involved would be attempts by government to exploit the previously apolitical nature of the office of Governor-General by appointing incumbents who could propound government policy with seeming objectivity. The object would be for the political arm to harness the legitimacy of the Governor-General.

    Thirdly, once a Governor-General has become 'active', there is no obvious, logical stopping point. There seems to be something of a current notion that there is a defined category of uplifting topics — such as reconciliation or multiculturalism — upon which Governors-General safely may talk, which are divided by a heavy black line from other, less safe areas. This is highly implausible. Once a Governor-General has embarked upon a program of inspired speech-making, there is no obvious reason why he or she might not stray into every disputed area of policy from health and education to national security and immigration.

    In this context, we sometimes are inclined to underestimate 'talking' as a power.[23] A Governor-General has very few independent powers, but even on the most conservative analysis, he or she can talk. Moreover, as we have seen, when Governors-General talk, they traditionally speak with an authority born of apolitical legitimacy. A highly active Governor-General delivering an ongoing critique of the policies of an uncongenial government would have a potentially devastating effect upon that government, soluble only by the extraordinarily politically (and constitutionally) unpalatable course of dismissal. This was one of the spectres that worried opponents of direct election at the 1998 Constitutional Convention: what did one do once a popular, directly elected President had denounced the Government?[24] One also needs to consider in this context the corrosive effect of a free-speaking viceroy upon the whole range of conventions of the Constitution ensuring that the Governor-General acts in accordance with ministerial advice. A Governor-General who talks freely and controversially inevitably must be psychologically and temperamentally more likely to act freely and controversially. It would be difficult to quarantine the conventions of the office of Governor-General from a more fluid approach to the public execution of the office.

    An important connected factor here is that republicans (or at least conventional republicans) logically should be wary of any extravagant interpretation of the office of Governor-General in the years leading up to what they hope will be an Australian republic. In other words, if one wishes to maintain the conventions of the Australian Constitution intact under a republic, a major part of that exercise will be translating the office of Governor-General intact into a republican constitution. In turn, a necessary part of this will be trying to keep that office within reasonable bounds, so that its interaction with those conventions will be assured. This particularly would be a matter of special importance for anyone contemplating some form of symbolic Presidency filled by way of direct election.

    Despite such considerations, there is a somewhat romantic view abroad that in a world of increasing Prime Ministerial domination, any added check and balance is welcome, even if it consists of a barn-storming Governor-General.[25] There are, however, a number of factors that render an expanded office of the Governor-General of very limited use in this connection. The first is that the power of appointment to the office rests with a single member of the political executive, the Prime Minister.[26] As we have seen, this power could be used just as easily to put in office a Governor-General whose soaring speeches are designed to reinforce the position of the Prime Minister rather than to control it.

    Secondly, because the office is by definition individual in character, unlike a multi-party upper house or a multi-judge bench, it necessarily is highly idiosyncratic in its operation as a check upon power. Thirdly, it is clear that Governors-General come from, and will in the future likely come from, an exceptionally narrow background of experience: one effect of the Hollingworth experience probably will be to set us firmly on a long road of judges and generals. The members of neither of these two categories of eminent citizen are particularly equipped to engage in a wide range of public policy debate. Fourthly, Governors-General will be largely unaccountable for any horrors perpetrated in the name of a wider approach to their office. The only available redress would be for the Prime Minister to secure their dismissal by the Queen, a politically unlikely and fraught course.

    Finally, were one really to desire that the Governor-General engage in extensive social commentary, it needs to be remembered that he or she will have neither the staff nor the resources adequately to ground such a role, and this deficiency is unlikely to be supplied by a jealous Prime Minister, unless cooperative results were assured. One interesting insight into the office during the final months of the incumbency of Dr Peter Hollingworth, was to observe just how inadequate and bad the advice to the Governor-General must have been to produce such a series of predictably catastrophic public outcomes.[27]

    The conclusion therefore must be that if one wishes to maintain the office of Governor-General (or its republican successor) as one that assists in the quarantining of legitimacy from political office, and as one that embodies a subfusc focus of apolitical unity, there is very little room for a Governor-General to act as a statesperson. On balance, if the nation really wants itself interpreted to itself, it probably would be better investing in mass psychiatric analysis than in an adventurous surrogate head of state.

    THE GOVERNOR-GENERAL AND CEREMONIAL EVENTS

    There is one further aspect of the office of Governor-General which should be considered, and this also is relevant to the relationship between legitimacy and power within our system. Here, however, the arguments for an extended (or at least restored) role for the Governor-General are considerably stronger.

    Recently, there has been some public debate over the prospect of Prime Ministers undertaking great ceremonial functions of state that previously had been discharged by the Governor-General. This practice appears to have begun in earnest around the mid-1980s during the Hawke Government, but since that time, all Prime Ministers seem to have been equally guilty of elbowing the Governor-General from centre stage. Most recently, for example, we have seen Prime Minister Howard presiding over the Bali remembrance ceremonies, and more prosaically, over the opening of the World Cup rugby. Such occasions usually are analysed as cases of political, and perhaps constitutional, bad manners, but not much more. The reality, however, is that they are considerably more serious, for reasons which hark back to the division between legitimacy and power under our constitutional arrangements.

    What effectively is involved in these Prime Ministerial ceremonial hijacks is a deliberate attempt by politicians to break through the legitimacy–power divide. In essence, the politician who essays to captur`e some ceremonial moment of national importance is also attempting to attach to themselves some element of public legitimacy, and to strengthen the degree of identification between themselves and the state. By so doing, they enhance their personal and political prestige, and to some extent succeed in elevating themselves above the political brawl and their opponents.

    It was, of course, one of the great traditional advantages of the office of Governor-General that where an event was one of deep national, rather than merely political importance, it was performed by the apolitical Governor-General as a national focus. The Bali memorial service is a perfect example of such an event that properly belongs within the province of Australia's surrogate head of state. Similar reasoning would apply to ceremonies marking the completion of great state projects that were not the work of any one government, but true national achievements. The very positive effect of this traditional understanding was to limit any identification between a politician as a repository of power with the profound interests, achievements or griefs of the nation. When captured by political figures, these types of ceremonial events are dangerous for precisely these reasons, and they should be returned firmly to the hands of the Governor-General in the Commonwealth sphere, and the Governors in the State arena.

    CONCLUSION

    Essentially, the argument here has been that the office of Governor-General, in addition to its specific constitutional functions, does have a high constitutional dimension. Fundamentally, that dimension is to facilitate a separation between legitimacy and power within our constitutional system, so preventing a close identification between politicians and the state itself and its interests. This dimension is not easily consistent with an adventurous understanding of the office of Governor-General. It also is enormously important that, as Australia contemplates its future as a republic, this aspect of the Governor-General's role be translated intact to any future office of President.


    [*] Professor of Government and Constitutional Law, Curtin University. A version of this piece was presented as a paper at the Annual Public Law Weekend, Canberra, 7–9 November 2003.

    [1] A poll conducted in December 2003 indicated that 57 per cent of those polled wanted a further referendum on the republican issue: Newspoll, 6 January 2004 ( <http://www.newspoll.com.au/image_uploads/cgi-lib.11730.1.1202_2004_polls.pdf> at 27 June 2004).

    [2] For example, five of the six options in the current options paper of the Australian Republican Movement answer this description: Australian Republican Movement, '6 Models for an Australian Republic' (Discussion paper, 2001).

    [3] See Richard McGarvie, Democracy: Choosing Australia's Republic (1999) 18–19.

    [4] A sustained, but unconvincing argument that the Governor-General is Australia's true head of state is made in David Flint, The Cane Toad Republic (1999) ch 3.

    [5] Constitution s 2.

    [6] Constitution Alteration (Establishment of Republic) Bill 1999 (Cth) sch 3, cl 1.

    For example, some of those happiest to see Sir William Deane interpret his office expansively would have been appalled by any corresponding action on the part of Dr Peter Hollingworth.

    [8] Undoubtedly the best treatment is to be found in George Winterton, Parliament, the Executive and the Governor-General: A Constitutional Analysis (1983).

    [9] Constitution s 58.

    [10] Constitution s 5.

    [11] Constitution s 68.

    [12] See, eg, A V Dicey, Introduction to the Study of the Law of the Constitution (8th ed, 1915) ci–cii.

    [13] See, eg, Walter Bagehot, The English Constitution (1867) 111.

    [14] Admittedly, 'legitimacy' in this context is an imprecise and not very wieldy term, but it is difficult to arrive at a superior alternative. One possibility would be 'respect', but this too readily confuses feeling towards the incumbent with feeling towards the office. There is a limited analogy between the type of institutional legitimacy referred to here and the more commonly encountered 'democratic legitimacy', denoting not merely the fact of political power, but valid democratic title thereto; and see n 15, below.

    [15] As Winterton states (George Winterton, 'The Evolving Role of the Governor-General' (Paper presented at the Annual Public Law Weekend, Canberra, 7–9 November 2003)), a Prime Minister certainly will enjoy 'democratic legitimacy'. Yet this is a quite different sort of legitimacy to that enjoyed by the Queen and the Governor-General. It reflects a popular (and often highly grudging) acknowledgement of a right to power, rather than any particularly strong element of institutional respect.

    [16] The Queen retains certain theoretical constitutional discretions, including the very theoretical discretion to dismiss a government, but it is virtually impossible to imagine situations where the more significant of these powers practically could be exercised: see, eg, Stanley de Smith and Rodney Brazier, Constitutional and Administrative Law (7th ed, 1994) ch 6. The Governor-General certainly enjoys reserve powers, but these have been exercised only once in over a century of federation.

    [17] See Dicey, above n 12; and Bagehot, above n 13.

    [18] For example, it is hard to imagine the Queen actually exercising the reserve powers: see George Winterton, Monarchy to Republic: Australian Republican Government (1986) 32–3.

    [19] For example, the vicious attacks on the 'politicians' republic' by the No case during the 1999 referendum may well have done long-term damage to popular perceptions of parliamentary government.

    [20] Again, such ideas seem to underlie some of the thinking of Dicey and Bagehot in relation to the monarchy: see Dicey, above n 12; and Bagehot, above n 13.

    [21] See, eg, Winterton, above n 15.

    [22] See, eg, Sir Ninian Stephen, 'Depicting a Nation to Its People', The Weekend Australian (Sydney), 7 January 1989, 12.

    [23] By reference to such considerations, Article 13.7 of the Bunreacht na hÉireann (the Irish Constitution) requires that government approval be forthcoming before the Irish President can address the nation.

    [24] For a general critique of the public dimensions of a directly elected President, see McGarvie, above n 3, 136–9.

    [25] Analogous views underlay much of the feeling at the 1998 Constitutional Convention in favour of a similarly free-wheeling directly-elected President: see, eg, Commonwealth of Australia, Report of the Constitutional Convention (1998) vol 3, 42–5 (Ted Mack), 101–3 (Phil Cleary).

    [26] See Winterton, above n 15.

    [27] For example, the media advice proffered to and acted upon by the Governor-General, particularly in the early stages of the crisis, consistently served to worsen his position.

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