Wednesday, 29 October 2025

Restitution of Indigenous lands in Australia: how should we frame it?

 

A man may see how this world goes with no eyes.

Look with thine ears.

King Lear, Act four, Scene six.

 

I recently read an excellent overview article examining progress over the past sixty years in restoring rights over land to Indigenous groups and interests. That article, Aboriginal Land Rights in Australia: Neither National nor Uniform, authored by Francis Markham and Heidi Norman provides what is perhaps the best and most valuable overview of the development of land rights across the nation in recent decades. See the abstract and hyperlink to the article at the link (link here). The authors combine a synoptic account of the nation’s struggle to come to terms with the reality of dispossession of First Nations with succinct but detailed accounts of the variable processes adopted across the multiple jurisdictions that comprise the Commonwealth of Australia.

Their conclusion states, inter alia:

Legislative responses to recognize Aboriginal land rights were initially led by the states, and the Commonwealth in the Northern Territory. The Woodward Report [to the Whitlam Labor Government] was intended to guide state-based responses; however, both the Fraser coalition government in the late 1970s and the Hawke Labor government in the 1980s failed to advance a national land rights agenda that left advancing Aboriginal interests in land to the states and litigation through the courts. … Litigation that successfully challenged the legality of occupation [the Mabo Case] necessitated a Commonwealth Government response confirming land dealings and creating a mechanism for the recognition of native title. State-based responses after recognition of native title rights and interests have continued to evolve. … In Victoria and Western Australia, settlement processes have been underway that utilize the structures of the Native Title Act, and that also engage the states in the negotiation of a range of social justice aspirations that go beyond land repossession.

In this chapter we argue the land rights recognition in Australia is an outcome of shifting state–Commonwealth relations within the Australian federation. This has led to a hugely varied and spatially uneven set of legislative land rights regimes across Australia, placing onus on Indigenous Peoples to work to advancing their rights and interests in the absence of agreed-upon national standards or leadership from the Commonwealth government.

The conclusion emanates from the detailed recounting of the processes that led to the various state and territory responses, and the value derived from having a jurisdiction-by-jurisdiction narrative of the processes pursued. There are very few potential readers who would not learn something new from reading this account. I did have a few minor quibbles. For example, notwithstanding detailed discussion of the Aboriginal Land Fund Commission which operated between 1974 and 1978, there is no mention of its successor, the Indigenous Land and Sea Corporation established in 1995 following the passage of the Native Title Act (link here). My idiosyncratic quibbles however do not detract from the overwhelming value and importance of the article.

The authors’ core analytic frame seeks to provide an explanation of the narrative laid out in Altman & Markham’s 2015 article (reference below) which used a series of quite stunning maps to visually demonstrate both the extent of dispossession and the partial extent of restitution since settlement. The authors explanation, which is persuasively argued, is that both Labor and Coalition national governments, for different reasons, failed to legislate a national land rights regime consistent with the Woodward Commission principles that underpinned the Commonwealth’s 1976 land rights legislation in the NT (despite having the constitutional power to do so). This failure continued notwithstanding that several states, particularly WA and Qld, failed to legislate adequate state land rights legislation. This left a ‘centralising’ High Court with the opportunity to step into the gap and recognise the existence of native title under common law principles.

The authors suggest that the High Court decision in Mabo ‘may be seen as a move by the judiciary to force the Parliament to legislate on the unresolved question of national land rights, which the Commonwealth had abandoned for almost a decade.’

While the authors’ assessment is framed around a comparative assessment of governments’ actions against the (arguably arbitrary) benchmark of uniform national land rights consistent with the Woodward commission principles, it seems to me that it is not the only approach to assessing the slow and rocky progress in coming to terms with Indigenous dispossession across the nation, nor to understanding what transpired.

In one alternative framing, it might be argued, contra the authors, that the High Court was focussed more on addressing the injustice of dispossession in contexts where prior alienation of the land in favour of the Crown had not occurred. This did have national application by virtue of being Australian law, but it did not necessarily require national legislation. The fact that the Keating Government decided to legislate the Native Title Act was in this framing essentially a political decision aimed at removing uncertainty, and the threat of a loss of social cohesion and political support across the community had the issue been left to the states to manage. The political objective was thus not to reach a consensus between the states and Indigenous interests (see page 137) but to establish processes consistent with the High Court decision that provided certainty to existing non-Indigenous landowners (hence the post 1975 validation provisions) and thus to the electorate at large. Such an alternative framing is consistent with the authors’ conclusion that the NTA was reformist not revolutionary in its impact.

A second alternative framing would look past the antics of political parties vying for political office, and analyse the events in this space over the past sixty years as an ongoing conflict between the state (representing core economic interests such as miners and pastoralists) and the heterogeneous and diverse Indigenous interests, mediated by temporally divergent contact histories, divergent political systems in different states and territories, and the ongoing systemic exclusion of Indigenous people from the benefits taken for granted in the mainstream settler community. In this framing, the political gridlock over national land rights was the outcome of deep-seated ideological and interest-based differences and was only undone because the adverse consequences on dominant interest groups from the loss of political cohesion arising from perpetual and systemic exclusion had different and temporally determined consequences in different jurisdictions. There is evidence for this framing in a close examination of the Noonkanbah issue which the authors mention, but without seeking to look beneath the public narratives promulgated by the Western Australian Government and its then Premier, Sir Charles Court.

The extraordinary action of the Court Government in despatching from Perth, in a blaze of manufactured publicity, a police-protected convoy of drilling trucks to facilitate drilling on a mere exploration lease (that was eventually abandoned by Amax, the explorer), does not stack up. It was designed to create conflict, with the ALP Opposition, the unions, and with Aboriginal interests and to promulgate a narrative of irrational opposition to mining and the economic development associated with it. Conveniently, albeit never acknowledged or recognised by governments nor the media, it created a major distraction from the simultaneous battle between miner CRA (now Rio Tinto) and Aboriginal groups over site destruction at the proposed Argyle diamond mine which ultimately extracted diamonds conservatively valued at around AUD$8 billion over the 37-year life of the mine. There was clearly an incentive to find a way past the strictures in the then WA Aboriginal Heritage legislation.

In this framing then, the question becomes why did the High Court act to break the policy and political gridlock when it did? I don’t pretend to have a definitive answer but suspect it would comprise a combination of wider judicial and political context, realisation that social cohesion would be at risk if the increasing gap between the values the nation claims to live by and the values being applied, as well as the emergence of individual agency by progressive and forward-looking individual judges.

A third alternative framing (which I find attractive) would focus on the prolonged impact of systemic exclusion in leaving Indigenous interests without the ability to apply robust interest group pressure. Yet as those impacts weakened, Indigenous interests were able to mobilise and drive incremental gains, assisted by allies such as progressive lawyers and the unions. I note that the authors of the article spend remarkably little time focussing on the roles of Indigenous advocates in both driving reform and change, and in addressing why those efforts failed where they did and succeeded where they did. It strikes me that these are important issues that require consideration in any overarching account of the drivers of the restitution agenda over sixty years.

The authors comment in the last sentence of their conclusion (quoted above) that this places the onus on Indigenous interests to advocate to advance their rights and interests in the absence of leadership from the Commonwealth resonates with this framing. However, a close reading suggests that the authors (a) believe that governments have a responsibility to, in effect, do the right thing. There is also perhaps an implication or suggestion — and I may be wrong in attributing this to the authors — that (b) Indigenous interests only need to criticise government for their non-performance or quote the UN Declaration on the Rights of Indigenous Peoples often enough, for governments to see the light and do the right thing. While I vehemently agree with proposition (a), I have concerns with any suggestion along the lines of (b). A realist interpretation of public policy formation on land rights, Indigenous policy, or indeed any public policy in modern Australia, suggests that governments react only to organised interest groups (except where electoral pressure emerges which forces a reconsideration), and that where there is a gap between the public interest and the interest group interest, then the public interest suffers. Think about gambling or health insurance, or FOI ‘reform’, or alcohol regulation policy, or virtually any other issue governments touch (link here).

A fourth potential framing would focus more on the institutional underpinnings of the restitution process. I don’t propose to outline this in detail, but would point readers to my own 2017 paper on the strategic challenges facing native title (link here) which covers only part of the policy landscape the authors cover in their paper.

To sum up, Francis Markham and Heidi Norman have produced an excellent and succinctly comprehensive overview of the development of the policies of land restitution to Indigenous interests in Australia over the past sixty years. Their article will expand the wider understanding of the history of land rights in Australia and deservedly be widely cited over the coming decade and perhaps beyond. Yet it relies on a particular framing, which I am not arguing is wrong or misconceived, but rather might be seen as incomplete or partial given that at least several credible alternative framings exist (and probably more that I have not identified).

My deeper purpose in this post is to argue for a wider acknowledgment of the constraints of particular narratives however attractive and well-conceived they may be, and thus for a wider openness to the idea of narrative diversity in shaping the underpinnings of policy development and policy critique. Implicit in this view is an argument for a stronger commitment to understanding the intellectual and conceptual rationales for, and underpinnings of, particular policy approaches. I have a sense that both governments and to a lesser extent the academy have lost sight of the importance of intellectual dialogue and debate as a crucial element in driving better policy outcomes.

Werner Heisenberg wrote (in his 1958 book Physics and Philosophy: The Revolution in Modern Science) that ‘We have to remember that what we observe is not nature in itself, but nature exposed to our method of questioning.’ In discussing and assessing Indigenous policy there is a parallel need to be aware of the ‘method of questioning’ underpinning both the narratives employed, the frames of reference utilised to justify, assess and critique those policy narratives, and the rationales adopted to justify the policy decisions taken.

 

References:

Altman, J. C., & Markham, F. (2015). Burgeoning Indigenous land ownership: Diverse values and strategic potentialities. In Brennan, S., Davis, M., Edgeworth, B., & Terrill, L. (eds.), Native Title from Mabo to Akiba: A vehicle for change and empowerment (pp. 126–142). Melbourne: Federation Press. Google Scholar

 

Dillon, M.C. (2017) Emerging strategic issues in Native Title: future political and policy challenges, CAEPR Discussion Paper 292/2017, Centre for Aboriginal Economic Policy Research, ANU. https://cipr.cass.anu.edu.au/research/publications/emerging-strategic-issues-native-titlefuture-political-and-policy-challenges

 

Markham, F., & Norman, H. (2025). Aboriginal Land Rights in Australia: Neither National nor Uniform. In W. Nikolakis (Ed.), Land Rights Now: Global Voices on Indigenous Peoples and Land Justice (pp. 119-148). Cambridge University Press. https://doi.org/10.1017/9781009521581.009

 

29 October 2025

 

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