October 2011 e-brief 14/2011

Racial vilification laws: the Bolt case from a State perspective by Gareth Griffith

1 Introduction that she was not really Aboriginal, On 28 September 2011 Justice that she had identified as Aboriginal Bromberg handed down his judgment for career, political or financial gain, and that in so doing she had in [2011] FCA 1103 (the deprived more worthy "genuine" Bolt case). Journalist was Aborigines access to assistance. In found to have contravened s 18C of October, Ms Eatock was joined in the Commonwealth Racial her action by eight others also Discrimination Act 1975. named in the articles.3

The judgement has given rise to 2 Vilification laws in Australia considerable debate. For George With the exception of the Northern Brandis, the federal Shadow Attorney- Territory, all Australian jurisdictions General, one consequence is that: "it have introduced racial vilification laws. is clear that freedom of political In the States and the ACT, this is in expression in Australia is subject to a addition to a range of other vilification 1 significant new constraint". laws, as set out in the table below.4 Conversely, David Marr wrote in the immediate aftermath of the judgment; ACT NSW Qld SA Tas Vic WA "Freedom of speech is not at stake Race √+ √+ √+ √+ √ √+ √- here. Judge Mordecai Bromberg is not Homo- √+ √+ √+ √ telling the media what we can say or sexuality/ where we can poke our noses. He's Sexual 2 Orientation/ attacking lousy journalism". Sexuality Trans- √+ √+ √+ sexuality/ The broad facts behind the case were Gender set out by Karl Quinn, writing in the Identity SMH: Religion √+ √ √+ HIV/AIDS √+ √+ Disability √ Ms [Pat] Eatock initiated her claim that Bolt had committed a breach of Key the Racial Discrimination Act last √+ Unlawful conduct; criminal conduct if September. She claimed that two serious. articles he wrote for the Herald Sun √ Unlawful conduct only – the subject of and two blogs published on the complaint. paper's website, in 2009, implied √- Criminal conduct only.

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3 Racial Vilification Laws in Australia Section 18B is a deeming provision The current racial vilification laws in which provides that if one reason for Australia are set out in the following the doing of an act was "the race, table:5 colour or national or ethnic origin of a person", then for the purposes of Part Statute Key In 11A, that will be deemed to be the sections force reason for which the act was done, NSW Anti- 20C-20D 1989 Discrimination Act "whether or not it is the dominant 1977 reason or a substantial reason for ACT Discrimination Act 66-67 1991 doing the act". 1991 C'th Racial 18C-18D 1995 Discrimination Act Guidance as to what is meant by 1975 "otherwise than in private" is provided SA Racial Vilification 3-6 1996 by s 18C(2). Most relevant to the Bolt Act 1996 Civil Liability Act 73 case, an act is taken not to be done in 1936 private if it "causes words, sounds, Tas Anti- 19 1998 images or writing to be communicated Discrimination Act 1998 to the public". Qld Anti- 124A 2001 Discrimination Act 131A According to Human 1991 Vic Racial and 7-12 2002 Rights Commission: Religious 24-25 Tolerance Act The complainant is responsible for 2001 proving that the act was done in WA Criminal Code 77-80H 1990 1913 (revised public, that it was done because of 2004) his or her ethnicity and that it was reasonably likely to offend, insult, 4 Commonwealth racial humiliate or intimidate a reasonable vilification law person of that ethnicity.

Twenty years after the Act was first Exemptions are provided under s 18D. passed, Part 11A headed "Prohibition In particular, s 18D(c) provides that s of offensive behaviour based on racial 18C does not render unlawful anything hatred" was inserted into the said or done "reasonably and in good Commonwealth Racial Discrimination faith" in making or publishing: Act 1975. (i) a fair and accurate report of any Section 18C(1) makes it unlawful for a event or matter of public interest; or person to do an act "otherwise than in (ii) a fair comment on any event or private", if: matter of public interest if the comment is an expression of a (a) The act is reasonably likely, in genuine belief held by the person all the circumstances, to making the comment. offend, insult, humiliate, or intimidate another person or a In respect to this exemption, the group of people; and Australian Human Rights Commission (b) the act is done because of comments that it gives the media race, colour or national or "considerable scope" by permitting ethnic origin of the other "fair and accurate reporting on any person or of some or all of the matter of public interest". The people in the group.

Page 2 of 10 E-Brief Racial vilification laws: the Bolt case from a State perspective exception is said to allow "editorial including discussion or debate about opinions and the like, providing they and expositions of any act or matter. are published without malice". It is further explained that: By s 20D, the 1989 amendment also created a criminal offence for inciting The respondent is responsible for hatred, contempt or severe ridicule establishing that the act is covered towards a person or group on the by one of the exceptions and that it grounds of race by threatening was done reasonably and in good physical harm (towards people or their faith. property) or inciting others to threaten such harm.7 With the impact on Under s 18E employers may be held freedom of speech in mind, Dan vicariously liable for acts done by their Meagher has observed that: employees or agents; while s 18F provides for the concurrent operation Criminal liability is attracted only with of State and Territory laws. Part 11A the presence of an aggravating does not therefore purport to "cover factor – the threat to do violence to the field" in respect to racial vilification person or property or inciting law in Australia. another to do so.8

5 Racial vilification laws in the Prosecution of the offence of serious States and Territories vilification requires consent from the Attorney-General. An offence has not NSW: In 1989 NSW became the first 9 State to introduce racial vilification yet been prosecuted under this law. laws, by the insertion of Part 2, Division 3A (ss 20B-20D) into the Anti- This is the "NSW model", as it has Discrimination Act 1977. Section been called, which is followed with certain variations in most other States 20C(1) makes it unlawful for a person: 10 and the ACT. by a public act, to incite hatred towards, serious contempt for, or : In broad terms s 7 ("Racial severe ridicule of, a person or group vilification unlawful") and s 24 of persons on the ground of the race ("Offence of serious racial vilification") of the person or members of the under Victoria's Racial and Religious group. Tolerance Act 2001 follow the "NSW model". One difference is that, The word "race" is defined broadly whereas the NSW legislation requires under the Act to include "colour, that the prohibited conduct must nationality, descent and ethnic, ethno- involve a "public act", the Victorian religious or national origin".6 approach is to create an exemption for "private conduct". Thus, conduct which Various exemptions are created under would otherwise amount to vilification s 20C(2). In particular, by s 20C(2)(a) is exempted from liability only if the and (c) respectively, nothing in s defendant can establish, on objective 20C(1) renders unlawful "a fair report grounds, that it was intended to be of a public act" or: private.

a public act, done reasonably and in By s 7(1), a person is prohibited from good faith, for academic, artistic, engaging in certain conduct – that, on scientific or research purposes or for the ground of race, "incites hatred other purposes in the public interest, against, serious contempt for, or

Page 3 of 10 NSW Parliamentary Library Research Service revulsion or severe ridicule of" a Criminal Code are set out in ss 77- person or class of persons. The 80H. phrase "engage in conduct" is defined to include a single or a series of acts 6 The Commonwealth and occurring "in or outside Victoria". A States/Territories laws note to the legislation adds that the compared phrase also includes "use of the As outlined by Neil Rees, Katherine internet or e-mail to publish or transmit Kindsay and Simon Rice in Australian statements or other material". anti-discrimination law: text, cases and materials, at least three issues of Tasmania: Both racial and religious difference arise for interpretation vilification is covered under s 19 of the between the Commonwealth and State Anti-Discrimination Act 1998. This is a models: civil provision only, with no criminal 11 penalties imposed. The impact of the conduct in question; : Conversely, in WA The perspective from which that only criminal racial vilification conduct is viewed and the provisions apply, introduced originally impact assessed; and in 1990 and amended in 2004. Writing The causal link between the of the original 1990 provisions, the respondent's conduct and the Tasmanian Law Reform Institute race of the target person or commented: group.13

The first set of provisions, 6.1 The impact of the conduct in introduced in 1990, was specifically drafted to address the activities of question the Australian Nationalist Movement Different language is used to describe (ANM), a neo-Nazi organisation led the requisite impact of the relevant by Jack Van Tongeren. During the conduct. The Commonwealth Act 1980s, the ANM was responsible for stipulates that the conduct must a number of fire-bombings of Asian generate a response that would restaurants. They also defaced "offend, insult, humiliate or intimidate" Jewish Synagogues and businesses another person or group of persons. owned by Jews and produced posters that racially vilified Jewish Under the NSW Act, the conduct in and Asian Australians and called for question must "incite hatred towards, their expulsion from Australia. serious contempt for or severe ridicule" Because of the typical activities of of another person or group of persons. the ANM, which included the Rees et al comment that what is called production of anti-Semitic and anti- the "harm threshold" is far lower under Asian posters and other forms of the Commonwealth Act it is under the graffiti, the legislation only targeted "NSW model". written or pictorial racist communication. Despite being 6.2 The perspective from which drafted to counter the activities of that conduct is viewed and the this particular group, only one member of the ANM was convicted impact assessed under these provisions.12 According to Rees et al, a reason for the difference in the "harm threshold" The current expanded provisions may stem from the fact the under the 2004 amendments to the Commonwealth Act requires the

Page 4 of 10 E-Brief Racial vilification laws: the Bolt case from a State perspective impact of the conduct in question to be In the summary to the Bolt case, gauged from the perspective of a Justice Bromberg commented in hypothetical reasonable member of the respect to the Commonwealth victim group, whereas the NSW model legislation: requires that the impact of the conduct in question be measured from the Whether conduct is reasonably perspective of the ordinary, reasonable likely to offend, insult, humiliate or member of the community. The federal intimidate a group of people calls Act therefore is concerned with the for an objective assessment of the emotional response engendered in a likely reaction of those people. I have concluded that the member of the victim group by the act assessment is to be made by in question, whereas the "NSW model" reference to an ordinary and is: reasonable member of the group of people concerned and the values concerned with the emotional and circumstances of those response to members of the victim people. General community group by ordinary members of the standards are relevant but only to community as a result of the act in an extent. Tolerance of the views question. It is this ordinary, of others may be expected in a reasonable member of the multicultural society, including from community, and not a hypothetical those persons who are the subject reasonable member of the target of racially based conduct.16 group, who must be incited to feel hatred towards, serious contempt 6.3 The causal link between the for, or severe ridicule of others on respondent's conduct and the the ground of their race because of 14 race of the target person or the respondent's conduct. group The same issue is discussed by Rees et al explain that, under the Darryn Jensen,15 in an article which "NSW model" it is not necessary to deals with the Bolt case and the prove a causal link between the differences between federal and respondent's reasons for doing the act Victorian vilification laws. Jensen in question and the race of the target writes: person or group. Rather, the tribunal which hears the case must determine, The Commonwealth Act seems to objectively, whether the ordinary, consider the likely effect of the reasonable member of the community conduct upon the person or group would have been incited to feel hatred, of people at whom the conduct is serious contempt, or severe ridicule of directed. In other words, the focus the victim, or his or her racial group, of the "wrong" is upon the victim or because of that person's or group's victims. The Victorian Act race. considers the effect that the conduct is likely to have upon other people – that is, whether other Under the federal Act, however, it must people might be led to despise the be shown, following an objective people referred to by the relevant evaluation, that the race of the target words or actions….The critical person or group was one of the question is whether the conduct defendant's reasons for performing the would encourage the relevant act in question. In the Bolt case the emotions on the part of the court had to address the question audience to which it is directed. whether Bolt's comments about the

Page 5 of 10 NSW Parliamentary Library Research Service persons named in the publications newspaper and on that paper’s online were made because of their race or site. She also complained about two colour. blog articles written by Bolt and published by the Herald & Weekly 6.4 In summary Times on the Herald Sun website. Following Rees et al again, while the causation requirement is easier to The applicants complained that the meet under the NSW model, the "harm articles conveyed offensive messages threshold" under the Commonwealth about fair-skinned Aboriginal people, Act is "considerably lower" than under by saying that they were not genuinely its State counterpart, with the result Aboriginal and were pretending to be that "it will usually be easier for an Aboriginal so they could access applicant to succeed at least in relation benefits that are available to Aboriginal to the issue of impact, in litigation people. The applicants claimed this conducted under the Commonwealth contravened s 18C of the Racial Act rather than under the legislation Discrimination Act (Cth). which follows the 'NSW model'". Rees et al go on to conclude that: The elements the applicants had to prove? To succeed, Ms Eatock had to when viewed overall the range of establish: conduct which is prohibited by the Commonwealth race hatred It was reasonably likely that fair- legislation appears to be much skinned Aboriginal people (or broader than that which is prohibited some of them) were offended, by State and Territory racial insulted, humiliated or vilification which follow the "NSW intimidated by the conduct; and model".17 That the conduct was done by Which begs the question why the Andrew Bolt and the Herald & Commonwealth racial vilification law Weekly Times, including opted to ignore the "NSW model", because of the race, colour or passed six years before the federal ethnic origin of fair-skinned Racial Discrimination Act was Aboriginal people. amended? One reason may be that The respondents' arguments in the Commonwealth drafters opted instead for consistency with the 1992 reply: In part, it was argued that, even "sexual harassment" amendments to if those elements were proved, the the federal Sex Discrimination Act.18 conduct would find exemption under the "fair comment" limb of s 18D. 7 The Bolt case According to Justice Bromberg, "It is a provision which, broadly speaking, Justice Bromberg's summary can be seeks to balance the objectives of s used to set out the basic facts and 18C with the need to protect justifiable findings in the Bolt case. freedom of expression". He went on to explain that, while Part 11A of the Facts: The complaint of Pat Eatock federal Act is designed to protect and her fellow applicants related to two against racial hatred, it is newspaper articles written by Andrew Bolt and published by the Herald & also concerned to protect the Weekly Times (the second respondent fundamental right of freedom of in the case) in the Herald Sun expression. Freedom of expression

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is an essential component of a tolerant and pluralistic democracy. Did the freedom of expression Section 18D of the Racial exemption apply?22 Justice Discrimination Act exempts from Bromberg's reference was to the being unlawful, offensive conduct bundle of exemptions under s 18D, based on race, where that conduct which require an inquiry into whether meets the requirements of section 18D and may therefore be regarded the act was done "reasonably and in as a justifiable exercise of freedom good faith" in making or publishing: of expression. In that way, Part IIA seeks to find a balance between (i) a fair and accurate report of any freedom of expression and freedom event or matter of public interest; or from racial prejudice and intolerance (ii) a fair comment on any event or based on race. matter of public interest if the comment is an expression of a Test – perspective from which genuine belief held by the person conduct viewed: As noted, the making the comment. question whether the conduct at issue was "reasonably likely to offend…" The finding was that the exemption did was to be judged objectively by not apply in this case. Bromberg J reference "to an ordinary and commented in part: reasonable member of the group of The reasons for that conclusion people concerned and the values and have to do with the manner in which circumstances of those people". the articles were written, including that they contained errors of fact, Applying this test, Bromberg J found distortions of the truth and that he was "satisfied that fair-skinned inflammatory and provocative Aboriginal people (or some of them) language. were reasonably likely, in all the circumstances, to have been offended, In coming to that view, I have taken insulted, humiliated or intimidated by into account the possible degree of the imputations conveyed by the harm that I regard the conduct newspaper articles".19 involved may have caused. Beyond the hurt and insult involved, I have

also found that the conduct was Test – the causal nexus: Bromberg J reasonably likely to have an further concluded that a causal nexus intimidatory effect on some fair- was established between the acts in skinned Aboriginal people and in question and the applicants' race. In particular young Aboriginal persons effect, Bolt's comments about the or others with vulnerability in relation persons named in the newspaper to their identity. articles were made because of their race or colour.20 The same causal Orders: After Bromberg J had directed nexus was established in relation to the parties to confer on the remedial the publication of the articles by the action to be taken, the Herald Sun was Herald & Weekly Times.21 ordered to publish two corrective notices within a fortnight, to be In reaching this conclusion, Bromberg published alongside Bolt's regular J observed that "People should be free column. The notices were to set out, in to fully identify with their race without summary, the reasons for the fear of public disdain or loss of esteem judgment, including that the articles: for so identifying". "were reasonably likely to offend,

Page 7 of 10 NSW Parliamentary Library Research Service insult, humiliate or intimidate some making unlawful speech merely Aboriginal persons of mixed descent because it causes offence.27 who have a fairer, rather than darker, skin and who by a combination of In his view, if the Bolt decision was not descent, self-identification and overturned on appeal, "the provision in communal recognition are and are its present form should be repealed". recognised as Aboriginal persons".23 Commenting on 20 October 2011 on The Herald & Weekly Times has the first corrective notice published in declared it will not appeal against the the Herald Sun, David Marr cast a decision.24 critical eye on Andrew Bolt's "martyrdom". He noted that Bolt had 8 Reactions to the Bolt case not been fined, required to pay Reactions to the Bolt case have been damages or "warned off the delicate many and varied. For example, for subject of whites identifying as blacks". Geoff Clark, the former ATSIC chairman and one of the applicants in However, on the broader issue of the the case, declared it to be a "great interpretation of s 18C, Marr was in day",25 whereas the man at the centre general agreement with George of the controversy, Andrew Bolt, said Brandis, stating: that "writing frankly about multiculturalism, and especially The anti-vilification provisions of the Racial Discrimination Act used to Aboriginal identity, yesterday became 26 attack Bolt are drafted far too too dangerous for any conservative". broadly. They outlaw speech that is merely offensive or insulting. Of the many comments on the Bolt Vigorous public discussion in a free case, only another two are discussed society is impossible without causing here. First, George Brandis, the insult and offence.28 federal Shadow Attorney-General, said that s 18C of the Racial Discrimination Marr went on to conclude that "short of Act "has no place in a society that abolishing these anti-vilification values freedom of expression". He protections entirely, no amendment of argued (in part): the law would have helped the hapless Bolt". But his analysis does not seem By making the reasonable likelihood to take account of the way in which of causing offence or insult the test vilification provisions are drafted in of unacceptable behaviour, in any other jurisdictions, under the "NSW political context, section 18C is a model". It is possible that a different grotesque limitation on ordinary outcome could have been reached in political discourse. While some have the Bolt case under that model. pointed out the analogy with the limitations on free speech in the defamation laws, the threshold at 9 Commentary on freedom of which speech may be unlawful speech and racial vilification because it is defamatory is much laws higher: the traditional formula is that However and wherever formulated – in it must be likely to bring the victim the context of international treaties, into "hatred, ridicule or contempt". national constitutional or statutory bills There is all the difference in the of rights, sub-national charters of rights world between that standard and or under the common law – it is a truism to say that freedom of speech is

Page 8 of 10 E-Brief Racial vilification laws: the Bolt case from a State perspective not and cannot be absolute. Limits States and the ACT based on the apply in a range of contexts, from war "NSW model". In that case, however, time emergency legislation to a the answer would have to take account prohibition against shouting "Fire" in a of the different and more stringent crowded theatre", where the harm test that applies, based on the justification is in terms of protection concepts of incitement to "hatred, from physical harm. The sub judice serious contempt for or severe ridicule" rule operates to protect the of a person or group of persons. administration of justice, whereas the law of defamation operates to protect 1 G Brandis, "Section 18C has no place in a reputation. The prohibition against society that values freedom of expression", The Australian, 30 September 2011, p 12. child pornography is another case in 2 D Marr, "In black and whie, Andrew Bolt point, where the protection of minors is trifled with the facts", SMH, 29 September at issue. 2011, p 11. 3 K Quinn, "Bolt unrepentant but slur victims Racial vilification laws are a relatively hail victory", SMH, 29 September 2011, p 4. new feature of this legal landscape, a 4 This table is based on G Griffith, Sedition, culmination of the evolving post-1945 Incitement and Vilification: Issues in the abhorrence of the casual (and not so Current Debate, NSW Parliamentary casual) racism of the earlier period, on Library Research Service, Briefing Paper one side, and of the growing 1/2006, p 41. 5 This is table is updated from L McNamara, complexity of Australia's multi-ethnic Regulating Racism: Racial Vilification Laws society, on the other. Where civil in Australia, Sydney Institute of Criminology penalties are imposed they can be Monograph Series 16, 2002, p 6. characterised as limiting freedom of 6 The meaning of the term "ethno-religious" speech to protect against forms of was discussed in Briefing Paper 1/2006, pp 51-54. expression which are culturally 7 The maximum penalty is 50 penalty units, 6 unacceptable, although the non- months imprisonment or both for physical harm that might be caused by individuals, and 100 penalty units for "hate speech" may be another factor in corporations. 8 the debate. Where criminal penalties D Meagher, "So far no good: the regulatory failure of criminal racial vilification laws in apply, there is also the threat of Australia" (2006) 17 Public Law Review physical harm to persons or property. 209, p 212. 9 Note that a sentence aggravation provision In the Bolt case, Justice Bromberg applies in NSW, under s 21A(2)(h) of the discussed in detail the contrasting Crimes (Sentencing Procedure) Act 1997. This would not operate in relation to objectives of the federal Racial vilification laws but, rather, in the context of Discrimination Act, its balancing of criminal offences relating to assault and the freedom of expression against the like. It provides:"(2) The aggravating factors promotion and protection of tolerance to be taken into account in determining the for racial and ethnic diversity. The appropriate sentence for an offence are as follows:…(h) the offence was motivated by rights and wrongs of the Bolt case hatred for or prejudice against a group of aside, the question is whether the people to which the offender believed the Commonwealth Act, with its victim belonged (such as people of a conceptual armoury based on offence, particular religion, racial or ethnic origin, insult, humiliation and intimidation, language, sexual orientation or age, or having a particular disability)…". This gets that balance right? provision was applied in R v Amir El Mostafa [2007] NSWDC 219, a case which The same question might be asked of involved a confrontation between members those racial vilification laws in the of the Sunni and Shite Muslim communities

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in the Sydney suburb of Auburn. Similar 24 M Bodey, "Herald Sun will not appeal Bolt provisions apply in the Northern Territory case", The Australian, 19 October 2011. (Sentencing Act 1995 (NT), s 5(2) read with 25 K Quinn, "Bolt unrepentant but slur victims s 6A(e)) and Victoria (Sentencing Act 1991, hail victory", SMH, 29 September 2011, p s 5(2)(daaa)). 4. 10 The Queensland, South Australia and the 26 A Bolt, "Silence now golden on this critical ACT vilification laws essentially mirror the issue", Daily Telegraph, 29 September NSW legislation and therefore include both 2011, p 35. civil and criminal provisions. One difference 27 G Brandis, "Section 18C has no place in a is that the ACT criminal offence provision society that values freedom of expression", (Discrimination Act 1991, s 67) expressly The Australian, 30 September 2011, p 12. requires an element of intentionality and 28 D Marr, "Bolt's freedom of speech crusade recklessness to be established in the won't right his wrongs", SMH, 20 October incitement of hatred. The Queensland 2011. criminal offence provision (Anti- Discrimination Act 1991, s 131A) expressly Information about Research Publications can be found on the Internet at the: requires knowledge or recklessness. 11 NSW Parliament's Website A report in April 2011 by the Tasmanian Law Reform Institute recommended against Advice on legislation or legal policy issues contained in this introducing a criminal offence, but in paper is provided for use in parliamentary debate and for related parliamentary purposes. This paper is not support of a relevant sentence aggravation professional legal opinion. provision – Racial Vilification and Racially Motivated Offences, Final Report No 14, © 2012 April 2011. Except to the extent of the uses permitted under the 12 Copyright Act 1968, no part of this document may be Racial Vilification and Racially Motivated reproduced or transmitted in any form or by any means Offences, Final Report No 14, p 16. In including information storage and retrieval systems, without 2007 this remained the only successful the prior written consent from the Librarian, New South criminal prosecution in Australia: K Gelber Wales Parliamentary Library, other than by Members of the New South Wales Parliament in the course of their official and A Stone, Hate Speech and Freedom of duties. Speech in Australia, The Federation Press 2007, p 8. ISSN 1838-0204 13 The following commentary is based on Neil Rees, Katherine Kindsay and Simon Rice, Australian anti-discrimination law: text, cases and materials, The Federation Press 2008, pp 579-582. 14 Ibid, p 580. 15 D Jensen, "The battlelines of interpretation in racial vilification laws", Policy, Vo 27 No2 Winter 2011. 16 Para 15. 17 Neil Rees, Katherine Kindsay and Simon Rice, Australian anti-discrimination law: text, cases and materials, p 580. 18 Sex Discrimination Act 1984 (Cth), s 28A(1)(b). The key concepts used in this context are "offended, humiliated or intimidated". 19 Eatock v Bolt [2011] FCA 1103 paras 241- 302. 20 Eatock v Bolt [2011] FCA 1103 paras 303- 335. 21 No findings were made in relation to the two blog articles [Summary, para 27]. 22 Eatock v Bolt [2011] FCA 1103 paras 336- 451. 23 N Leys, "HWT order runs with Bolt piece", The Australian, 24 October 2011, pp 30-31.

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