CHAPTER 4

Seventh Report of the Parliamentary Joint Committee on Native Title and the Aboriginal and Torres Strait Islander Land Fund
TABLE OF CONTENTS

CHAPTER 4

The RDA and Native Title

4.1 The Racial Discrimination Act 1975 commenced operation on 31 October 1975. The most relevant aspects of the RDA for the purposes of this report are as follows:

PART II - PROHIBITION OF RACIAL DISCRIMINATION

Exceptions

8. (1) This Part does not apply to, or in relation to the application of, special measures to which paragraph 4 of Article 1 of the Convention applies except measures in relation to which subsection 10(1) applies by virtue of subsection 10(3).

(2) This Part does not apply to:

(3) In this section, "charitable benefits" means benefits for purposes that are exclusively charitable according to the law in force in any State or Territory.

 

Racial discrimination to be unlawful

9. (1) It is unlawful for a person to do any act involving a distinction, exclusion, restriction or preference based on race, colour, descent or national or ethnic origin which has the purpose or effect of nullifying or impairing the recognition, enjoyment or exercise, on an equal footing, of any human right or fundamental freedom in the political, economic, social, cultural or any other field of public life.

(1A) Where:

the act of requiring such compliance is to be treated, for the purposes of this Part, as an act involving a distinction based on, or an act done by reason of, the other person's race, colour, descent or national or ethnic origin.

(2) A reference in this section to a human right or fundamental freedom in the political, economic, social, cultural or any other field of public life includes any right of a kind referred to in Article 5 of the Convention.

(3) This section does not apply in respect of the employment, or an application for the employment, of a person on a ship or aircraft (not being an Australian ship or aircraft) if that person was engaged, or applied, for that employment outside Australia.

(4) The succeeding provisions of this Part do not limit the generality of this section.

 

Right to equality before the law

10. (1) If, by reason of, or a provision of, a law of the Commonwealth or of a State or Territory, persons of a particular race, colour or national or ethnic origin do not enjoy a right that is enjoyed by persons of another race, colour or national or ethnic origin, or enjoy a right to a more limited extent than persons of another race, colour or national or ethnic origin, then, notwithstanding anything in that law, persons of the first-mentioned race, colour or national or ethnic origin shall, by force of this section, enjoy that right to the same extent as persons of that other race, colour or national or ethnic origin.

(2) A reference in subsection (1) to a right includes a reference to a right of a kind referred to in Article 5 of the Convention.

(3) Where a law contains a provision that:

not being a provision that applies to persons generally without regard to their race, colour or national or ethnic origin, that provision shall be deemed to be a provision in relation to which subsection (1) applies and a reference in that subsection to a right includes a reference to a right of a person to manage property owned by the person.

4.2 To summarise and simplify these provisions:

The Attorney-General's Department has advised that:

4.3 In Mabo (No1) a majority of the High Court held that the Queensland Coast Islands Declaratory Act 1985 (Qld) would have extinguished native title but for the operation of s.10 of the RDA. The state legislation was accordingly rendered inoperative.

4.4 The view taken by the High Court about the RDA in Mabo (No2) is less straightforward. Prior to the RDA, grants of land extinguished native title; a majority of the High Court held in Mabo (No2) that extinguishment of native title by inconsistent Crown Grant did not give rise to a claim for compensatory damages. For grants made since the commencement of the RDA in 1975, however, it has been suggested that where such a grant would have the effect of extinguishing native title interests without compensation, and where such a grant would not extinguish other relevant interests without compensation, the effect may be discriminatory in relation to a human right to own property and not be arbitrarily deprived of it. [2]

4.5 Comment was made on this issue by the Attorney-General's Department in August 1993 as follows:

There is doubt as to which view a court would take (see, eg, Toohey J's comment that 'nothing in this judgement should be taken to suggest that the titles of those to whom land has been alienated by the Crown may now be disturbed': 153, and compare it with his comments about the impact of the RDA: 167-169). On the latter view, statutory titles are valid and the RDA may give native title holders a right to compensation, subject to the operation of statutes of limitations. On this view, appropriate compensation would be due to holders of native title, where this has been extinguished or impaired. (It is also perhaps arguable that, in the case of mining leases, the RDA would operate to prevent the extinguishment of native title. The rights of conventional property owners are not permanently curtailed or extinguished by the grant of a mining lease; rather, there is only temporary interference during the term of the lease. If, as is [sic] may well be the case, a mining lease permanently affects native title, equality of treatment might require that native title rights survive the grant of a mining lease, with compensation payable for the temporary disturbance of rights.) On the former view, the RDA may in some cases render wholly or partly invalid State laws or grants. [3]

4.6 For this reason, ss.14, 15, 19 and 229 of the Native Title Act 1993 provide for the validation for 'past acts'. (Section 7(1) provides that nothing in the NTA affects the operation of the RDA and s.7(2) provides that 7(1) does not affect the validation of past acts.) Land grants first made between October 1975 and January 1994 now are valid and compensation may be payable. Crucially, however, and concerning extinguishment, the question is whether any native title rights have survived. The wording of the NTA (s.15) is that 'the act extinguishes the native title concerned'. It may be an open question whether rights such as a right to negotiate, if it is a native title right, has survived this legislative act.

4.7 Similarly, with regard to land grants that were validly issued prior to October 1975 (and, therefore, not subject to the RDA), the question remains whether the native title rights that may have survived (which is a matter largely for the courts) are, since October 1975, protected by the RDA.

4.8 The Commonwealth Departments have advised [4] that the High Court did not feel compelled to take into account the particular characteristics of native title when determining whether the Land (Titles and Traditional Usage) Act 1993 (WA) and the NTA were inconsistent with the RDA: the Departments quote the judgement:

4.9 Since the commencement of operation of the NTA, of course, native title is also protected pursuant to the Act. Notably, the Preamble to the NTA states that:

It has already been noted that s.8 of the RDA allows 'special measures' which confer benefits on racial grounds.

4.10 Submission No 82 from the Commonwealth Departments confirms that the basis of the NTA was the provision of special measures and a 'dualistic approach of formal equality':

4.11 If native title, (perhaps) including a right to negotiate, is protected by the NTA, what scope is there for amending the NTA without being inconsistent with the RDA? Under the RDA 'special measures' (s.8) may be either conferred or withdrawn by legislative act. The Commonwealth Departments have advised:

4.12 Nevertheless, an alternative view has been put concerning the question whether the parliament may legislate to amend the NTA without offending the RDA. Paragraph 4.4 of the First Minority Report, in referring to an advice of Mr John Basten QC, suggests that the RDA requires substantial (or substantive) rather than merely formal equality with regard to respect for rights. One aspect of this view is that native title as a property right has traditionally included something like the right to negotiate, and that legislation should respect the 'whole bundle' of native title rights if the 'whole bundle' of non-Indigenous title rights are afforded similar respect (even though the contents of the bundle may differ). Another possible implication is that the right to negotiate is necessary for the dignity of Indigenous people in socio-economic terms; ie to bring Indigenous people to par with non-Indigenous society.

4.13 On this view, the guarantee of formal equality in s.235 of the Native Title Act is necessary, but not sufficient, to comply with the principles in the RDA; to comply with the RDA and achieve substantive equality the right to negotiate would also be necessary. The withdrawal or restriction of the right to negotiate, by way of a more stringent registration test or any other measure, would then be contrary to the principles in the RDA. Crucially, benefits for native title holders under the NTA would not be regarded as special measures but merely 'benign discrimination'.

4.14 This alternative view is supported by the Aboriginal and Torres Strait Islander Social Justice Commissioner (at pp.20 to 25 of his Native Title Report: 1994-1995, which quotes an excerpt from an advice by Mr Basten QC), and an article by W. Sadurski entitled Gerhardy v. Brown v. The Concept of Discrimination: Reflections on the Landmark Case that Wasn't (1986) 11 Sydney Law Review 5. This view would appear to run counter to the High Court's exposition of the relevant principles in Gerhardy v. Brown. However, there is a passage in Western Australia v. the Commonwealth which suggests that the High Court has acknowledged the existence, if not necessarily the merit, of the alternative view.

4.15 The alternative view, advocating that the acknowledgment of native title rights (including the right to negotiate) does not amount to a special measure but is in fact given to ensure substantive equality, is confronted with questions of legal fact. The Attorney-General's Department has advised the Committee that the substantive equality approach has not yet been accepted in Australian law. Even were it so accepted, a substantive equality approach would not require governments to make laws with that objective; it would simply enable them to do so. [8]

4.16 This has been contested by Mr John Basten QC. Mr Basten relies on a footnote to a passage from pages 483 to 484 of the Commonwealth Law Reports in Western Australia v. the Commonwealth:

Mr Basten expressed confidence that the High Court will accept that benign discrimination is appropriate. [10] Mr Basten further argued that the special measure provision itself may import a positive obligation under international convention: in other words, a positive obligation on government to enact special measures where appropriate and necessary. He claimed, further, that if substantive equality is the correct approach, it positively means that the Racial Discrimination Act does not accept conduct which fails to recognise the inequalities which may arise in the context of race. [11]

4.17 There are two major difficulties for Mr Basten's argument. First, it remains true as a matter of fact that the law in Australia has yet to move to an acceptance of the benign discrimination or substantive equality view. Mr Basten himself acknowledges this, although he believes that there is a 'very real likelihood' of the position changing in the future. [12] It is difficult to share Mr Basten's expectation in this matter, or his reliance on the footnote in Western Australia v. the Commonwealth (1995). Further, the Committee cannot support any suggestion that the passage referred to in that judgement clearly identifies the NTA as 'benign discrimination'; the relevant sentence is :

Arguably, the High Court merely noted the possibility in theory that the 'benign discrimination' view presented an alternative to the 'special measure' approach. To suggest that the High Court is likely to move to the 'benign discrimination' position in the future is to draw an unacceptably long bow. When it came for the High Court to actually decide in the case of Western Australia v. the Commonwealth, it took the formal equality approach:

4.18 Second, if the alternative view is correct, the States and Territories (whose legislation is subject to the RDA) might have to consider the differential impact of a number of kinds of legislation on the various races or ethnic groups within the State or Territory. Mr Basten himself has offered the opinion that if substantive equality is the correct approach, one cannot say that it is permissive only. [14] Hypothetically, this might have implications extending, for example, to industrial relations, consumer or residential tenancy legislation. And the question of conformity with the RDA would, on the alternative view, be reviewable by the High Court which would have to consider social and economic questions arguably more suited to the political arms of government (which have parliamentary committees and other ways of acquiring information on social, economic and political policy issues). On the Government's view of the RDA the question whether measures should be instituted to bring about substantive equality would be a matter for parliament, with limited court review.

4.19 In summary, the Government's view is that the right to negotiate is a 'special measure'; as such it is permitted, but not required, by the RDA; and it may be modified without offending the principles in the RDA. The alternative view is that the RDA requires substantive equality (or equality of outcome); that the right to negotiate is necessary to achieve such equality as between native title holders and ordinary title holders in relation to the enjoyment of their property and possibly other rights; and that the impairment of the right to negotiate would therefore infringe the RDA. This report argues that the alternative view cannot be accepted, and that the 'special measures' provided under the NTA can be modified without offending the RDA.

4.20 Finally, the Committee notes another issue raised by Mr Basten QC. He suggested that if the Native Title Amendment Bill is inconsistent with the RDA, then it impliedly amends the RDA to the extent of such inconsistency. And if that results in the RDA corresponding less closely to the terms and intent of the International Convention on the Elimination of All Forms of Racial Discrimination, the constitutional support for the RDA in its modified form disappears (the argument being that the RDA is dependent on close correspondence with the Convention and the support of the external affairs power in s.51(xxix) of the Constitution). Mr Basten advised the Committee:

This argument depends on the premise that the Native Title Amendment Bill 1996 and Exposure Draft provisions are inconsistent with the RDA. That premise is not accepted for the reasons already outlined.

 

Footnotes

[1] Evidence, p.3595.

[2] Mabo The High Court Decision on Native Title AGPS 1993, p.24.

[3] op.cit., pp. 15, 16.

[4] Submission No 82, op.cit., p.5.

[5] Native Title Act 1993, Preamble, p.3.

[6] Submission No 82, op.cit., p.3.

[7] ibid, p.2.

[8] Evidence, pp.3595 - 3600; the passage from the Law Reports, including the footnote, is reproduced in this report at Appendix 2.

[9] Evidence, p.3609.

[10] Evidence, p.3612.

[11] ibid.

[12] Evidence, p.3612.

[13] Evidence, p.3620.

[14] ibid.

[15] Evidence, p.3609.