Chapter 14

Trick or Treaty? Commonwealth Power to Make and Implement Treaties

Chapter 14

The need for greater parliamentary involvement

Is there a democratic deficit in the current treaty making practices?

14.1 There is criticism that current practices have led to a 'democratic deficit' or a lack of accountability in those practices.[1] The concern is that the practice, whereby treaties are entered into by the Executive (ie the Government) without significant Parliamentary involvement, is 'undemocratic', as treaties can have a range of significant effects on the Australian legal and administrative systems; the Australian economy and indeed the way Australians live.

14.2 Dr David Kinley, from the Australian National University, rejected the democratic deficit argument. He stated, in evidence before the Committee:

14.3 The same point was made by the Minister for Foreign Affairs and Trade, the Hon. Senator Gareth Evans QC, when he observed that the democratic accountability of the executive is achieved through the ordinary method of election to government.[3]

14.4 It is also argued that because the official Government policy is that treaties will not be ratified until Australian law is in conformity with the treaty obligations,[4] Parliament does play a vital role prior to the ratification of treaties, and there is, therefore, no democratic deficit.

14.5 Others have disputed that this 'official' policy is always put into practice. Professor Charlesworth has stated:

14.6 Many treaties are implemented by executive action and do not require legislation, for example, treaties concerning trade cooperation, defence logistics and procurement.[6] Even when treaties are not implemented by legislation, they may still have domestic consequences. Treaties can affect the interpretation of law, by being used to resolve any ambiguity in legislation or any gap in the common law. They are considered by the courts to be a legitimate source of influence on the development of the common law, and may be the source of a 'legitimate expectation' under administrative law, that government officials will comply with the treaty when making administrative decisions which affect the rights of people.[7]

14.7 Sir Ninian Stephen also saw the potential for a 'democratic deficit' because international agencies can exert influence over nation-states when countries enter into international treaties. He stated:

14.8 Sir Ninian's remarks are relevant to recent Executive action which has submitted Australia to the scrutiny or jurisdiction of several international bodies.[9]

14.9 A background paper submitted by the Victorian Government also pointed to a number of other features of international treaty processes as being undemocratic, including:

14.10 Some of the concerns raised in the Victorian Government Background Paper relate to the general practice of international law and of the United Nations and are not matters which could be addressed by the Australian Parliament. However, more active parliamentary involvement prior to ratification, and the full legislative implementation of treaties, may alleviate these problems.

14.11 The National Farmers' Federation has also pointed to the inadequate parliamentary processes for debate on treaties as contributing to the democratic deficit. Mr Hadler stated:

14.12 Professor de Q Walker, of the University of Queensland, queried whether even parliamentary involvement in treaty making could redress the democratic deficit, observing that:

14.13 The Australian Council for the National Interest called for increased parliamentary debate.[16] The Council argued:

14.14 Professor Webb, of the University of Western Australia, was critical of Parliament's lack of action in relation to treaty making. He stated:

14.15 The Department of Foreign Affairs and Trade rejected the argument that treaty making by the Executive is undemocratic as follows:

Influence on Parliament to implement treaty obligations

14.16 Another aspect of the 'democratic deficit' concern is the argument that Parliament is influenced by the fact that treaties already entered into by the Government are binding at international law. If they are not complied with by Australia, Australia will be in breach of its obligations to other countries.[20]

14.17 Mr Anthony Morris QC argued that the present system allows the Executive to dictate to the Parliament that treaties signed by the Government should be implemented by the Parliament. He stated:

14.18 Mr Hodgkinson, from the NSW Farmers' Association, agreed that once a treaty is entered into, an obligation arises, and obligations should be honoured. It is important, therefore, that treaties are subject to full scrutiny before they give rise to obligations 'which we are bound to honour to the fullest extent we can'.[22]

Human Rights (Sexual Conduct) Act 1994

14.19 An example of how the adoption of a treaty can lead to a change in domestic law is the Human Rights (Sexual Conduct) Act 1994. The Human Rights (Sexual Conduct) Act 1994 was passed by the Commonwealth Parliament in response to the finding by the United Nations Human Rights Committee in the Toonen case that Australia was in breach of its treaty obligations under the International Covenant on Civil and Political Rights (ICCPR).[23]

14.20 Mr Toonen had complained that Tasmanian laws which make homosexual acts a criminal offence breached his right to privacy under article 17 of the Covenant. The United Nations Human Rights Committee agreed, finding that an appropriate remedy would be the repeal of the relevant laws. As the Tasmanian Government declined to repeal its laws, the Commonwealth Parliament enacted legislation which was intended to provide a remedy for the complaint.

14.21 Prior to the ratification of the ICCPR, it was not commonly realised that there might be a conflict between the right to privacy in the Covenant and the Tasmanian laws which were the focus of the Toonen complaint. The Hon. Elizabeth Evatt, a member of the United Nations Human Rights Committee, stated that the Toonen case revealed a violation of the Covenant 'which may not have been obvious at the time of ratification'.[24] Indeed, the Toonen complaint was the first complaint in which the United Nations Human Rights Committee considered whether the right to privacy applied to sexual conduct.

14.22 On the other hand, it could be argued that if Australian law had been changed to make sure it conformed with the Covenant before its ratification, there would be a legal right to privacy as part of Australian law, so the complaint about the breach of the right of privacy made by Mr Toonen, could have been dealt with by Australian courts under domestic law.

14.23 The Human Rights (Sexual Conduct) Act 1994 is clearly a direct response to the finding of the United Nations Human Rights Committee. It does not implement the whole of the Covenant, nor does it implement the whole of article 17, by giving Australians a general right to privacy. It is specifically limited to privacy in relation to 'sexual conduct involving only consenting adults acting in private'.[25] Professor Charlesworth has noted that this legislation sends the curious message:

14.24 The decision to enact the Human Rights (Sexual Conduct) Act 1994 was the decision of a sovereign nation, and the legislation was passed through the Parliament as part of the democratic process.[27] However, it is arguable that there would not have been the same pressure to enact such legislation if it were not for the treaty obligation and the fact that the UN Human Rights Committee had alerted the world to Australia's breach of that obligation.[28]

Other examples of international influence on Parliaments

14.25 The Background Paper submitted by Mr Baxter, Secretary of the Department of the Premier and Cabinet of Victoria, also suggested that the decision not to prohibit racial hatred when enacting the Racial Discrimination Bill 1974 was a similar instance where Parliament was influenced to implement treaty obligations:

14.26 Australia has maintained a reservation to the clause in the Convention on the Elimination of All Forms of Racial Discrimination requiring the prohibition of words or acts which incite racial hatred, and is therefore not obliged under international law to enact such legislation. However, the fact that such a provision is contained in the Convention is sometimes given as a reason for enacting such laws.[30]

14.27 Mr Baxter also pointed to Australia's recognition of the jurisdiction of the International Court of Justice to hear and determine disputes involving Australia as an example of where a decision would bind Australia at international law and have profound effects.[31] Similarly, Australia is obliged to implement resolutions of the United Nations Security Council.

Ratification of treaties prior to passage of legislation

14.28 There have been concerns that the Government policy of not ratifying treaties until necessary legislation is in place has not been followed on a number of occasions. Examples which have been suggested are the following:

14.29 Several witnesses wished to reinforce the point to the Committee that before entering into a treaty, the law implementing it should already be in place or should be enacted immediately thereafter.[35]

Accountability

14.30 A related concern to the issue of a democratic deficit in the current treaty making processes is the need for the Government to be made more accountable to the Parliament. Although it is open to parliamentarians to utilise the usual parliamentary processes to facilitate debate, current practices do not ensure that important national decisions are subjected to appropriate scrutiny.

14.31 Even the decision made by the Executive to enter into a treaty may not be subject to sufficient scrutiny by the Executive itself. The Chief Justice of the High Court, Sir Gerard Brennan, referring in a speech to an article written by Professor Cheryl Saunders,[36] made the following admission:

14.32 The criticism can be made that procedures should be in place so that important national issues dealt with by treaties should at the least be subject to systematic scrutiny.

14.33 The Australian Catholic Bishops Conference made the point in the following terms:

14.34 Mr Stokes argued that accountability is more important than convenience, stating:

Arguments for greater parliamentary involvement

14.35 While there perhaps is not sufficient evidence to conclude that there is a democratic deficit, a range of arguments can be made for greater parliamentary involvement in the treaty processes. The key arguments would appear to be the following:

14.36 There was clearly strong support in the evidence before the Committee in favour of a greater parliamentary involvement in the treaty process.[41] There were a range of suggestions as to what the role of Parliament should be and these issues are discussed further in Chapters 15 and 16.

Treaties and sovereignty

14.37 One criticism, which is not infrequently made, is that by signing treaties Australia is in fact surrendering its sovereignty.[42] A former Governor-General, Sir Ninian Stephen, has agreed with this concern:

14.38 There are many different aspects to the criticism that entering into treaties adversely affects Australia's sovereignty. One of the central tenets of international law is that countries refrain from acting in a way which is inconsistent with their international obligations. In this sense, all treaty making may be said to limit sovereignty.[44] However, the decision to enter into a treaty is a deliberate sovereign decision of the Government concerned.

14.39 At one level the limitation on sovereignty imposed by treaties is not significant, particularly in relation to treaties like the Genocide Convention, the Convention on the Elimination of Torture, or the Slavery Convention. Clearly there is no significant abandonment of sovereignty in relation to these actions because no civilised country would countenance acceptance of torture, slavery or genocide.[45]

14.40 Nevertheless the issue of sovereignty becomes more significant in relation to issues which are more contentious, such as trade policies, or the abolition of the death penalty.[46]

14.41 Treaties are part of an international legal regime and to an extent it is clear that we all benefit from the existence of an international legal order. The Department of Foreign Affairs and Trade has pointed out that the decision to enter a treaty is a decision by the Government taken as a 'judgement that any limitations on the range of possible actions which result are outweighed by the benefits which flow from the existence of a widely endorsed, international agreement.'[47]

14.42 The Department of Foreign Affairs and Trade also argued that:

14.43 Treaties can be used to reinforce sovereignty. As the Attorney-General, Michael Lavarch, pointed out in the debate on the Human Rights (Sexual Conduct) Bill 1994:

14.44 The United Nations Association of Australia submitted that:

14.45 The issue was also raised that the greater loss of sovereignty in Australia is through international trade and finance, rather than treaties. The Hon. P Pendal quoted the following phrase from Time magazine:

United Nations Committees and Australian Sovereignty

14.46 One of the particular concerns raised by Senator Kemp is the role of the United Nations Human Rights Committee under the First Optional Protocol to the International Covenant on Civil and Political Rights and various other committees established under the auspices of the United Nations. Senator Kemp has stated:

14.47 Several witnesses before the Committee had strong views on the issue of sovereignty and treaties.[53] Mr Guy Barnett from the Liberal Lawyers Association of Tasmania stated:

14.48 Mr Barnett considered that the Government should 'cease allowing appeals from Australia to the myriad of foreign-based international committees established under these 2000 odd international treaties'.[55]

14.49 Mr Roger Wilkins, the Director-General of the New South Wales Cabinet Office, noted that the reason successive NSW Attorneys-General had objected to the ratification of the First Optional Protocol to the International Covenant on Civil and Political Rights was that they saw it as 'ceding sovereign power to bodies outside the Australian jurisdiction'. He also observed that although this was considered to some extent 'inevitable', they considered that it should only be done with our eyes open and with a clear understanding of the consequences.[56]

14.50 Mr John Daley, from the Victorian Department of Premier and Cabinet, argued that the fact that international committees may influence Australian law 'is a good reason for saying that Parliament ought to be involved before effective jurisdiction is conferred on those international bodies'.[57]

14.51 Mr Jeremy Buxton argued that the opening up of access to the United Nations Human Rights Committee raised real questions about Australian sovereignty. He observed that appeals to the Privy Council are no longer allowed because it is an 'affront to Australian sovereignty to go to a foreign court', but that we now encourage Australians 'to go to another foreign tribunal that is not even a real court of law'.[58]

14.52 The Hon. Justice Kirby, however, has argued that the UN committees do not have a similar role to that previously played by the Privy Council in the Australian legal system. He stated:

14.53 The Department of Foreign Affairs and Trade has argued that the ratification of treaties does not result in the loss of sovereignty to UN Committees:

14.54 The Australian Law Reform Commission also pointed out that the committees established under the major human rights treaties do not impinge on national sovereignty. The Commission stated:

Sovereignty and denunciation of treaties

14.55 Some witnesses before the Committee expressed concern that Australia was entering into treaties from which it was not able to withdraw. Mr Bruce Hannaford stated in evidence before the Committee:

14.56 Senator Abetz asked the Department of Foreign Affairs and Trade at the public hearing on 1 May 1995, which of the 920 head treaties to which Australia is a party, do not allow denunciation. The Department took the question on notice, and provided the following answer to the Committee:

14.57 Even when withdrawal is permitted by the treaty, it may be politically difficult to withdraw from the treaty. Officers of the Victorian Department of Premier and Cabinet addressed this problem at the public hearing on 2 May 1995, in the following terms:

14.58 The Hon. Elizabeth Evatt also expressed concern as to the consequences of denunciation of treaties, stating:

14.59 Mr Guy Barnett suggested that the Federal Government 'should seriously consider declining to sign a treaty if it does not include a clause for withdrawal'.[65]

Conclusion

14.60 The act of entering into a treaty is a free decision of Australia as a sovereign nation. This decision is made by a government which has been democratically elected by the Australian people and is accountable to them. Any action taken to change the law in order to implement the treaty must be taken by the Commonwealth Parliament, or the parliaments of the States or Territories. Hence the process of entering into and implementing treaties is democratic, but the process could be improved. For example, there could be better consultation.

14.61 The Committee recognises that by incurring international obligations under treaties, the Commonwealth Government exerts influence on the Commonwealth Parliament or the States to fulfil those obligations. International influence may be brought to bear by the international community or organisations such as the United Nations Human Rights Committee.

14.62 International obligations are incurred at the point of entering into a treaty. However, the function of implementing the treaty is often reserved to the Commonwealth Parliament. Accordingly, it would be preferable to involve Parliament prior to ratification, so that it can make a free choice without the pressure of a potential breach of treaty obligations. The Committee's proposals and recommendations for parliamentary involvement prior to ratification are contained in Chapters 15 and 16 of this report.

Endnotes

  1. The term 'democratic deficit' was reportedly coined in the context of European Community institutions. Mr K. Baxter, Submission No. 111, Vol 7, p 1435.
  2. Hansard, SLCRC, 1 May 1995, p 107, per Dr D. Kinley.
  3. Hansard, Senate Estimates, 1 June 1995, p 36, the Hon. Senator G. Evans QC.
  4. Department of Foreign Affairs and Trade, Negotiation, Conclusion and Implementation of International Treaties and Arrangements, August 1994: para 56. See also: The Hon. E. Evatt, Submission No. 110, Vol 7, p 1408.
  5. H. Charlesworth, 'Implementation of Australia's Human Rights Treaty Obligations', Paper given at a conference on Australia in a Global Context: The United Nations and Law-Making for the Twenty-First Century, University House, Canberra, May 1995. See also: Hansard, SLCRC, 2 May 1995, p 189 per Mr S. Donaghue; and Mr D.Williams QC, Submission No. 154, Vol 10, p 2241.
  6. Mr C. R. Jones, Department of Foreign Affairs and Trade, Submission No. 93, Vol 3, p 1173.
  7. For further detail, see the discussion in Chapter 6 above.
  8. Sir Ninian Stephen, 'Making rules for the world' (1995) Vol 30(2) Australian Lawyer, p 14.
  9. On 28 January 1995, the Executive removed reservations or subjected itself to other articles of treaties, which allowed scrutiny of Australia's actions by international committees under the International Covenant on Civil and Political Rights, the Convention on the Elimination of All Forms of Racial Discrimination, and the Convention against Torture. See Joint Committee on Foreign Affairs, Defence and Trade, A Review of Australia's Efforts to Promote and Protect Human Rights, AGPS, Canberra, 1994: p 29.
  10. Mr K. Baxter, Submission No. 111, Vol 7, p 1436.
  11. Mr K. Baxter, Submission No. 111, Vol 7, p 1437.
  12. Mr K. Baxter, Submission No. 111, Vol 7, p 1437.
  13. The Submission by the Victorian Government notes, however, that such 'contravention may be a necessary result of Australia's participation in the international community.' Mr K. Baxter, Submission No. 111, Vol 7, p 1434.
  14. Mr R. Hadler, Submission No 62, Vol 3, p 521.
  15. Professor G. de Q Walker, Submission No. 103, Vol 6, p 1310.
  16. Other submissions made to the Committee also called for treaties to be subjected to proper parliamentary scrutiny and debate. For example, see Mr R. Mansour, Submission No. 142, Vol 9, p 2131.
  17. Mr S. Gethin, Submission No. 97, Vol 6, p 1227.
  18. Professor Emeritus M. Webb, Submission No. 128, Vol 8, p 1758.
  19. Mr C. R. Jones, Department of Foreign Affairs and Trade, Submission No. 93, Vol 6, p 1177.
  20. Several witnesses raised this type of concern, including: Hansard, SLCRC, 2 May 1995, p 168 per Ms J. Paterson and p 188 per Mr S. Donaghue; Hansard, SLCRC, 15 May 1995, p 247 per Mr S. Gethin; Hansard, SLCRC, 16 May 1995, pp 391-2 per Mr D. Bennett QC; Hansard, SLCRC, 22 May 1995, p 486, per Dr D. Mitchell; Professor G. Winterton, Submission No. 89, Vol 5, p 1073.
  21. Hansard, SLCRC, 13 June 1995, p 589, per Mr A. Morris QC.
  22. Hansard, SLCRC, 14 June 1995, p 725, per Mr D. Hodgkinson.
  23. Toonen v Australia, Communication No. 488/1992, UN Doc. CCPR/C/50/D/488/1992, 8 April 1994. See also: I. Shearer, 'United Nations: Human Rights Committee: The Toonen Case', (1995) 69 Australian Law Journal 600-609. Mr K. Baxter, Submission No. 111, Vol 7, p 1431.
  24. The Hon. E. Evatt, Submission No. 110, Vol 7, pp 1408-1409.
  25. Human Rights (Sexual Conduct) Act 1994: s. 4.
  26. H. Charlesworth, 'Implementation of Australia's Human Rights Treaty Obligations', Paper given at a conference on Australia in a Global Context: The United Nations and Law-Making for the Twenty-First Century, University House, Canberra, May 1995.
  27. Senate Legal and Constitutional Legislation Committee, Human Rights (Sexual Conduct) Bill 1994, Canberra, 1994, p 9; Hansard of that hearing, L&C 316-317. See: Bulletin, 'UN rules OK?' 11 October 1994, pp 18-19; Mr K Baxter, Submission No. 111, Vol 7, p 1432.
  28. See the exchange between Senator Kemp and Senator Evans on whether Australia can pick and choose those views of the UN Human Rights Committee which it is prepared to implement: Hansard, Senate Estimates, 1 June 1995, p 38.
  29. Mr K. Baxter, Submission No. 111, Vol 7, p 1431.
  30. See, for example, Hansard, Senate, 23 August 1995, p 223, per Senator C. Evans.
  31. Mr K. Baxter, Submission No. 111, Vol 7, p 1432.
  32. The circumstances relating to the Government's ratification of this treaty are discussed in Chapter 9.
  33. Mr K. Baxter, Submission No. 111, Vol 7, p 1433.
  34. Hansard, SLCRC, 22 May 1995, p 486, per Dr D. Mitchell.
  35. See, for example, Hansard, SLCRC, 22 May 1995, p 486, per Dr D. Mitchell; Hansard, SLCRC, 25 July 1995, per Professor H. Charlesworth and Mr A. Rose at pp. 823-6.
  36. C. Saunders, 'Articles of Faith or Lucky Breaks', (1995) 17 Sydney Law Review 150.
  37. The Hon. Sir G. Brennan, AC KBE, 'Launch of the Sydney Law Review (Vol 17 No. 2), Reporting Papers of the Symposium: The Internationalisation of Australian Law', Transcript of speech, 27 July 1995.
  38. Rev. W. Wright, Submission No. 79, Vol 5, p 961.
  39. Hansard, SLCRC, 22 May 1995, p 475, per Mr M. Stokes.
  40. Senate Legal and Constitutional References Committee, Treaties and the External Affairs Power, Discussion Paper, Canberra, 1995, p 7.
  41. See Mr D. Purnell, Submission No. 69, Vol 3, p 578-579; Ms D. Brown, Submission No. 121, Vol 7, p 1384; Mr M. Stack, Submission No. 120, Vol 7, p 1377; Ms V. Filling, Submission No. 116, Vol 7, pp 1533-1534; Mr A. Proudfoot, Submission No. 10, Vol 1, p 104; Mr E. Chapman, Submission No. 11, Vol 1, p 116; Ms J Paterson, Submission No. 14, Vol 1, p 173; Mr R. Downey, Submission No. 18, Vol 1, p 216; Mrs V Guest, Submission No. 30, Vol 2, p 268; Mr G. Watts, Submission No. 35, Vol. 2, p 279; Ms S. Laxton, Submission No. 91, Vol 5, p 1104; Mrs R. Miller, Submission No. 137, Vol. 8, p 2085; Mr C. Ronden, Submission No. 20, Vol 2, p 222. The Hon. E. Evatt agreed that a Parliamentary Committee could have the function of scrutinising proposed treaties and reporting to Parliament: Submission No. 110, Vol 7, p 1416.
  42. See for example: Hansard, SLCRC, 13 June 1995, per Mr C. Clark, p 583. Mr J. Bryson, Submission No. 2, Vol 1, p 11; Mr G. Hart, Submission No. 9, Vol 1, p 100; Brotherhood of Man of Nebadon, Submission No. 6, Vol 1, pp 28-29; Mrs G. Alcock, Submission No. 29, Vol 2, p 266; Mrs P. Gibson, Submission No. 31, Vol 2, p 270; Mrs W. Teakle, Submission No. 42, Vol 2, p 376; Mr B. Katz, Submission No. 86, Vol 5, p 1047; Ms D. Brown, Submission No. 121, Vol 7, p 1583; Mr N. Udloff-Browne, Submission No. 26, Vol 2, p 259; Mr D. Sisson, Submission No. 46, Vol 2, p 418; Mr R. de Louth, Submission No. 139, Vol 8, p 2092; Mr S. Carter, Submission No. 43, Vol 2, p 378.
  43. Sir Ninian Stephen, 'The Expansion of International Law - Sovereignty and External Affairs', Sir Earl Page Memorial Trust Lecture, 15 September 1994, p 3.
  44. See the dissenting opinion of Justices Adatci, Kellog, Rolin-Jaequemyns, Hurst, Schucking, Van Eysinga and Wang in the Permanent Court of International Justice's Advisory Opinion on Customs Regime Between Germany and Austria PCIJ Ser.A/B, No. 41, where they stated: 'Practically, every treaty entered into between independent States restricts to some extent the exercise of the power incidental to sovereignty. Complete and absolute sovereignty unrestricted by any obligations imposed by treaties is impossible and practically unknown'.
  45. Ms P. Mathew, Submission No. 115, Vol 7, pp 1524-1525.
  46. The Second Optional Protocol to the ICCPR.
  47. Department of Foreign Affairs and Trade, Australian and International Treaty Making, Information Kit, October 1994.
  48. The Department of Foreign Affairs and Trade, Australian and International Treaty Making, Information Kit, October 1994.
  49. The Hon. M Lavarch, House of Representatives, Hansard 12 October 1994, p 1775. Second Reading Speech, Human Rights (Sexual Conduct) Bill 1994.
  50. Mr D. Purnell, Submission No. 69, Vol 3, pp 578-579.
  51. Hansard, SLCRC, 15 May 1995, p 235, per The Hon. P. Pendal.
  52. Senator R. Kemp, 'International Tribunals and the Attack on Australian Democracy', in Upholding the Australian Constitution: Proceedings of the Fourth Conference of the Samuel Griffith Society, July 1994: p 135.
  53. See for example: Hansard, SLCRC, 15 May 1995, p 246, per Mr S. Gethin.
  54. Hansard, SLCRC, 22 May 1995, p 482, per Mr G. Barnett.
  55. Hansard, SLCRC, 22 May 1995, p 483, per Mr G. Barnett. See also Hansard, SLCRC, 15 May 1995, p 250, per Mr G. Gethin.
  56. Hansard, SLCRC, 16 May 1995, p 430, per Mr R. Wilkins.
  57. Hansard, SLCRC, 14 June 1995, p 629, per Mr J. Daley.
  58. Hansard, SLCRC, 15 May 1995, pp 329-330, per Mr J. Buxton.
  59. The Hon. Justice M. Kirby AC CMG, Submission No. 41, Vol 2, p 350.
  60. Mr C. R. Jones, Department of Foreign Affairs and Trade, Submission No. 93, Vol 6, p 1175.
  61. Ms S. Tongue, Submission No. 77, Vol 5, p 845.
  62. Hansard, SLCRC, 25 July 1995, p 769, per Mr B. Hannaford.
  63. Hansard, SLCRC, 2 May 1995, pp 148-149.
  64. The Hon. E. Evatt, Submission No. 110, Vol 7, p 1415.
  65. Hansard, SLCRC, 22 May 1995, p 483, per Mr G. Barnett.