APPENDIX 3

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

SECOND MINORITY REPORT
CONTENTS

APPENDIX 3

Submission No 84 from Mr John Basten QC

 


COMMENTS ON 1996 AMENDMENT TO THE NATIVE TITLE ACT

1. BACKGROUND

1.1 My comments relate in part to of the Native Title Amendment Bill 1996 introduced on 27 June 1996, but also to the "exposure draft" tabled in the Senate on 8 October 1996. The main issue which I have considered is the consistency of the proposed amendments in relation to the rights to negotiate with the Racial Discrimination Act 1975 (Cth).

1.2 Conceptually, the proposed amendments to the right to negotiate provisions can be considered under the following topics:

1.3 Future acts are dealt with in Part 2, Division 3 of the Native Title Act. Subdivision B, entitled "Right to Negotiate" applies to certain "permissible future acts". It does not provide Indigenous people with a right of veto over all or any developments on their land: it provides, in identified circumstances, a right to negotiate with respect to proposed developments. The precise coverage of the right need not be identified for present purposes: however, it may be noted that the definition of "permissible future act" covers legislation which applies "in the same way to the native title holders ... as it would if they instead hold ordinary title", or at least does not cause them to be more disadvantaged at law than they would be if they held ordinary title, and applies to non-legislative acts which could be done in relation to the land if the native title holders instead held ordinary title to it: s.235(2) and (5). Thus, it is clear that an act is not a permissible future act if its application or effect is to disadvantage native title holders as compared with ordinary title holders. Because the comparisons made by s.235 require that consideration be given to the application or effect of acts if "native title holders instead held ordinary title" it appears that the drafter intended that the acts reflect formal equality, rather than substantive equality. The definition does not recognise the possibility that spiritual or cultural aspects of native title may demand different treatment from that accorded to holders of ordinary title.

1.4 Against this background, it is clear that the right to negotiate provisions were intended to have at least two areas of operation. In relation to persons whose native title had been the subject of a determination, the right to negotiate should appropriately have been seen as a recognition of the importance to native title holders of the power to control access to and activities on their land. Consistently with this approach, the right to negotiate will not necessarily apply in relation to a future act done in accordance with a registered Indigenous land use agreement see proposed s.25F.

1.5 In addition, the right to negotiate reflects a second purpose, namely to permit those who may be native title holders to negotiate the terms of access to land before the opportunity to determine their claims has been fulfilled.

1.6 In considering whether the right to negotiate, if amended as proposed, would provide substantive equality, it would be legitimate to test the legislation by a standard of strict scrutiny. In other words, given the absolute inappropriateness of discrimination on the basis of race, the Government should not be allowed a wide discretion in determining what protection is necessary for native title holders. Similarly, if the legislation is to be justified as a "special measure the Government has limited room to amend the Act given the historical treatment of native title and given the fact the NTA itself constitutes a balance between recognition of native title and validation of past intrusions upon that title.

 

2 - REGISTRATION OF CLAIM

2.1 The most important right given to native title claimants is the right to negotiate. Notice must be given to a registered native title claimant (s.29(2)(b)) and any person who becomes a registered native title claimant within three months after the notice is given is a native title party for the purpose of the negotiations: s.30(l). The registration of claims has been proceeding since the introduction of the Act, although claims made since July 1996 will be subject to the Transitional Provisions proposed by the amendments to which I refer below. As time passes, no doubt it is reasonable to assume that more and more plausible claims will be registered prior to the need to consider future acts. However, that process will be a slow one for various reasons. First, the preparation of a claim requires advice and resources which are limited and are likely to remain limited. Secondly, as with all human activity, there will be room for disagreement and disputation between Indigenous people in relation to claims. As with non-Indigenous people, disagreements take time to resolve. Accordingly, for some years hence, it will be important that there be a reasonably flexible scheme for the registration of claims, or else procedural fairness will require that the right to negotiate process may need to be delayed. Given the need to balance the interest of possible native title holders against the interests of continued development where native title may not exist, the proposedd principle should be to allow ready registration of claims with power to deregister where it can be demonstrated that the claims are frivolous or vexatious.

2.2 The proposed scheme does not reflect these principles. In order to participate in s.24A agreements or in the right to negotiate, claimants must satisfy quite onerous requirements: proposed s. 190A. There are a number of problems with this approach. First, unless by chance a representative body has anticipated the future act (and realistically, very few representative bodies currently have the resources to undertake this kind of exercise) it is most unlikely that the formulation of a claim would be sufficiently advanced for it to be lodged much inside a period of three months. However, what is to be required is not merely that the claim be lodged within that period, but that it be considered by the Registrar and a decision be made within that period if a relevant notice has been given. Surely it is quite wrong to make substantive rights of native title claimants depend not only upon the resources and priorities representative bodies (on whom they will rely, but over whom they will have no ultimate control) and on the resources, allocation of priorities and competence of a bureaucratic procedure to be conducted by the Registrar. In what other area do the rights of citizens depend upon the prompt action of bureaucrats in order to avoid extinguishment? This is a particularly unacceptable situation where government itself will usually have an interest in short-cutting or avoiding the right to negotiate.

2.3 Secondly, any disruption of the process, even that for which the claimant is not responsible and cannot control, may lead to the expiration of the prescribed three month period and the loss of the right to negotiate. For example, the Government party may well supply extensive material a week or two (or even a day or two) before the end of the period. The Registrar must consider that material: Subsection (4). Further, one of the non-native title parties may consider that the Registrar is carrying out his or her functions improperly and may seek relief from the Federal Court especially in the initial stages of the new legislative scheme, the obligations of the Registrar may well be subject to legitimate doubts and therefore frequent court challenges. The Registrar may quite properly think it inappropriate to continue consideration in the face of a Court challenge or may restrained by interlocutory injunction. Again, the three month period will expire and the claimants will lose their rights. Finally, the Registrar will, inevitably, make mistakes, whether of law or on the merits of the claim. Even if that is later judicially established, the claimant will suffer unavoidable loss because the three month period will have expired without a proper decision having been made.

2.4 There is no simple solution to these problems, other than to revert to a simple, registration process as under the present law. If protection is needed for non-native title parties, they should be given a right to challenge the registration as being frivolous or vexatious.

2.5 As noted above, there is a further aspect to the proposed amendments, contained in the Transitional Provisions, which is thoroughly objectionable in principle. It is that the new registration test will apply to all claims lodged on or after 27 June 1996: Schedule 3, part 2, cl.7(4). Further, where an application was made before 27 June 1996, and s.29 notice is given for the first time under the new Act, again, the registration must be reconsidered under s.19OA: cl.7(3). This latter provision provides a mechanism whereby almost every claim which has not yet proceeded to a determination of native title (and none have) may in effect be challenged by invoking the s.29 procedure with respect to some part of the land claimed- (27 June 1996 is treated as the date on which effective notice was given by the Government of the proposed amendments to the Native Title Act, including the inclusion of s.190A.) To reopen claims accepted prior to the amendment of the legislation has its own problems: to reopen claims lodged and accepted prior to the date on which the amendment was proposed is retrospective legislation, taking away a form of property right, and would simply not be tolerated were it applicable to the wider community. If there is evidence of abuse of the registration process, that can be dealt with in an appropriate manner to give carte blanche to retrospective reconsideration according to new standards, in the absence of any hint of abuse, is surely objectionable.

2.6 Apart from such objections of principle, there are also practical considerations which militate strongly against the Transitional Provisions. The unfairness of imposing a rigid time limit, which can only be fulfilled if the Registrar is able to act expeditiously and determine applications with great speed, has already been discussed. The Transitional Provisions give rise to a potential for increasing exponentially the work load of the Registrar. Any government or mining industry body which stands to benefit from avoiding the right to negotiate will surely have identified this potentiality already. To publish a flood of s.29 notices upon the enactment of s.190A will inevitably render the Registrar's task impossible and the provisions unworkable. The only people to suffering (apart from the Registrar and his or her staff) will be native title claimants. It is disingenuous to put forward these provisions in the supposed interest of improving "workability" of the procedures.

2.7 I have not stayed to consider various aspects of the tests imposed by s.19OA. These are, I understand, dealt with in a number of other submissions and publications which the Committee has received, including those of the Social Justice Commissioner and various Land Councils.

 

3. COVERAGE OF THE RIGHT TO NEGOTIATE

3.1 The present coverage of the right to negotiate is sought to be limited in two ways. First, it is proposed that, in relation to mining interests, renewals, regrants and extensions will not be the subject of the right to negotiate if the original title had been subject to the right: s.26B. There are three issues which need to be addressed in relation to this amendment.

3.2 First, it is presumably intended that the nature of the acts covered by subsection (a) are not intended to permit the grant of any more extensive interest than that which had been created by the earlier right to mine. The point could be clarified as in other provisions in the NTA, by making it clear that no larger interest was created by the new act.

3.3 Secondly, an issue arises as to the operation of the proposal. It might not be unfair to permit once only negotiation in circumstances where the possibility of a future negotiation was anticipated, should the right be extended or renewed. However, the present terminology would prevent further recognition in relation to an earlier right which had been covered by s.25(2) prior to the amendment. Thus, in theory, a short exploration licence, which had been subject to the right to negotiate, could be extended for a lengthy period without any further negotiation, even though that possibility had not been within the contemplation of the parties at the time the earlier right was the subject of negotiation.

3.4 Thirdly there is a restriction on the scope of the right to negotiate, where the later act is not merely the renewal or regrant or extension of the term of an earlier act, but is an act preceded by an act "consisting of the creation of a right to explore or prospect": proposed s.26B (2)(a). Whilst it appears that the later act could be further exploration, it is not so limited: accordingly, the later act could, as the explanatory memorandum recognises, involve mining. No further right to negotiate would arise where the negotiation had anticipated a possible grant of a mining right and that matter had been dealt with in the conditions of the resulting determination. In practical terms there appears to be no obligation on the parties to negotiate over such future acts and they will not, presumably, have failed to negotiate in good faith if a party declines to negotiate in relation to such later acts: cf. proposed s.31 (1)(a). Given the speculative nature of the process, it would seem undesirable to allow one party to force another to negotiate in relation to the possible interests in a mine, when all that is at stake is proposed exploration. That uncertainty must be increased in circumstances where the period of exploration may not be defined by the original grant or a right to explore, but may be extended without any further negotiation in accordance with the other part of s.26B.

 

4. EXCLUSION - BY MINISTERS

4.1 The Commonwealth Minister has always had the power to exclude an act from the coverage of the right to negotiate: s.26(3)(b). However, the criteria which must be satisfied include notification of a relevant representative body and of the public and the taking of submissions concerning the proposed exclusion, satisfaction of the Minister that appropriate consultation will take place with native title holders and, significantly, satisfaction that "the act will have minimal effect on any native title concerned": s.26(4). This limited right of exclusion has been extended in two ways. The first is the provision for "approved scheme acts" under proposed s.26A. This provision provides for the exclusion of acts or classes of act subject to a weaker criterion than that presently in s.26(4)(a), namely that, "the act is unlikely to have a significant impact on the particular land ...": s.26A(2)(b). Secondly, the nature of the Minister's satisfaction in relation to processes of consultation is spelled out in more detail. Where any other person (not a native title holder) would have a right to be heard by an independent body about the doing of the act, any person holding native title in relation to the land must have a right to be notified and to be heard by such body. Similarly, at least one of the people responsible for doing the act must have a legal obligation to consult (or there must be procedures in place under which such consultation will be required) "for the purpose of minimising the impact of the act of the exercise on the person's native title rights and interests ... ": s.26A(4)(c). In relation to the process of consultation, the amendments contained in the new Bill provide greater clarity and probably greater protection to native title holders. Both the present Act and the proposed amendments are deficient in failing to ensure that native title claimants are covered by the criteria.

4.2 There are four problems with this proposal. First, the broadening of the test for exclusion is apparent in the change from "will have minimal effect" to "is unlikely to have significant impact". However, the new provision also emphasises that the impact is impact on the "particular land". Consistently with the change to the test of an act attracting the expedited procedure, this test ignores impact on spiritual and cultural aspects of community life. This will seriously undermine the protection provided by the negotiation process.

4.3 Secondly, the third condition may not provide for effective consultation with persons holding native title: see s.26A(4)(c). Controlling access to and use of land is well recognised as central to protection of native title interests. This criterion does not ensure that the standards of negotiation provided in the NTA will be available from other sources, being presumably State and Territory laws.

4.4 Thirdly, the condition that persons holding native title be accorded the same rights as others holding an interest in the land is ambiguous and unsatisfactory. If the "interest" must have been established in accordance with legal procedures, even native title claimants will be ignored with impunity. If it means those who may hold native title, it is unlikely to be satisfied unless there is a provision in the other law equivalent to s.23(7).

4.5 Fourthly, this amendment must be read with an amendment to s.23(6) which excludes the protections contained in that subsection from approved scheme acts: see cl.98A. Exclusion from that guarantee of procedural equality should not be countenanced unless equal or better protection is provided elsewhere. The scheme of s.23(6) and (7) is designed to cater for the difficulties arising from the failure of our legal system to recognise native title in the past. It recognises that interference with native title will continue for some time unless particular measures are provided to deal with a period of continuing uncertainly. Accordingly, in my view these amendments, if passed, would mean that the NTA will fail to provide a minimum guarantee of substantive equality.

4.6 The second procedure by which acts can be excluded from the right to negotiate concerns the area of compulsory acquisition. The present Act permits the negotiation process to occur where compulsory acquisition is contemplated for the purpose of conferring rights or interests on persons other than "the Government party." (For this purpose, "the Government party" is the Commonwealth, a State or Territory s.26(l)) The new proposals allow the Commonwealth Minister to determine that the reason for the acquisition is to provide "a public infrastructure facility:" proposed s.26(2)(d)(i). That phrase is defined to include highways, railways, dams, electricity and water transmission facilities and "any other facility of a similar nature": proposed s.253. According to the explanatory memorandum, the justification for this area of exclusion is that such public infrastructure projects would "formerly have been constructed and operated by Government agencies" but are now being contracted out to third parties. A determination of the Minister under this provision is expressly provided to be a "disallowable instrument under the provisions of the Acts Interpretation Act: NTA(s.214-see cl.98 ZZW).

 

5. EXCLUSION - BY GOVERNMENT PARTY

5.1 The Act has always provided a means by which a Government party can exclude a future act from the negotiation process. It can do so by giving notice that it considers the act is "an act attracting the expedited procedure": s.29(4) and s.31 (1). In the case of an objection lodged by a native title party, the Act provided that the Tribunal should determine whether the claim by the Government was justified or not: s.32. In determining whether an act does attract the expedited procedure, the Tribunal is required to determine that three specific tests are satisfied: s.237. In particular, the first test is that the act "does not directly interfere with the community life of" native title holders: s.237(a).

5.2 It is proposed that this test, and the other limbs of s.237, be amended by substituting for "does not" the phrase "is not likely to" and, in relation to the third test concerning major disturbance to land or waters, the test of creation of rights "whose exercise will create major disturbance" is to be amended to "whose exercise is likely to involve major disturbance". The present formulation of the three tests in s237 is curious, as only the third test acknowledges that the act may not itself have the prohibited effect, but may create rights whose exercise will have that effect. A similar dichotomy would be desirable to clarify the operation of the first two tests. That having been said, it is logical to change the phraseology in relation to the exercise of rights by conceding that a prediction is required. So much has already been accepted and approved by the Federal Court: see Ward v. Western Australia (1996) 136 ALR 557.

5.3 More importantly, the test of direct interference with the community life of native title holders is to be amended to refer to direct interference "with the physical aspects of the community life" of native title holders. This is in my view, a significant diminution of the protections provided by the negotiation process. While it is not necessarily the case that native title entails maintenance of close spiritual links with land, in many cases there will be strong spiritual attachment to land and the maintenance of traditional laws and customs will also involve important cultural continuities. The preservation of Indigenous spirituality and culture must be at the heart of the rationale for recognising native title. Failure to accept that the negotiation process should apply where spirituality or cultural matters are directly threatened is inconsistent with this rationale. The important purpose of the negotiation process where spiritual aspects of community life are subject to interference was recognised in Ward v. State of Western Australia (1996) 136 ALR 557. There, Carr J expressly held that direct interference with community life is not confined to physical interference. In interpreting s.237(a), His Honour held that "there is no justification for requiring a direct interference with community life also to be a physical interference": see p.572(40)-573(15). The proposal to amend the Act so as to exclude such considerations seriously compromises the protection given by the negotiation process, particularly in relation to remote communities which may suffer most seriously from the development of a mine or similar activity, even if not in immediate proximity to their settlements.

 

6. CONTENT OF NEGOTIATION

6.1 In Wal!ey v. Western Australia (unrep 20 June 1996) Carr J held that the jurisdiction of the Tribunal to arbitrate did not arise unless the Government party had fulfilled its obligation to "negotiate in good faith with the native title parties ...": s.31 (1)(b). Thus the Federal Court held that negotiation in good faith by the Government party was a precondition to the exercise by the Tribunal of its arbitral function under s.36. The proposed new s.36(1A) would require the Tribunal to arbitrate even if not all parties have complied with the requirements of s.31(l)(b). However, by inference the amendment confirms that the party who applied for the determination (presumably under s.35) must have negotiated in good faith.

6.2 The content of the obligation clearly has importance in this context. The amendments to that provision are designed to ensure that all parties must negotiate in good faith pursuant to that section: see cll. 98Y-ZA. These amendments do not appear to be controversial. However, the addition of s.36(1A) is a matter of concern. It is plausible to assume that the Government and grantee parties will share a common interest in having the act go ahead. It is not satisfactory that one could stall negotiations while the other presses ahead in apparent good faith and makes application to the Tribunal. It would be more appropriate if the amendment in cl.98ZG read:

The absence of such protection, particularly in combination with the Ministerial intervention power provided by s.36A, could allow the complete subversion of the negotiating process. The mere existence of such a power would affect the perceived bargaining positions in an unacceptable manner.

6.3 The proposals also seek to define good faith negotiation by providing that there will be no refusal or failure to negotiate if the refusal or failure is concerned with matters unrelated to the effect of the act on the determined or claimed native title rights and interests ...": proposed s.31(1A)-cl.98ZB. The insertion of the proposed s.31(1A) is curious. On the one hand, it would seem obvious that failure to negotiate about matters unrelated to the proposed future act could not be said to indicate a failure to negotiate in good faith. However, the scope of negotiation is to be limited by the requirement that negotiation must be as to "the effect" of the act on "native title rights and interests". At the very least, there is a danger that the terminology adopted will discourage imaginative solutions to disputes. It is quite plausible and appropriate that, if the proposed act is the establishment of a mine, Indigenous people might wish to negotiate a level of employment. Arguably, such issues are unrelated to affect of the mine on native title as such, and hence would not be part of the good faith negotiation process under the proposed amendment. Surely such a result cannot have been intended?

6.4 Furthermore, the phraseology directs attention away from a pragmatic resolution of differences and directs it towards that very matter which cannot be resolved before a determination of native title has been made, namely the precise native title rights and interests existing. The same inappropriate change of focus is reflected in the proposed s.33(2). Even without reference to that proposal, the new s.31 (1A) seems inconsistent with s.33, which permits a far more extended scope for negotiations. A further question arises as to the inter-relationship of s.31(1A) and the criteria appropriately set out in s.39, with which, again, it seems inconsistent.

6.5 The idea behind s.33(2) is understandable. That proposal is apparently designed to permit negotiations to take into account the effect of "existing rights and interests in relation to the land concerned and "existing use of" the land concerned and the "practical effect" of the exercise of such rights and interests on the exercise of native title rights and interests". However, the present draft does not seek to distinguish between rights and interests which arose before the NTA, and may therefore be valid, and those which may not. Further, this proposal may unduly encourage parties in the course of negotiations to assess the validity and possible extinguishment of the native title claims, which would be inappropriate in this context.

 

7. INTERVENTION - BY MINISTER

7.1 The proposals seek to provide new powers of Ministerial intervention in two separate sets of circumstances. First, the relevant Minister may intervene and make a determination that the act may be done if certain conditions are satisfied, including a condition that the act is likely to be of "substantial economic benefit to Australia": see proposed s.34A(3). This power is vested in "Relevant Ministers" who may be Commonwealth or State or Territory Ministers.

7.2 The power given to Ministers under s.34A can only be exercised if three months have passed since the giving of a s.29 notice. That period is the period required for a native title claimant to register his or her claim, but one month less than the period for negotiation prior to the entitlement of a party to take the matter to the Tribunal. The Minister must be satisfied that if the determination is not made at that time, the substantial economic; benefit to Australia will at least be substantially reduced. Apart from anything else, it seems curious that a State or Territory Minister should be given the right to make such decisions.

7.3 There is provision that each negotiation party be given written notice that the Minister is considering making a determination and is entitled to 14 days within which to put written material before the Minister s.36B(l) and (2). They are also entitled to receive materials supplied by other negotiation parties within the period and have a further seven days to respond. Although any determination made by the relevant Minister must be laid before Parliament, it is not proposed, even in relation to the Commonwealth, that such an instrument be a disallowable instrument: see cl.98ZZW, which makes no relevant amendment to s.214.

7.4 Finally, a determination may not be made under s.34A unless the relevant Minister considers that "there will be significant benefits" to the relevant native title holders. No reference is made to possible detriments accruing to those native title holders, nor is any assessment of relative benefit and detriment required. In short, it would arguably be sufficient to satisfy this criterion if the Minister considered that there were economic benefits (perhaps by way of royalties) which would flow from the act, even though the community life of the native title holders might be seriously interfered with, their sacred sites affected and their cultural integrity lost. Although it is possible that a determination could be made under s.34A in the case of an act which could attract the expedited procedure, the power is very unlikely to be used in such a case and, more importantly, is certainly not limited to such decisions.

7.5 Under the existing provisions, the Tribunal is required to take "all reasonable steps" to make a determination, in the case of an exploration licence, within four months of the application being made and, in any other case, within six months. The new proposals would delete those periods and simply require the Tribunal to make the determination as soon as practicable: cl.98ZF. If the Tribunal does not make a determination within four months of the application, it must notify the Commonwealth Minister. At any time after a negotiation party has applied to the Tribunal, a relevant Minister may request the Tribunal to make a determination within a period of not less than four months after the application was made and, thereafter, the Minister may intervene to make a determination in relation to the act: proposed ss.36(3) and 36A. Again there are further criteria specified: the Minister must consider that the Tribunal is "unlikely to make its determination within a reasonable period" and that it is in the interests of the State or Territory or in the national interest to make a determination at that time. The consultation procedures referred to in relation to intervention under s.34A also apply in relation to intervention by a Minister pursuant to this provision.

7.6 This latter intervention power recognises (as does the present s.36) that the Tribunal should not generally be forced to make a determination within a particular time. However, instead of requiring the Tribunal to make a determination by the completion of the period specified in the written notice which may be given by the relevant Minister, the power of determination is taken away from the Tribunal altogether. Although the heading to the proposed new section states that it applies where the arbitral body determination is "unreasonably delayed", in fact it applies where the arbitral body is thought by the Minister to be unlikely to make a determination within a period considered by the Minister to be "reasonable". The criteria specified in s.36A are in substance a Minister's concerns as to the time taken by the negotiation process. The Minister's concerns need not be shared by any negotiating party, although the Government party may be the Government of which the Minister is a member. Further, the Minister is not required to take into consideration the criteria specified in s.39 of the Act nor is the power of intervention conditional upon negotiation in good faith.

7.7 The question of possible intervention by a Minister is one of importance. Future acts will usually involve development activities in particular States and Territories, which will often be treated as requiring expeditious treatment by the government of the State or Territory concerned. That government will also be a party to the negotiations. Giving a Minister of such a government a power to intervene in circumstances which will readily be fulfilled and a power to make a determination untrammelled by the criteria to be considered by the Tribunal, ie to allow the negotiation process to be sidestepped by one party. The role of the independent arbiter is thus severely undermined. The possibility of such intervention will have a chilling effect on all negotiations.

7.8 I conclude that the proposed power of Ministerial intervention is likely to undermine to a significant extent the conduct of good faith negotiations and the likelihood of fair agreements being reached. Any party which believes its interests are more likely to be met by a relevant Minister is likely to resist reaching a negotiated agreement on terms less favourable than those it expects from the Minister. The attitudes of relevant Ministers will clearly vary, depending on the Government of the day and the geographical area. There is no means of ensuring that a uniform approach is adopted, even at a given point in time, across the country.

 

8 CONCLUSIONS

8.1 The Government is to be congratulated on its reconsideration of the original suggestion that the right to negotiate be limited to registered native title holders. Further, a number of the amendments proposed are commendable attempts to clarify and simplify the procedures provided with respect to permissible future acts. I have not commented on these aspects of the amendments.

8.2 The matters I have dealt with above are matters which, to varying degrees impact adversely on the present entitlements of native title holders or claimants under the right to negotiate procedures. Individually, the most serious limitations on the right to negotiate are:

8.3 The matters referred to above deserve careful reconsideration. At the very least,

8.4 1 also suggest that the amendments in relation to public infrastructure facilities, s.26B and the transitional arrangements, the scope of project act notification, the content of good faith negotiations (s.31(1A) and s.33(2)), and s.39(1A) require further consideration.

8.5 The cumulative effect of these amendments is undoubtedly to reduce significantly the rights of native title parties in relation to negotiations concerning permissible future acts. If the current elements of the right to negotiate are considered appropriate in terms of consistency with the principles underlying the Racial Discrimination Act (and they could certainly be improved), any significant impairment of those elements will render the procedures less adequate for their purpose. The amendments could thus be seen as impairing the full effect and operation of the principles underlying the Racial Discrimination Act and amounting to an implied repeal of that Act to the extent to which they fail to provide an adequate negotiation procedure. In my view, each of the individual matters referred to in the preceding paragraph should be seen in this light. Both their individual and cumulative effects are matters of degree and judgment They do, however, lead to a serious curtailment of its effectiveness, so far as the protection of native title rights and interests is concerned.

8.6 In relation to the interpretation of the principles of non-discrimination established by the Racial Discrimination Act 1975 and the International Convention on the Elimination of All Forms of Racial Discrimination, I refer to my oral submissions to the Committee of 27 November 1996.

Frederick Jordan Chambers

6 December 1996 JOHN BASTEN, QC