George Williams 'The Role of Parliament under an Australian Charter of Human Rights'

Papers on Parliament No. 51
June 2009

Background

Australia is now the only democratic nation without a national Bill or Charter of Rights. Some form of protection for basic rights is seen as an essential component of modern democratic governance around the world. No democratic nation has ever done away with its Bill or Charter of Rights, and over time they have assumed bipartisan support.

Bringing about a national human rights law has been federal ALP policy since 1969, though the first attempt to bring about such a law anywhere in Australia was not by the ALP, but by the Nicklin Country Party Government in Queensland in 1959. This shows how the issue crosses party lines, and indeed some of the strongest supporters of the reform today fall with the Coalition ranks.

While such a law has now been achieved in the ACT in 2004 and Victoria in 2006, every attempt to achieve the reform at the national level has failed. Now there is again a once in a generation opportunity to achieve this reform.

The Rudd Government announced a National Human Rights Consultation on the 60th anniversary of the Universal Declaration of Human Rights on 10 December last year. It comprises Father Frank Brennan (Chairperson), Mary Kostakidis, Mick Palmer, Tammy Williams and Philip Flood (as an alternate when Mick Palmer is unavailable). The deadline for submissions is 15 June 2009. It must report to the Australian Government by 31 August 2009.

I am confident that the process will lead to strong community support for a national human rights law, based upon:

Underlying popular support

A survey published in 1997 of 1505 citizens indicated 72 per cent support.
In 2006 Amnesty International Australia commissioned a nationwide poll of 1001 voters by Roy Morgan Research. Sixty-nine percent said that they were very likely or likely to support a national Bill or Charter of Rights.

Experience in places like Victoria

Eighty-five per cent across all political divides wanted human rights to be better protected by the law. They did not want radical change, but reform to strengthen democracy.
Some wanted their human rights better protected to shield themselves and their families from the potential misuse of government power.
For even more people, the desire for change reflects their aspiration to live in a society that reflects common values and responsibilities. People want to live in a community based on equality, justice and the idea of a ‘fair go’ for all.

Does Parliament need a Charter of Human Rights?

I welcome the chance to look beyond the arguments over the pros and cons of Bills of Rights, and to focus on the role of Parliament. Indeed, my starting point is that I support a Charter of Human Rights for Australia not because I seek to transfer power to the courts (although I do see better checks and balances in this area as being desirable), but because I see it as a means to improve the workings of Parliament and its deliberations, and especially its scrutiny of executive action.

I believe that we need legal reform that drives parliamentary change when it comes to human rights, and especially the rights of people in Australia who are most marginalised and disadvantaged and whose voices are heard too rarely within Parliament.

My own thinking has changed significantly on this issue. It began when I walked into the High Court building in Canberra in early 1992. I had come straight from law school and was lucky to arrive at the beginning of the most interesting and active year in the court’s history. That year the Mabo case and early free-speech cases marked the peak of the Mason court’s impact on Australian law and government. It was a year when the court demonstrated it could play a major role in shaping Australian democracy. As a young graduate, it seemed to me that the court had all the answers and arguments for a leading judicial role.

I no longer believe this, and indeed see the judiciary as having an often minor, largely supporting role, under an Australian Charter of Rights. Parliament, and also the executive, needs to play the more important role. Why?

The key aim is to prevent human rights violations occurring in the first place, not merely to provide remedies for their breach (hence, must get laws and policies right at first instance).
To make the greatest difference to human rights protection, the real game is not in the few cases that are reported in the media and might go to court, but in service delivery and day to day decision-making by the executive.
Difficult pathways of partisan politics must be navigated to achieve lasting results (for example, native title was a momentous achievement, but this foundered as new judges were appointed. The court alone could not forge a lasting political settlement.) Lasting reform can often only be won by democratic engagement and political leadership.

That said, does Parliament really need reform when it comes to protecting human rights? Yes, the evidence shows:

Processes

Inadequate scrutiny, especially when one side of politics controls both houses.
Human rights are not considered in a systemic and effective way. Under Senate Standing Order 24 the Senate Standing Committee for the Scrutiny of Bills is charged with reporting whether Bills and Acts: ‘trespass unduly on personal rights and liberties’. Nothing lists the extent to which government can trespass upon our core rights or what these rights are. This is ignored anyway in many key debates, eg, anti-terror laws.
Human rights arguments can lack legitimacy. In the absence of a Charter, human rights language and concepts can lack political and legal legitimacy in parliaments and the community. As a consequence, Australia is an example of a country where people and parliaments do not always take human rights as seriously as they should.
Problems with the speed and volume at which new laws made. One of the most contentious laws of recent times is the 2007 NT intervention legislation, which, for example, suspended the Racial Discrimination Act. It required a robust debate to get the law right (a prime function of Parliament). But when the Northern Territory National Emergency Response Bill was introduced into the House of Representatives on 7 August 2007 (a package of five bills of 480 pages first viewed on that day), debate on the bill commenced at 9:02pm, and the bill passed at 9:15pm. Scrutiny was better, but not adequate, in the Senate, where debate amounted to 19 Hansard pages.

Outcomes

Detention of children seeking asylum.
Suspension of the Racial Discrimination Act twice in the last decade.
Anti-terror laws—44 (1 every 7 weeks). Consider for example, that:
The Attorney-General can issue a certificate to close a court from public view and restrict evidence a defendant can see.
The detention of non-suspects by ASIO for intelligence gathering, with up to five years jail if they do not co-operate and a ban on publishing information about the detention for two years (including for torture).

These can be fixed by Parliament (for example, children in detention) but often only years after the event, and after people have been damaged, or sometimes not fixed at all. A key part of the problem is the lack of a proper check and balance for democratic rights. The only check may be our trust in parliamentarians’ wisdom and common sense. This leads to human rights often not being given proper consideration, rights being undermined in a hasty and ill-considered way and the situation being made worse at times of national fear or crisis or when one party controls both houses.

Parliament or the courts as rights protector?

The reform debate is often reduced to: who best protects rights, parliaments or the courts? For me, the answer is ‘both’. Neither by itself is sufficient.

Hence, aspirational standards for Parliament, such as the Qld Legislative Standards Act 1992, are not acceptable. They do not work. After more than 17 years, this Act has had little impact. Unsurprisingly, self-enforcement by Parliament of human rights standards is not effective.

I have three reasons why the judiciary and Parliament need to be involved in the protection of human rights under a national Charter of Rights.

The effective protection of human rights requires that a body besides Parliament be involved. Parliament, as has often been the case in Australia, has proved unable or unwilling to protect some of the most basic rights and freedoms of members of the Australian community. The record is clear. The number of contemporary human rights concerns that have arisen due to new laws passed by the federal Parliament is, unfortunately, very long indeed. Such examples demonstrate how Parliament, by itself, can prove ineffective in protecting not only the rights of minorities but also some basic political freedoms. The election of the Parliament every three years is no cure for this, especially when the rights of non-voters, such as children, are considered.

At a time of community fear either of terrorism or invasion from outside, there are strong currents that can be taken advantage of that undermine human rights. This is always the case in democratic systems, but a system without a Charter of Rights involving a role for the judiciary is especially vulnerable.

The problem is magnified when a government gains control of both houses of Parliament. The only significant limit that may now come into play is the integrity and good sense of our elected representatives, something that manifests itself in the occasional person crossing the floor or backbench government revolt. At this and other times, more checks and balances are needed.

Even when Parliament plays an effective deliberative and scrutiny role, this does not negate the need for judicial involvement. Parliament has many strengths as a deliberative chamber, including its capacity to bring an authoritative resolution to division within the community and through deliberation to enact carefully tailored laws to meet pressing social problems. However, it also has weaknesses. For example, Parliament can lack the rationality and analytical capacity that judges, especially judges of appeal, can bring to questions of law. Judges also have a particular advantage that parliamentarians do not. Judges usually look at a problem not in the heat of the moment but sometime afterwards and can analyse an issue in light not only of the underlying policy need but also with the benefit of hindsight given how the law has actually operated. Judges are also able to analyse how the law has impacted on a person at a very specific level, something that can easily be lost in the generalities of lawmaking in Parliament.

My argument is not that the court should replace Parliament (or in any way better), only that the courts have something to offer that Parliament does not. It is also not an argument that the courts should have a final say. My view is that the role of the courts can be complementary to that of Parliament and that when we are dealing with questions of human rights there is a role for a dispassionate, independent, rational decision-maker who with the benefit of hindsight is able to examine how a law operates on the rights of an individual.

Third, the courts must have a role to bring out the best in Parliament. A lack of any judicial involvement affects the parliamentary process. Self-enforcement by Parliament of human rights is not effective. Or, to put it another way, the presence of an external check and balance can have a positive effect on Parliament. If there is no capacity for human rights principles to be raised in the courts through a Charter or other means, they can fail to receive examination by Parliament. Politicians are pragmatic, and often deal only with issues that are pressing and need attention. Hence, political debate and committee inquiry processes in the federal Parliament are often sparked by concern that legislation may be declared unconstitutional.

Without the possibility of post-enactment scrutiny by the judiciary on human rights grounds, there may not be an incentive for pre-enactment scrutiny to occur within the legislative process. Hence, a significant advantage of a Charter of Rights is not so much the dialogue that may follow a judicial decision, but the deliberation that begins within the legislative body before any such decision.

The parliamentary rights model

I support a national Charter of Human Rights in the form of a parliamentary rights model, to use the term coined by Canadian Professor Janet Hiebert and others. This would be based on the NZ Bill of Rights Act 1990, UK Human Rights Act 1998, ACT Human Rights Act 1994 and finally the Victorian Charter of Human Rights and Responsibilities 2006.

The newly enacted Victorian Charter reflects how human rights can be protected by simultaneously providing the judiciary with an important, but limited, function and also retaining parliament sovereignty. The Charter is not modelled on the United States Bill of Rights. It does not give the final say to the courts, nor does it set down unchangeable rights in the Victorian Constitution. Instead, it is an ordinary Act that can be changed over time by Parliament.

The Charter protects those rights that are the most important to an open and free Victorian democracy, such as the rights to expression, to association, to the protection of families and to vote. The rights in the Charter are not absolute and can be limited, as occurs in other nations, where this can be justified as part of living in a free and democratic society. Elected representatives in Victoria continue to make decisions on behalf of the community about matters such as how best to balance rights against each other, protect Victorians from crime, and distribute limited funds amongst competing demands. The Charter even recognises the power of the Victorian Parliament not just to balance such interests but to override the rights listed in the Charter where this is needed for the benefit of the community as a whole.

An important aim of the Charter of Human Rights and Responsibilities is to create a new discussion on human rights between the community and government. A key innovation of the Charter is that rights and responsibilities are taken into account from the earliest stages of government decision-making to help prevent human rights problems emerging in the first place. The key aspects of this model are:

Public servants will take the human rights in the Charter into account in developing new policies.
Public authorities like government departments are required to comply with the Charter. If they fail to do so, a person who has been adversely affected by a government decision, as is possible now under Victorian law, will be able to have the decision examined in court. There is no right to damages.
Government departments and other public authorities can undertake audits of their programs and policies to check that they comply with the Charter.
Where decisions need to be made about new laws or major policies, submissions to Cabinet are accompanied by a Human Rights Impact Statement.
When a Bill is introduced into the Victorian Parliament, it is accompanied by a Statement of Compatibility made by the person introducing the Bill, setting out, with reasons, whether the bill complies with the Charter. This enhances scrutiny of the executive. Parliament will be able to pass the bill whether or not it is thought to comply with the Charter.
Parliament’s Scrutiny of Acts and Regulations Committee has a special role in examining these Statements of Compatibility. It advises Parliament on the human rights implications of a bill.
Victorian courts and tribunals are required to interpret all legislation, ‘so far as it is possible to do so consistently with their purpose’ in a way that is compatible with human rights.
Where legislation cannot be interpreted in a way that is consistent with the Charter, the Supreme Court may make a Declaration of Inconsistent Interpretation. This refers the law back to Parliament, but does not strike it down. Parliament can decide to amend the law or to leave it as is.
Where the circumstances justify it, Parliament can pass a law that overrides the rights in the Charter. This prevents a Declaration of Inconsistent Interpretation being made for five years. The override can be renewed.

What does the record show in the United Kingdom and Victoria?

A lawyers’ picnic?

United Kingdom. Impact of the UK law on the courts is monitored by the Human Rights Unit of the Department for Constitutional Affairs. It has been found that the Act has not produced a significant increase in litigation or a ‘litigation culture’ (an increase of less than half of one per cent). Not only did few cases involve questions of human rights law, but where such issues were raised they were, in general, ‘as additional points to existing cases’ that could have been lodged ‘even if the Act had not been in force’.

In Scotland, a study found that human rights arguments were raised in ‘a little over a quarter of one per cent of the total criminal courts caseload over the period of the study’. Overall, the authors concluded that ‘it seems clear that human rights legislation has had little effect on the volume of business in the courts.’

Victoria. Attorney General Rob Hulls said: ‘There have been a very small number of Charter arguments raised in Victorian courts. I think about seven. I think each and every one of those has either been withdrawn or dismissed.’

There has now been one successful case invoking Charter. The Victorian Civil and Administrative Tribunal handed down its decision in Kracke v Mental Health Review Board in April 2009. The Tribunal found that a mentally ill man's human rights had been breached. He had been forced to undergo drug treatment by the state, but his case had been ignored for years and his human right to a fair hearing had been breached by a ‘deplorable’ and ‘inexcusable’ system failure which denied him reviews of his medical treatment in a reasonable time.

Every case litigated under the Charter was also brought on non-Charter grounds. The myth that Charters of Rights create a ‘lawyers’ picnic’ is unsubstantiated. In any event, with almost no exceptions, Chartercases for disadvantaged Victorians are run pro bono.

Does it undermine parliamentary sovereignty?

United Kingdom. Far from it. The Human Rights Act has invigorated debate and scrutiny on human rights issues, especially due to the work of the UK Joint Committee on Human Rights (for example, in relation to anti-terror laws). I have spent time in the UK observing the work of that committee, and have spoken to UK parliamentarians and read their debates. The Act has been positive in enhancing both debate on new laws and the scrutiny function of Parliament when it comes to the work of the executive.

Victoria. The Charter of Rights has not shifted power to the judiciary. Contentious social policy issues continue to be determined by Parliament. Far from threatening democracy, the Victorian Charter entrenches and enhances democratic values.

Has it made a difference to people’s lives?

United Kingdom. Yes. The November 2008 report from the British Institute of Human Rights on the impact of the UK law, marking ten years of the UK Human Rights Act, found: ‘that the Human Rights Act is protecting vulnerable people from abuse and poor treatment in public services.’

Victoria. Yes. In individual cases:

The Charterprevented the eviction of a single mother and her children from public housing into homelessness.
A 19-year-old woman with cerebral palsy relied on the Charterto obtain support services and case management.
Children with autism were deemed eligible for disability support services after their advocates invoked the Charter. This lead to an additional $2.75 million in support by the Community Services Minister who said: ‘this will make a major difference to the lives of many Victorian families facing the challenge of raising a child with an autism spectrum disorder.’
Assisted an elderly woman with brain injury to access critical medical assistance. The woman required urgent therapy to treat severe contractures of her left hand. They caused considerable pain and suffering and resulted in deterioration of her hand. Although the woman had been waiting for therapy for over three years, she was not considered a priority because she was aged over 50. If medical services were not provided, radical surgery could have been be required, such as severing the tendons in her fingers or even amputation of the hand. Using the Charter, her advocates were able to argue for and gain her medical treatment.

None of these cases went to court.

In terms of system change, the Victorian Department of Human Services (largest state government department that covers Health, Mental Health, Senior Victorians, Community Services and Housing and directly employs more than 13 000 people and funds organisations such as hospitals, aged care facilities, ambulance services and community service agencies that collectively employ more than 80 000 people) is:

Revising law and policies on involuntary detention for mental illness in the Mental Health Act 1986 to give a person more of a say in their own treatment.
Changes to disability housing to change models and culture from directive to participation and personal decision making.

Conclusion

I support reform in Australia to bring about a national Charter of Rights. I support this because human rights need better protection in Australia, especially the rights of the marginalised and disadvantaged for whom the existing political process can fail to work.

I also support the change for reasons of institutional design. I believe that a Charter, like that enacted in the UK and Victoria, can provide an important but limited new role for the judiciary while also improving the performance of Parliament. Indeed, without such a Charter, Parliament is less likely to fulfil its promise.

Question — My two questions to the panel are: why hasn’t Australia signed the United Nations Convention on Human Rights? And in recent days we have seen the family law courts violating some kind of parents’ rights, like fathers’ rights, and the children are becoming alienated or estranged from their fathers or main parents. This discriminatory practice of violation of the child’s rights or the father’s rights is very prominent. What are you going to do about it?

George Williams — Well the first question was asking why Australia hasn’t signed some of these international human rights conventions, and the answer is we have. In fact Australia is one of the very best at international citizenry when it comes to signing up to international human rights conventions. Better even than the United States and many other countries. When we signed those conventions we adopted an obligation to make those conventions part of our law which we never did. We are in breach of international law and this tells a bit of a story about Australia. Internationally we have, with some past disturbing exceptions, a justifiably good reputation on the international stage. Don’t forget that H.V. Evatt, an Australian, was one of the leading drafters of the Universal Declaration of Human Rights. I think we should be very proud of that. What we shouldn’t be proud of is that every other democratic nation has recognised the value in taking those international standards and putting them into law. We haven’t. There’s something that is wrong there between the dichotomy of what we do internationally and what we do at home that perhaps is only explained by a level of complacency about our human rights problems that I think we need to acknowledge.

The other question was about issues of child protection and the like. I would say that in Victoria and elsewhere child protection is one of those areas where charters and human rights standards have a lot of work to do. They are very difficult issues; policing is another example as well where they have a lot of work to do. I think the value of a Charter is not that it directs the outcomes in what can be very difficult, often traumatic cases, but it does ensure that when decisions are made they are made with the benefit of understanding of the rights of fathers, of mothers, of children, of others, and that decisions are made in the most respectful and just way possible. But it doesn’t direct the outcomes. It can’t. There needs to be room for individual discretion, but exercised according to what are just and fair criteria.

Question — I am interested in questions of enforcement and remedies and I wasn’t clear in your model how it works. On the one hand you said that if one is successful in a court, the judges will send the legislation back for review, so that’s the remedy. On the other hand, in the other extreme you have the situation where individual clients are getting outcomes without ever going to court. I guess my question is: is there a role for an individual litigant to go to court and get a remedy enforced in their favour?

George Williams — Yes. Most of these don’t go to court because a good law operates in the way that the standards are clear and you don’t need to litigate. So I think a good model says keep it out of court as much as possible, it’s too expensive, access to justice is too difficult and indeed I would say that if we start getting large volumes of litigation in the court then there is something wrong with the way that it’s operating. The court needs to be there though, because in the end you have to have a remedy and sometimes governments do make decisions in a really bloody-minded way that I think there does need to be a remedy for.

In Victoria you have the remedy of having statutes interpreted where possible to be consistent with your rights, and if that can’t be done, sent back to Parliament to be looked at again. But also, and I didn’t get to develop this in my talk, a range of remedies around administrative law. Which means that if a government agency, for example in aged care, is breaching a basic right you might seek an injunction to prevent that incurring. You might also seek a decision to be reviewed and remade and this just fits within the existing system. You don’t invent extra courts or tribunals. Bodies like the Administrative Appeals Tribunal do what they are already doing but can also use human rights standards in review. And that’s the UK experience, where most of that sort of action is in the administrative realm, just fitting in to that realm rather than getting into court. In Victoria, the right to damages is specifically excluded, so you can’t get any money out of it. It is available in the UK, and that’s one of the questions that should be on the table. I think that damages should be available because I think that if it’s demonstrated that somebody suffered a harm for which damages is the only adequate remedy then I think that it’s appropriate that that is recognised.

Question — I have a question about the role of the courts and in particular the dialogue between courts and Parliament. In the instance where the courts have said that the law isn’t consistent with the Charter, I wondered what the experience of overseas jurisdictions is, or what is the evidence of overseas jurisdictions of parliaments responding. In particular, in that example you gave of the tenancy where the court interpreted in favoured of same sex couples, did the legislature turn around, and this is maybe a cynical view, but did they turn around and say, no, we actually did mean just man and wife, contrary to what the court said?

George Williams — The UK experience is that no, in cases like that, where you are dealing with what could often be a fundamental injustice, they don’t make those changes. If you are dealing with a same sex couple that, say, have been living together in public housing for 50 years, and an elderly couple, and one of them is about to be evicted because they don’t fit within the definition, it would be unlikely a Parliament would intervene in that case, because I think in this day and age people can see that there is an injustice being done. Parliament lets it be in those interpretive cases. What happens with the inconsistent declarations, where it is sent back to Parliament when you can’t fix it by interpretation, in the UK in every one of those cases Parliament has responded.

Parliament responds in its own way. The courts identify a problem and it’s up to Parliament to work out the solution and that’s where you retain the sovereignty. A court says: the mental health system is not working, there is not adequate review. Parliament in a sophisticated way has a debate, it goes through committees, and they work out a new legislative scheme with the benefit of the court decision. In the UK it has worked very well I think, cause the courts have identified it, but then it has very quickly moved into the political world, where it should be, and which works out what the solution is. That’s why in the UK the system is really described as one that is very consistent with the separation of powers. It recognises the limits of those functions, recognises also what they can do and not do and actually does do that in a way that leads to demonstrably better outcomes when it comes to human rights protection, especially in those areas of service delivery and vulnerable people, which is where it should be directed.

Question — I have been living here in Australia since 1966. I notice you talked a lot about the UK, and you may hear that I am originally from the UK. Health, in checks and balances, health services, terminal sedation for a terminal illness, is quite high profile talk among people, but we don’t have the power to do anything about it. As you know, the Northern Territory did bring a law about it but the federal government was able to override it. It’s the same for the territory here, the ACT, we can’t make anything in that area, and I know that 75 to 80 per cent of people would like terminal sedation in a terminal illness. It is euthanasia I suppose to a point, but it’s not that big one where you say: ‘I’m tired of life and I’m going to commit suicide.’ And if people are going to commit suicide, who’s going to stop them anyway? You don’t need a law for that. I do believe that normally when you get to a certain age you could need this assistance, and I have had that with my husband who had a very bad stroke and was on the bed with just his heart beating. I did manage to get him morphine; the doctors are quite good for that, but they really want it down in black and white.

George Williams — I can deal with that issue and that does often come up in these contexts: the issue of voluntary euthanasia. It is a question of drafting more that anything else and this is why we encourage people to get involved in the national process that’s going on at the moment because we have an open slate as to what it might cover.

I think you have got a couple of choices. One is, you could have a Charter that does deal with those issues; you could put something in there about the right to life, or the right to die as it’s referred to in the United States, and you could include it in a way that recognises it. I would say under my model that even if you put it in, Parliament will still have the final say; this isn’t a strike-down mechanism. If Parliament says that we want to ban voluntary euthanasia, a Charter can’t stop that. If they say this is the way we want to go, well they will win on that, and I’m happy to live with that consequence because I think that’s the nature of the model that I’m talking about. I think though what is more likely in Australia is that probably we will end up with a Charter (if we get a Charter as I hope we do), that will deal with rights that have very broad and general acceptance in the community, maybe a level of over 90 per cent. That is what we did in Victoria. That’s why Victoria excluded abortion-related rights, for the reason that that was left solely to Parliament without any work for the Charter to do in that area. I think a government might say, if we go down this path, that they will simply excise areas like euthanasia and abortion and the like, and focus on free speech and the like, and that may be for political considerations perhaps or it may be that you just stick to those issues that have support. All of those options are open. I would simply say, if you care about these issues send something in. This is a process to give people a chance to say what the want in or not in.

Question — You do need a framework of checks and balances, there’s no doubt about it, so that you can stop abuse. But the big word is choice. If you have been given a choice, and if you have the right checks and balances and you’re seriously ill, and you’re not going to get any better, it’s much better to free up a hospital bed.

George Williams — Let me give you one quick example which I think illustrates that choice. In the UK there was a couple in a nursing home. They had been together for many many years, and one of them developed a disability for which he needed a new bed. The nursing home said they would give them a new bed, but only a single bed, as that was all their guidelines allowed. She said: ‘I have the money, I can pay for a double bed, because I want to continue sleeping with my husband, and we have been together for many years.’ They said no, their guidelines only would allow for a single bed. And she was given a single bed and they were separated for 18 months. It is one of those basic indignities that have such a big impact on our quality of life. She finally got some advice from a welfare rights centre there in the UK; they went and talked to the nursing home and said: ‘She has a number of rights here about family life and a number of other things.’ The nursing home said within three hours that they would get them the double bed. That is how these things work, and it is how they should work. It was a simple thing in the end, and you think that’s stupid, it should have always worked that way, but on too many occasions it doesn’t work that way without something to give you a little lift in how you actually deal with agencies.

Prev | Contents | Next

George Williams 'The Role of Parliament under an Australian Charter of Human Rights'

Papers on Parliament No. 51 June 2009

Papers on Parliament No. 51
June 2009