Capital Duplicators Pty Ltd & Anor v Australian Capital Territory

Case

[1992] HCATrans 59

No judgment structure available for this case.

IN THE HIGH COURT OF AUSTRALIA

Registry No CS of 1990

B e t w e e n -

CAPITAL DUPLICATORS PTY LTD

and LUHAZE ACT PTY LTD

Plaintiffs

and

AUSTRALIAN CAPITAL TERRITORY

and COMMISSIONER FOR

AUSTRALIAN CAPITAL TERRITORY

REVENUE

Defendants

Demurrer

MASON CJ
BRENNAN J
DEANE J
DAWSON J

TOOHEY J
GAUDRON J

McHUGH J

TRANSCRIPT OF PROCEEDINGS

AT CANBERRA ON TUESDAY, 3 MARCH 1992, AT 10.18 AM

Copyright in the High Court of Australia

Capital(2) 1 3/3/92

MR D.M.J. BENNETT, OC: May it please the Court, I appear

with my learned friend, MR R.C. REFSHAUGE, for the

plaintiffs. (instructed by Macphillamy Cummins &

Gibson)

MR D.F. JACKSON, QC:  May it please the Court, I appear with

my learned friend, MR L.S. KATZ, for the

defendants. (instructed by M.H. Peedom, Chief

Solicitor, Australian Capital Territory)

MR G. GRIFFITH, OC, Solicitor-General for the Commonwealth:

If the Court pleases, I appear with my learned
friend, MR G.K. BURTON, intervening for the

Attorney-General of the Commonwealth in the

interest of the defendants. (instructed by the

Australian Government Solicitor)

MASON CJ: Yes, Mr Solicitor?

MR GRIFFITH: If the Court pleases, I have had discussions

with Mr Pauling and subject to the Court's
convenience it might well be more economical of

time if the Commonwealth was last in argument.

MASON CJ: Very well.

MR T.I. PAULING, OC, Solicitor-General for the Northern

Territory: May it please the Court, I appear with my learned friend, MR G.R. NICHOLSON, on behalf of

the Attorney-General for the Northern Territory intervening in the interests of the defendants.

(instructed by the Solicitor for the Northern

Territory)

MASON CJ:  Mr Bennett.
MR BENNETT:  Your Honours, I hand up a short supplementary

outline.

MASON CJ: Thank you. Yes, Mr Bennett.

MR BENNETT: 

Your Honours, this case raises a very short constitutional point under section 90.

The

question concerns the meaning of the word

"exclusive" in that section. The problem, of

course, is that in 1900 there were no territories
and the conception of a territory in 1900 was no

doubt very different from what we now have in the

self-governing territories. The problem,

therefore, is to apply the words of section 90 to

the current situation.

The short simple way of putting this case,

unaided by any authority, would simply be to say

section 90 says that the power to impose duties of

excise is exclusive. Exclusive means no one else

Capital(2) 3/3/92

can exercise it, and therefore one has to ask, "Is the Australian Capital Territory Government someone

else in relation to the Commonwealth Parliament?"

That is the short simple way of looking at it.

The principal authority cited against the

plaintiffs' contention, and indeed, to a lesser

degree, references in other cases, are cases where

prior to the existence of self-governing

territories courts looking at section 90 have used

words to the effect, "Well, section 90 is clearly a

division of powers between the Commonwealth and the

States, therefore 'exclusive' is talking about the

Commonwealth as opposed to the States." Such

remarks, of course, have to be read in their

context. They were not remarks made at a time when

it was present to the minds of those making them

that there might be a.self-governing territory. If

there had been, it may well be that the judges who

decided Nott's case, and other cases with similar

references, would have said that the word

"exclusive" means, exclusive of self-governing

polities within the Commonwealth. Had they used

such a phrase, they would have been no doubt the

other way. There mere fact that the word "State"

was used, at a time when the States were the only

self-governing polities is, in our respectful

submission, not determinative of the question which

faces the Court today.

Now, the case which we submit is the most

helpful is the decision of this Court in

Hematite Petroleum where two of Your Honours

specifically referred to the purpose of section 90.

Your Honours, that case is reported in 151 CLR 599

and the first passage I want to briefly take

Your Honours to is the passage in the judgment of

Justice Deane at page 661. Your Honours will see

at the bottom of that page His Honour says this:

In the context of the foregoing, the

provision of s. 90 of the Constitution that the power of the Commonwealth Parliament to

impose duties of excise shall be exclusive

cannot properly be seen as part of a merely

arbitrary division of legislative powers

between the Commonwealth and the States. To

the contrary, that provision - or some other

means of ensuring uniformity of excise duties

throughout Australia - was a necessary
ingredient of any acceptable scheme for

achieving the abolition of internal customs

barriers which was an essential objective of

the Federation and for ensuring that the

people of the Commonwealth were guaranteed

equality -

Capital(2) 3 3/3/92
et cetera. Now, one asks rhetorically how is that

objective achieved if the Australian Capital

Territory and the Northern Territory are entitled

to impose excise duties on commodities but the

States are not.

There is a passage to the same general effect in the judgment of Your Honour the Chief Justice at

page 632 where, in the second full paragraph on

that page, at about point 3, Your Honour says:

That the object of the power was to

secure a real control over the taxation of

commodities provides strong support for a

broad view of what is an excise -

but the same phrase, "real control over the

taxation of commodities", meaning a real control in

the Commonwealth legislature is, in our respectful

submission, what section 90 is about.

The case which is most frequently cited

against this proposition and, indeed, the only case

in which there has been any real reference to the

problem, although in a very different context, is

Notts Bros v Barkley, which is a case we will have

to spend a few minutes on, 36 CLR 20.

Like many of the English cases, and the other cases which operate in this area, it seems to have

been concerned largely with the rule about sub-

delegation. Indeed, in the judgment of the Chief

Justice and Justice Higgins, at page 24, section 90

is not mentioned.

If Your Honours go to page 24, Your Honours

will see that the third submission, which

Your Honours can take as the relevant one, treated

there by Mr Justice Isaacs as being a section 90

argument, is simply, at point (3):

that sec.8 of the Act was invalid as amounting
to a delegation of legislative power to an
administrative officer;

and the answer, at point 9 of the page, is:

As to (3) - this point is concluded against

the plaintiff by the decision in Powell v

Apollo Candle Co.

However, Justice Isaacs, with whom

Justices Starke and Rich agreed, dealt with it as a section 90 submission. It is dealt with in one

page, and one page only, being page 29. Before

taking Your Honours to that page in detail, I

should show Your Honours what the Act did. The
Capital(2) 3/3/92

relevant provision is set out on page 20, at the provides, in effect, that if the Minister is satisfied of certain matter, the Minister may publish a notice in the Gazette specifying a
beginning of the report, in a footnote, where
section 8 of the Customs Tariff (Industries

country whose exchange rate has changed and:

Upon the publication of the notice, there

shall be charged, collected and paid to the

use of the King, for the purposes of the

Commonwealth, on all goods specified -

an excise. So the provision did not empower the Minister to impose the excise; it fell short of

that. It merely provided that the Minister should

declare certain matters whereupon the Act would

take effect. Justice Isaacs dealt with that this

way, at page 29:

We were greatly pressed to say that the

Parliament had delegated its power of taxation by investing the Minister with arbitrary power

to declare the tax. That, apart from

sec. 90 -

in dealing with the delegation section -

is a cardinal error. Parliament, in

committing such power to a Minister, is in no

sense abandoning any of its power. It has the

fullest control, not only by legislation, but

also by the ordinary operation of responsible

government - a factor not seldom overlooked -

it has complete control over such

administrative acts. Any unnecessary or

improper exercise of power entrusted to a

Minister can be checked or reversed.

Of course, that can be done in two ways. It
can be done first of all through the direct

parliamentary control through the Westminster

system over a minister, which is I think what is

being referred to, and it also of course relates to

the power of legislation. One could add it is the

legislation itself in the form which imposes the

duty. His Honour goes on:

The Privy Council, it was thought, had for ever settled that question in Powell v Apollo

Candle Co -

the case I will take Your Honours to in a moment.

That case decided that in almost analogous

circumstances - any difference telling in

Capital(2) 3/3/92

favour of the validity of the present Act -
the tax was imposed, not by the administrative

action authorized by Parliament, but by

Parliament itself, its law operating upon the

administrative event.

As Your Honours will see when I go to Apollo, that
was a case where the Act said the subordinate

authority could impose and levy the tax.

His Honour deals with that by saying:

almost analogous circumstances - any

difference telling in favour of the validity

of the present Act -

so it would seem that His Honour would have been of

the view that even an express delegation to the
minister would have been valid because of the
nature of the minister and the nature of the

delegation, but in this case of course, where the

wording was that the duty was imposed by the Act,

there was no problem. His Honour goes on at

point 5:

It was sought to distinguish that case from

the present by the terms of the first

paragraph of sec 90 of the Constitution -

which he sets out.

The word "exclusive" was relied on to support

the view that no administrative act whatever

can be made a factor in creating liability to

customs duties. So impracticable a position

is not within the contemplation of sec 90. it

was framed for a well-known purpose, which

appears on the face of the section read in its

collocation. The word "exclusive" means

simply exclusive of State Parliaments,

"exclusive" as opposed to concurrent,
"exclusive" in the sense in which that word is

to limit the ambit of Commonwealth found in secs 52 and 107. It was not intended
parliamentary power but to make that power
exclusive on the subject matter. It has no
function of hampering the Parliament in
utilizing the necessary offices of the
Executive Department as an aid in effecting
its objects.

Now, we submit it is taking that passage out of context to say that it involves the conclusion

that section 90, when it refers to "exclusive", is

only referring to exclusive of the States. It must

mean exclusive of any other body which takes it

outside direct Commonwealth power. The question

is, 6f course, where does one draw the line? One

Capital(2) 6 3/3/92
could imagine a number of different scenarios. One

could imagine at the beginning an Act which simply

said that the Administrator of Christmas Island is

authorized to impos& an excise on guano. There one

has a discretion conferred upon a public servant,

who is subject to ministerial direction, who does

not have plenary authority in relation to the

territory, and one might regard that as a direct

delegation.

The next step, I suppose, is where one says

that one creates a self-governing legislature but,
nevertheless, delegates to it an express power as the delegate of the Commonwealth Parliament. The

third level, the present level, is one which, we

submit, is clearly on the other side where one has

a self-governing legislature with power to

legislate for the peace, order, and good government

of the Territory which is, in every sense of the

word, a new polity, certainly one created by the

Commonwealth but one which operates under a

self-government charter, including the words,

"peace, order, and good government", and one

empowers that to do it. There, we submit, one has

passed across a line; one is no longer delegating,

one is rather permitting or one is transferring a

power which someone else now exercises, not as the

delegate of Parliament but in its own right.

Now, to make that last proposition good I need

to take Your Honours very briefly to the English

case referred to by His Honour and, indeed, the two

predecessor cases because it is a trilogy in which

the same proposition was firmly established, and

this has never, in my respectful submission, been

challenged since the last years of the last

century. The first case is Reg v Burah, 3 AC 889,
a case in 1887. I only need to refer Your Honours

to one very short passage and that is at page 904.

The issue here was whether an Indian legislative

authority had power to delegate, and the argument

was because the Indian Parliament, or the Indian

particular Parliament for the district, was a

delegate of the English Parliament the maxim

delegatus non potest delegare forbade it from

enacting delegated legislation. That was dealt

with, very briefly, at page 904 and in the

paragraph beginning two-thirds of the way down the

page, in the fourth line of the paragraph, the

Privy Council said this:

The Indian Legislature has powers expressly limited by the Act of the Imperial Parliament

which created it, and it can, of course, do

nothing beyond the limits which circumscribe

these powers. But, when acting within those

limits, it is not in any sense an agent or

Capital(2) 3/3/92

delegate of the Imperial Parliament, but has,

and was intended to have, plenary powers of

legislation, as large, and of the same nature,

as those of Parliament itself.

I hav.e given Your Honours a reference to the the Indian Councils Act 1861, (24 & 25 Viet Cap

Act. I will not take Your Honours to it. It is
LXVII) but Your Honours need not go to that. That

Act shows two things of importance: the first is

that the councils have power to legislate for the

peace, order, and good government. That is

section 23. The second is that in section 21 there

is a power of disallowance reserved to the Imperial
Parliament, both features which appear in the

Australian Capital Territory self-government

legislation.

The same result was reached in the second of the cases, Hodge v Reg, (1884) 9 AC 117, which I

can go to more briefly. At page 132 in relation to

the Canadian Parliament the same statement was

made. It is at line 6 on the page where

Their Lordships say at page 132:

They are in no sense delegates of or acting

under any mandate from the Imperial

Parliament. When the British North America

Act enacted that there should be a legislature

for Ontario, and that its legislative assembly

should have exclusive authority to make laws

for the Province and for provincial purposes

in relation to the matters enumerated in

section 92, it conferred powers not in any

sense to be exercised by delegation from or as

agents of the Imperial Parliament -

contra, of course, to the minister in Nott's

case -

but authority as plenary and as ample within

the limits prescribed by sect. 92 as the
Imperial Parliament in the plenitude of its
power possessed and could bestow.

The British North America Act again contained the

same two provisions:  a peace, order, and good

government provision, and a power to disallow

legislation. That was in section 56.

Closer to home, the third of the three cases, the one which is regarded as the principal

authority, is Powell v Apollo Candle Company,

(1885) 10 AC 282. There are two passages I should

refer Your Honours to. At page 284 the challenged

provision is set out at about point 4, and if

Capital(2) 3/3/92

Your Honours see on page 284 against the word

"dutiable" in the left-hand margin at point 4 the

words:

the Governor is authorized to levy a duty upon

such article at a rate to be fixed -

et cetera. So the governor is authorized to levy

the duty, and the old delegatus non potest delegare

argument was raised. The New South Wales

Constitution at the time had a peace, order, and

good government clause and a power of disallowance

reserved to the Imperial Parliament.

At page 290 the Privy Council was able to deal

with the submission with commendable brevity, and

they said at point 2, after referring to Hodge and

Burah:

These two cases have put an end to a

doctrine which appears at one time to have had

some currency, that a Colonial Legislature is
a delegate of the Imperial Legislature. It is

a Legislature restricted in the area of its

powers, but within that area unrestricted, and

not acting as an agent or a delegate.

And they apply the principles and hold the

legislation to be valid. Now, as if that were not

enough, that has been referred to by Justice Wilson

in this Court in R v Toohey ex parte Northern Land

Council, 151 CLR 170 at 279. His Honour there was

dealing with the status of the Administrator of the

Northern Territory and the extent to which

regulations made by him could be challenged, but in the course of this case at page 279, His Honour set out section 5 of the Self-Government Act applicable

to the Northern Territory, which says:

"The Northern Territory of Australia is

hereby established as a body politic under the

Australia." Crown by the name of the Northern Territory of

That provision appears virtually identically in the

Australian Capital Territory (Self-Government) Act,

section 7. His Honour goes on:

This section is of fundamental and

far-reaching importance. It brings into being

a new self-governing polity under the Crown.

Of necessity, it required the appointment of a representative of the Crown in right of that polity, to administer the government thereof

and perform the traditional vice-regal

functions. Section 6 invests the Legislative

Assembly with power to make laws for the

Capital(2) 9 3/3/92

peace, order and good government of the

Territory, a power which in my opinion,

subject to the limits provided by the Act, is

a plenary power of the same quality as, for

example, that enjoyed by the legislatures of

the States. The constitution of the Territory

as a self-govarning community is no less

efficacious because it emanates from a statute

of the Parliament of the Commonwealth than was the constitution of the Australian colonies as self-governing communities in the nineteenth

century by virtue of an Imperial statute.

And he refers to Hodge and Powell and, in my

respectful submission, the propositions established

by those cases are really beyond doubt.

So if the test is, as we submit it is,

might call the extended doctrine of Nott,

delegation; if the test is, is the subordinate body what one

acting as a subordinate or as a delegate of the

then the legislation may be valid. But if it is a
self-governing polity, not acting as a delegate,

then in our respectful submission it falls on the

other side of the line, it becomes someone else, to

use the phrase I put in the submissions, and

section 90 operates to prevent the legislation.

I have referred briefly in paragraph 5 of the

original submissions to the decision in

Commonwealth v Carkazis, 23 ACTR 5. That is a

decision of Chief Justice Blackburn sitting in the

Supreme Court of the Australian Capital Territory

and it is significant that he draws the same

analogy that is drawn in these cases and rejects a submission that there was no power in the then ACT

Government to sub-delegate. It is a decision under

the Seat of Government legislation. But he refers
to Dignan's case as rejecting the proposition that

one cannot have delegated legislation and he refers

again to the status of the Territory.
There, under a form of administration which

did involve the words "peace, order, and good

government" but which vested it in the Governor-

General. It is an indication of the significance
of the words of delegation.

I should very briefly just mention a case

relied on by my learned friend, Mr Pauling, on

behalf of the Northern Territory and this is

referred to in paragraph lf of the new submissions.

He relies on a decision of Mr Justice Sikri in

Delhi Municipality v Mills, a case in the All India

Reports. I do not want to spend a lot of time on
this. I simply want to point out in relation to
Capital(2) 10 3/3/92

that case that it dealt with provisions of the

Indian Constitution which are totally different to

our provisions.

Might I just hand up to Your Honours the relevant provisions of the Indian Constitution

which my learned friend submits correspond to

section 90. The passage my friend relies on in the

case - I will just read it to Your Honours, it is a

very short passage. It concerned the powers of the

Government of the Corporation of Delhi to impose

certain forms of taxation and His Honour said:

Apart from authority, in my view

Parliament has full power to delegate legislative authority to subordinate bodies.

This power flows, in my judgment, from

Article 246 of the Constitution. The word

"exclusive" means exclusive of any other

legislature and not exclusive of any

subordinate body.

My friend relies on that in relation to section 90. documents I have just handed to Your Honours,

Your Honours will see, first, it is in the part of

the Constitution headed, "Relations between the sections 245 and 246 for the division of powers.

Your Honours will see, in 246(1):

Parliament has exclusive power to make laws

with respect to any of the matters -

in -

the "Union List" -

and -

Parliament, and, subject to clause (1), the

Legislature of any State also, have power to

make laws with respect of any of the matters -

in -

the "Concurrent List" -

and -

State has exclusive power to make laws for

such State -

in the matters in

the "State List" -

Capital(2) 11 3/3/92

and there were then three lists, the Union List,

the Current List and the State List.

Obviously, when one is construing the word

"exclusive" there, one is construing it in the

context of a division of power between State and

Union. It is completely different to section 90.

Indeed, it is of some significance that when one

looks at the other sections of the Constitution

which used the word "exclusive", it talks about

exclusive of the States. That does not appear in

section 90.

So, if anything, one has an expressio unius

the other way. But, certainly, one does not get

any help from the Indian case where the

Constitution is quite different. I should add that

the power there, the power delegated to the Delhi

Council, was, in any event, not a plenary power.

It did not have power to make laws for the "peace,

order, and good government". What was delegated
was an express power in relation to taxation. So

we would submit that case really does not assist

Your Honours at all.

So to summarize on the first aspect of the

case - that is what I might call the non-section 52 aspect of the case - it is my respectful submission

that there is no reason for reading the word

"exclusive" as meaning exclusive of the States. A
more rational meaning, and one more in accordance
with the general policy of section 90, is to read
it as exclusive of anyone else, or perhaps any
independent self-governing polity.

The mere fact that a particular polity may be

it does not make it a

subject to a disallowance or may be created by the relevant sense. Certainly

delegate. We would submit if one looks at the

purpose of section 90, the purpose of enabling the

Commonwealth to control something, that purpose is simply not achieved if one says, "Well, the

Commonwealth can control it indirectly, because it can always disallow legislation or it can repeal

the Australian Capital Territory (Self-Government)
Act or it can amend it".

That is not the sort of control which is being

talked about. The sort of control Justice Isaacs

referred to and the sort of control which we submit

is relevant is direct governmental control as part

of economic planning. Once one applies that test

and looks for the need for uniformity there, there

is simply no reason for treating a self-governing

territory as different from a State.

Capital(2) 12 3/3/92
DAWSON J: 

What would happen if there were an express

provision saying, "the peace, order, and good
government of the Territory, including the
imposition of excise duties"?

MR BENNETT: 

Your Honour, it would be a question of

construction then as to whether that power was
conferred as delegate of the Commonwealth
Parliament or as part of a plenary grant of power

to an independent legislature. One would have to
look at it separately. If that simply appeared as
one of the powers conferred, or in addition to the
peace, order, and good government power in the Act,
that would not be sufficient to make it a delegate.

But if the legislation said, for example, "the

legislature of the Territory, in effect as personae

designatae, shall have power to impose duties" and

that power was under the control of the Minister

for Territories in the same way as any other

delegated power, then, in my respectful submission,

that would simply be a delegation and it would be

valid.

Questions of construction would then arise, but the ultimate question, we submit, is: is it

done as delegate? That phrase, "as delegate", is

not taken from any case. It is simply that one

must draw a line somewhere, one must apply some

sort of test.

DAWSON J:  What is the test of delegation?

MR BENNETT: 

The test is a simple test of agency. doing it for agent for?

Is one

So it is really the act of

the Commonwealth Parliament. We know from Nott's

case, where the minister makes declarations which

are relevant to it, it is done as delegate in that

sense. Or is it something done by a body which is

given the plenary powers and does not act as

delegate? It is to some extent a verbal

distinction, but we would submit a real

distinction.

The law of agency, perhaps as applied in the

governmental context, is, we would submit, the

appropriate test to apply. One has to search for a
test. It may be there are other tests one could

usefully apply. That appears to us, with respect,

to be the most convenient. It is the one which

best accords with the policy of section 90 as

defined by the Chief Justice and Justice Deane in

Hematite.

BRENNAN J:  Can a taxing power be delegated in such a way

that the proceeds of the exercise of the delegated

power neither find their way into consolidated

Capital(2) 13 3/3/92

revenue, nor are subject to the appropriations

power?

MR BENNETT:  As to the first, yes. As to the second, there

might be more difficulty with that. There are

cases which suggest that one is entitled, when one

imposes a tax, to direct payment in a particular

direction. One is simply, I suppose, leaving out

the intermediate step of paying it into

consolidated revenue and out of it. If the

Commonwealth has power to say an excise shall be

imposed, and then to say, by a separate Act, the

proceeds of that excise shall be paid from

consolidated revenue to a territory government, why

should it not have power to put them in the one

piece of legislation?

So far as the appropriation's power is

concerned, there may be a difficulty. But again,

the mere fact that the money is directed in a

particular direction would probably not be

decisive. The test section 90 looks to is not so

much where the money goes as the power to impose

it.

BRENNAN J:  Oh no, I would not have thought that section 90
covered my question at all. It was directed rather

to the notion of the extent of the power of

delegation.

MR BENNETT:  Your Honour, the power of delegation is really

a separate question from who it is paid to. The

Parliament can delegate its powers so long as it retains the ultimate control over them, and there are many cases since Apollo Candle and since Dignan

which have laid that down. There would seem to be

no reason why that would not apply to a taxation

power so long as the ultimate control is maintained

in the Parliament, and really so long as the power

is clearly an act of delegation, so the ultimate

act is the act of the Parliament itself.
That is really the test. One cannot say that

a piece of Australian Capital Territory legislation

is in any sense an act of the Commonwealth

legislature. One can say that a piece of delegated

legislation by a Minister or by any other person

delegated is an act of the Commonwealth
legislature. Indeed, there are cases where the

Commonwealth legislature has picked up State legislation, and one can look to the Judiciary Act

and one can look to the Commonwealth places

legislation as examples of that. But again, the

ultimate source of the imposition is the

Commonwealth act, whereas that is not the case

here, because the creation of a self-governing

polity means that there is one step removed. There

Capital(2) 14 3/3/92

is a relevant step between the act of the allegedly

subordinate legislature and the act of the

Commonwealth legislature.

The second aspect of the question is that

which concerns section 52, and as we apprehend the
way the issue is raised against us, two separate

matters are put in relation to section 52. The
first seems to be that section 52 picks up
section 90 and makes it subject to this
Constitution, which includes section 122. May I

just put that in stages. Section 52 provides that:

The Parliament shall, subject to this

Constitution, have exclusive power -

in relation to certain matters. One is the seat of

government, one is Commonwealth places, one is

certain public service departments and one is other

matters declared by this Constitution to be within

the exclusive power. The only matter that seems to

fall within placitum (iii) is section 90. So the

argument against us is "Well, section 52 picks up

section 90, confers exclusive power, but does so

subject to this Constitution. When legislation is

enacted under section 122 that therefore can

override section 90." We submit that is simply

incorrrect, for a number of reasons.

The first is that the words, "subject to this

Constitution" are, we submit, words which are introduced into section 52 for the purpose of admitting the exclusory provisions of the

Constitution such as, for example, section 92; such as, I suppose, prohibitions in section 117 and

section 116 and so on. Those exclusions apply to

section 52. In so far as they are restrictions on

Commonwealth power, section 52 picks them up. And,

indeed, there are two cases which provide examples

of that. I do not suggest that these cases lay

down any principle supportive of what I am saying,

they are simply examples of that operation of the
words, "subject to this Constitution". They are

Pemberton v Commonwealth and Le Leu v Commonwealth,

respectively in 49 CLR 382 and 29 CLR 305. They
are both cases involving the exclusion in
section 85. That involves some specific

limitations of Commonwealth power in relation to

departments which were taken over, and those

specific exclusions were held to apply to the

exclusive power.

But it is quite a different thing to suggest

that the words, "subject to this Constitution" are

intended to limit the exclusivity by reference to

other broad constitutional powers. The argument

has to be that there are two types of Commonwealth

Capital(2) 15 3/3/92

power, exclusive and non-exclusive, and that where

one has an intersection between them the words,

"subject to this Constitution" require, in some

sense, the subordination of section 52 to

section 122.

Now, may I just illustrate that. One has, if

this argument is right, two areas: one has the

power to legislate for territories, which is one

circle, and one has an intersecting circle which is

power to impose an excise. Within the area of

intersection one has power to impose what we might

call a territorial excise, to have a law which is

both a law in respect of a territory and a law in

respect of an excise. The argument then says,

"Well, section 122 authorizes matters within that

area of intersection, section 52 authorizes matters

within that area of intersection, but section 52,

although it says it is exclusive, makes that

subject to this Constitution" and, therefore, one

prefers the non-exclusive power in section 122 and, therefore, one can excercise it. In our respectful submission, that argument is fallacious. It is

fallacious because there are not two sorts of

power, exclusive and non-exclusive, there is only

one sort of power but there is a separate provision

that certain powers in that exercise is exclusive.

Now, if one looks at it that way one achieves

a completely different result. One still has the

intersecting circles but one has a mandatory

provision in section 90 which says that the power
to impose excises is exclusive. That mandatory

provision must operate, we would respectfully

submit, as much within the area of intersection as

in the rest of the circle, and section 52 when it

says, "subject to this Constitution" is not
intending to subordinate the exclusivity, it is
subordinating the power. In other words, the
words, "subject to this Constitution" qualify the
power, they do not qualify the exclusivity of the
power. If the Constitution has a limitation on•
power, that applies in section 52, but where the
Constitution confers a power one does not construe
that by virtue of these words as overriding the
exclusivity.

The other aspect is this, that if one assumes, contrary to my submissions, that there is power in section 122 to authorize a self-governing

legislature to impose an excise, and I stress that

is contrary to the other arguments I am putting, but if one does find such a power in section 122 then, in my respectful submission, one would not construe it as being exercised by mere general

words, one would have to find, as Justice Dawson
put to me earlier, some express provisions making
Capital(2) 16 3/3/92

it clear that, notwithstanding the exclusivity in

section 90, the Commonwealth under the Territories

power was delegating such a power. One would not

expect to find it done, as it were, by a side wind

in a general grant of power, but I stress that is a

subsidiary argument to the main one.

DEANE J: But, even if it not be delegation, the powers of

the ACT Assembly are carved out of the powers of

the Parliament.

MR BENNETT:  Yes.
DEANE J:  And what section 90 does is not to make the powers

of the Parliament exclusive of another body.

"Exclusive" qualifies powers, so it makes the

powers of the Parliament exclusive of powers which

are not powers of the Parliament.

MR BENNETT:  Yes, but that does not, in my respectful

submission, answer the problem.

DEANE J: Well, it puts a question beside it.

MR BENNETT:  It puts a question, Your Honour, but we would

submit that the effect of the three nineteenth

century decisions and the more recent cases

applying them, is that once one creates a new

self-governing polity, there is a degree of

separation; there is this bringing into existence

of a new entity with its own independent powers and

discretions and the relationship to the old, while

it may remain for certain purposes, does not make

its Acts subordinate legislation of the first. It
is analogous perhaps to the way an Imperial Act
created the Commonwealth of Australia; one would
not suggest that legislation of the Australian

Parliament, even in 1901, was in any way delegated

legislation or subordinate to the

Imperial Parliament.

DEANE J: Yes, but it does raise the question that if

section 90 says relevant powers of the Parliament

are exclusive, what does that say in relation to

powers carved out of the relevant powers of the

Parliament? On one approach, it says nothing at
all.

MR BENNETT: Well, it does, Your Honour, because the power

cannot be transferred to another person. The

Commonwealth would be acting contrary to section 90

if, for example, it were to confer the power of the

States. Suppose it were by a simple Act of

Parliament to say the States may impose excises and

assume on its true construction that it was not
empowering him to do it as its delegates; it was

simply transferring the power.

Capital(2) 17 3/3/92
DEANE J:  I think I follow the way you put it. While I am

interrupting you, do you rely at all on sections 80

and 81 of the Constitution? It is bringing you

back to what Justice Brennan asked you.

MR BENNETT:  Yes, it is. Your Honour, subject to all the

risks of adopting an argument on my feet, I

would - - -

DEANE J:  I was not suggesting you put an argument; I was

just asking - - -

MR BENNETT:  No, but, Your Honour, I would with respect put

that argument, although it is not in the

submissions, that those sections demonstrate that

part of the purpose of section 90 is to ensure that

the proceeds of the excise pass into the

consolidated revenue fund and that is an additional

reason why this legislation is invalid. It may be

that one could in some way notionally have a direct

payment where notionally the money goes to

consolidated revenue, but is applied directly. But
even if that is so, that is not done here. The

proceeds here are paid directly to the Australian

Capital Territory's fiscus, and I would adopt that

as an additional reason why this legislation is

invalid.

Your Honours, the other aspect of the second

argument is the one which turns on the language of

section 52(i) which deals with the seat of

government, and what seems to be suggested is that

there can be a passing of power to legislate in

relation to the seat of government to the

Australian Capital Territory Parliament. corresponding passage of power to impose an excise.

One simply treats as parallels placitum (i) and

placitum (iii).

The short answer to that, of course, is that

the Australian Capital Territory (Self-Government)
Act is not an Act under section 52(i) at all. It
is enacted solely, we would submit, under

section 122. Might I just remind Your Honours.of a

couple of short passages which make that point

clear.

In Spratt v Hermes, 114 CLR 226, there are

passages in a number of the judgments which make it

quite clear that the relevant legislation is

enacted under the Territory's power. That, of

course, concerned previous legislation governing

the Australian Capital Territory, but the doctrine,

we would submit, is quite clear.

Sir Garfield Barwick said at page 241 at the top of

the page:

Capital(2) 18 3/3/92

In particular, I see no relevant consequence

in the fact that the seat of government is to

be found within the Australian Capital

Territory or in the fact that the Parliament

and the Executive Government there 8xercise

powers which are federal in their nature. In my opinion, the power to make laws in respect

to the Australian Capital Territory is derived

from s. 122; in relation to the present

matter I do not think that anything is added

to or subtracted from that power bys. 52(i).

Mr Justice Kitto said the same thing at page 258;
Mr Justice Taylor at page 262 to 263, and

Justice Owen at page 282. They all made it quite clear that the relevant power is in section 122.

BRENNAN J: Is there a territorial identity between the

Australian Capital Territory and the seat of

government?

MR BENNETT:  No, Your Honour. That is made clear by

Worthing v Rowell & Muston Pty Ltd, 123 CLR 89.

Your Honours will recall this was one of the two

cases which led to the passing of the Commonwealth
places legislation, and there are a number of

references in that case to the distinction between

the two. Sir Garfield Barwick at pages 96 to 97,

starting with the last words on page 96, said:

In my opinion, the seat of government is a

place, required by the Constitution to be
geographically situated in relation both to

the City of Sydney and the territory of the

State of New South Wales as well as to

territories of the Commonwealth. It must not

only be so situate, but must be vested in and

belong to the Commonwealth. The expression

"Seat of Government" as found in the

Constitution of the United States ..... clearly refers to a physical area of land.

He refers to some cases there.

It seems to me that the word "place" is used

ins. 52 somewhat in contradistinction to a

territory acquired by the Commonwealth to

which s. 122 has relevance. The difference

between a place and a territory is perhaps

more than one of degree or extent. A

territory of necessity is comprised of an area of land usually of considerable extent but, as well, in general already subject to some

political arrangements. But this distinction

is not necessarily, in my opinion, definitive
of any difference in the extent of the

relevant legislative power of the

Capital(2) 19 3/3/92

Commonwealth, a matter into which I find it

unnecessary to go.

Justice Menzies, at the bottom of page 114 at about

point 7, against the words "the United States" in

the left-hand margin where they secondly appear,

said:

In my opinion the Australian Constitution likewise contemplated that Parliament should

determine that a place is to be the seat of

government ands. 52(i) is a grant of power to

make laws with respect to that place. This

latter power is a power separate and distinct

from the power to make laws for a larger

area - the Australian Capital

Territory - under section 122 of the

Constitution. The acknowledged existence of

the full power of Parliament to make laws for

the larger area has, it seems, made it

unnecessary to define the limits of the power

conferred bys. 52(i) to make laws for the

seat of government of the Commonwealth.

And Justice Windeyer, at page 124, said the same

thing. So it seems to be assumed that seat of

government is some narrower term. It has never

been clearly defined in any case in this Court

exactly what it comprises. No doubt it covers the
land on which Parliament stands. It may cover some
immediate precincts. It may or may not include

this Court. It probably includes the land on which

departments of government stand. It may or may not include some area around them. It almost certainly

would not include Tharwa and Hall. Where one draws

the line one does not know. But certainly, the

problem has never arisen because legislation for

this Territory has always been enacted under

section 122, and that has been made clear in

Spratt's case.

So it is not correct to say that the

Australian Capital Territory (Self-Government) Act

is in any sense legislation under section 52(i).

It may well be that an interesting question would

arise as to whether that placitum permits the grant

of self-government alone in the absence of

section 122. It may well be that it does not

because of the exclusive nature of the power.

Indeed, that would be what we would submit would be

the consequence, but it is a consequence of no

particular significance because section 122 is wide

enough to permit the legislation to be made.

In relation to Commonwealth places, we would

submit that the law laid down in Worthing is still

applicable to Commonwealth places in the

Capital(2) 20 3/3/92

territories. Because the provisions of

section 52(i) are exclusive, one can do what was

done in the Commonwealth places legislation and

adopt State laws as part of Commonwealth law, as is

done in the Judiciary Act - and indeed that was

suggested by this Court in Worthing's case and in

Phillips' case, which is the other case which led

to that legislation - but the Commonwealth places

legislation does not refer to territories.

There is a very live question which, subject

to something I will say in a moment, has not been

determined - it certainly has not been determined

in this Court - as to whether a Territory

government can legislate in relation to

Commonwealth places within the Territory. We would

submit that the better view is that it cannot,

because the power to legislate with respect to

Commonwealth places is exclusive under section 52.

There is a reference to that in an article in

the Federal Law Review, which I have not given

Your Honours reference to except in the

submissions. It is an article by Mr Rose entitled

The Commonwealth Places (Application of Laws) Act

in volume 4 of the Federal Law Review at page 263 and 268, where Mr Rose refers to the question but does not answer it.

There is also a decision of the Supreme Court

of South Australia in Reg v Holmes, 93 FLR 405,

which I hand up to Your Honours. The only

relevance of that case for present purposes is that
the Chief Justice makes it clear that the

Commonwealth places legislation is valid for the

reason given in Worthing, where this Court

suggested how the problem of Commonwealth places

could be overcome.

It is a passage at the bottom of page 406. I

will not take Your Honours to it in detail, but it

does show that one may avoid the exclusivity

problem in section 52 by Commonwealth legislation.

If the Commonwealth legislation picks up State law,

then one has validly enacted oneself. It is not

someone else who is exercising the exclusive power.

That, we submit, is the appropriate way of looking

at it.

I should disclose to Your Honours that there

is - when I say "disclose", it is in my learned

friend Mr Pauling's submissions - there is a

decision of the acting Chief Justice,

Mr Justice Muirhead, in the Northern Territory,

where His Honour reached a conclusion contrary to

the submission I am putting. That is Pryce v King.

King, (1985) 37 NTR 19. It is in 63 ALR.

Capital(2) 21 3/3/92

That involved a person who was charged with a

traffic offence under Northern Territory law within

the precincts of Darwin airport, which was a

Commonwealth place. The argument which I am

putting to the Court was made on her behalf and

made unsuccessfully. The passage which, in my

respectful submission, is the ratio and which

contains the error, appears at page 23 where

His Honour said this at line 15:

Whilst the Northern Territory (Self-

Government) Act certainly granted plenary

powers to the Territory government, it did not

alter the status of the Northern Territory as

a Territory qua the Constitution -

that is plainly correct -

ie, this Territory did not assume the status

of a State in the federal system -

We do not dispute that.

The Act and the Northern Territory

Government's subsequent legislative powers

were brought into effect by reason of s 122 of

the Constitution -

That is correct.

Section 52(i) of the Constitution applies to

Commonwealth places within State territory,

not to land within a Territory as such.

We would submit it applies to Commonwealth places,

wherever they are situated.

The Traffic Act was an exercise of the plenary

power granted by the Commonwealth Parliament

to the Territory Government to make laws for

peace, order and good government and had its source in the grant of power by the
Commonwealth. The s 52(i) argument does not,
in my opinion, apply.

It is really that last sentence and a half, that

because it had its source in the grant of power by

the Commonwealth, exclusivity is not breached.

There is no further reasoning in support of that

conclusion, and we would respectfully submit that

it is wrong, that once the self-governing polity is

set up, the exclusivity does operate. That is a

consequence of the submissions which we make.

For those reasons, Your Honours, it is our

respectful submission that the question which has

been referred to the Court should be answered

Capital(2) 22 3/3/92
favourably to the plaintiffs. The question

appears - the matter referred in an order made by

Your Honour the Chief Justice in which the following question is referred. It is an order of

18 December:

Does section 90 of the Commonwealth

Constitution operate so as to preclude the Legislative Assembly of the Territory from exercising the power to impose duties of

excise -

and we submit that question should be answered in

the affirmative. May it please the Court.

MASON CJ: Yes, Mr Jackson.

MR JACKSON:  Your Honours have our written submission

already, I think, and may we say the first approach

to the question, in our submission, is to look at
the language of the Constitution itself. What we

would submit in that regard is that it does not

suggest that the exclusivity which is contemplated

by section 90 means to the exclusion of anyone

other than the States. And if one accepts that
position for the moment, what emerges from that, of

course, is that in section 90, as in section 122,

as in section 51, as in section 52, and in a number

of places in the Constitution, one simply sees the

legislative power of the Commonwealth referred to

as being the power of the Parliament.

Your Honours, if that is the case, there would

seem no reason, in our submission, why the general

principle as to the power of Parliament, which is

evidenced by cases such as Powell v Apollo Candle

Company and also by Cobb & Co v Kropp, namely that

the Parliament may utilize the organs which it

chooses to enact the legislation provided that it

retains itself its power over the legislation why

principles of that nature are not applicable. And,
Your Honours, if one does accept the primary
proposition that section 90 does not exclude anyone

other than the States then the position, in our

submission, is that unless one were to overrule

Nott v Barkley, then the result would be that the

decision in that case would be equally applicable

to the present case.

Your Honours, could I start - if, in dealing

with the question, one looks at the Constitution

itself, the exclusivity contemplated by section 90
means to the exclusion of anyone other than the

States.

If one goes to section 51, section 51 seems

clearly to be conferring legislative power on the

Capital(2) 23 3/3/92

Commonwealth and the legislative power that it is conferring there is one which when one comes to

taxation is expressed to be a power which has a

relationship - if I can put it that way neutrally,

Your Honours - to the States. It says, "taxation",

but so as not to discriminate between States or

parts of States. It does not speak of anything

else.

If one goes to section 52, section 52 also

uses the expression "the Parliament shall have

power to make laws", using the word "exclusive", of

course. When Your Honours see that, the term

"exclusive of the powers of the States" in

section 52 - the term "exclusive" in section 52 has

been treated as being exclusive of the powers of

the States. May I give Your Honours a reference in
that regard. What Your Honours will see in

Worthing v Rowell & Muston Pty Limited,

(1970) 123 CLR 89, and at page 109 at the bottom of

the page, Justice Kitto said - it is the last

paragraph on that page:

For the carrying out of this scheme two

provisions needed to be made and they are

found ins 51 ands 52 respectively, the one

setting out the matters upon which the

Parliament of the Commonwealth has
non-exclusive power to make laws, the

Parliaments of the States retaining their

pre-existing powers but commonwealth laws on

those matters prevailing by force of s 109

over inconsistent State laws, and the other

drawing together the matters upon which -

and His Honour expresses it in this way -

power is vested in the Parliament of the

Commonwealth and denied to the Parliaments of

the States.

Now, His Honour's observation was one in the course of a judgment which, in the result, was

dissenting, but a similar observation can be found

in Justice Menzies' reasons for judgment at

page 113, and His Honour formed one of the

majority. Your Honours will see the paragraph

commencing in the middle of page 113 where

His Honour said:

Section 52 is a provision of the

Constitution which has not been the subject of
a great deal of judicial exposition.

Primarily it is, of course, a grant of

legislative power to the Parliament. It has,

however, a secondary aspect; to the extent to

which it grants legislative power to the

Capital(2) 24 3/3/92

Parliament, it denies legislative power to the

Parliaments of the States.

Now, Your Honours, if one moves from section 52 to

section 89, what one sees in sections 89 and 90 is

that section 89 itself is a position dealing with

the events to occur until the imposition of uniform

duties of customs and Your Honours will see that

the purpose of section 89 is to effect a

distribution, in effect, of revenues collected by

the Commonwealth and a distribution as between the

Commonwealth on the one hand and the States on the

other.

Your Honours, if one goes then to section 90, what one sees is that section 90 contains not one

but two paragraphs. The first paragraph is the one

to which reference has already been made, but when one goes to the second paragraph what one will see

is that it speaks of the effect of the exclusivity

contemplated by the first paragraph upon the laws

of the States which have, up to then, been in
operation. And, Your Honours, that in our

submission supports the general proposition we are

advancing, that the exclusivity contemplated by

section 90 means exclusive of the States, or

exclusive of the powers of the States.

Your Honours, if one goes then to sections 93,

94 and 95, what Your Honours will see is that those

provisions deal with regulation of the situation of
the States and a State in the period after the

imposition of uniform duties of customs.

Your Honours will see that the expression "the

imposition of uniform duties of customs" is the expression which is used as the trigger for the

exclusivity provision of section 90. That is to be

found in the opening words of it. Those provisions

together give an indication, in our submission,

that what was said by the two members of the Court

in Worthing's case is an accurate description of

the effect of the exclusivity. Your Honours, the whole tenor of those

provisions, we would submit, is that they are
discussing a relationship between the Commonwealth

and the States and that impression, Your Honours, is conveyed also, we would submit, by section 107 which again uses the expression "exclusively" and

it uses it in a context where there is an exclusive vesting in the Parliament of the Commonwealth and a

withdrawal from the Parliament of a State.

Now, Your Honours, not all things withdrawn

from the Parliaments of the States were vested exclusively in the Commonwealth because of the prohibitions in the Constitution but, Your Honours,

Capital(2) 25 3/3/92

section 107 again supports the implication that

section 90 is speaking of an exclusivity from the

legislative powers of the States and, Your Honours,

so too - although one must take it in its context -

is section 111, when it speaks of the Parliament of

a State surrendering any part of the State to the

Commonwealth and then, in due course, the part of the State becoming subject to the exclusive

jurisdiction of the Commonwealth.

Now, Your Honours, the submission we have been

making in relation to the Constitution is supported
by the course of decisions, in our submission, in
relation to section 90 itself and, indeed, the

course of decision in relation to section 90, in

our submission, is really quite opposed to the

contention on behalf of the plaintiffs.

Your Honours, if I could go first and briefly

to the case to which my learned friend referred,

Nott Bros & Co Ltd v Barkley, 36 CLR 21. The case

is of importance, Your Honours, because, in dealing with section 90, what is clear from the decision is

that the Court took the view that the exclusivity

referred to in section 90 means only that the

States are excluded from the power. Your Honours,

could I go first to page 29, and Your Honours will

see at page 29 in the third line, the question

numbered (3) was described by Justice Isaacs as

being:

Sec. 90 of the Constitution -

and Your Honours will see - this is the passage to

which my learned friend referred but I wish to

refer to it again for a number of reasons - the

first is that in the first-half of the passage, in

effect, on page 29, His Honour rejects the

proposition that if one puts section 90 to the

side, that the operation of the power to make laws

with respect to taxation is a power which cannot be dealt with in the way contemplated by cases such as Apollo Candle.

Now, Your Honours, one sees that in the

passage which commences in the third line on the

page and then goes to about half-way down the page

and, Your Honours, that clearly contemplates, in

our submission, that the power is one which need

not be exercised by the Parliament itself.

Your Honours, if I could pause for a moment in

dealing with that case to go to the
(Self-Government) Act, what one sees in relation to
the (Self-Government) Act is that, if one goes, for

example, to section 35 - Your Honours, perhaps I

should say one thing: if one goes first to

Capital(2) 26 3/3/92

section 22 Your Honours will see the power there

expressed, the legislative power in section 22(1).

Your Honours, certain matters are excluded and they

are listed in section 23(1). One also sees,

Your Honours, that if one goes to section 35 that

there is a power of disallowance by the

Governor-General in section 35(2). Your Honours, I

should say that there is an inconsistency provision

in section 28.

Your Honours, if I could, having referred to

those provisions, just say that if one goes back to

the observation made by Justice Isaacs in

Nott Bros, at page 29, about a third of the way

down the page, where His Honour observed:

Any unnecessary or improper exercise of power

entrusted to a Minister can be checked or

reversed -

Your Honours, one might say look, in the present

case, at the provisions of the Australian Capital

Territory (Self-Government) Act, and look also to

the fact, which is something which underlies but is

not really mentioned in our learned friend's

submission, that whilst it may be something which

it would be politically undesirable for the

Commonwealth to do, there is no question about the

Commonwealth's power, pursuant to section 122,

itself to amend or change the terms of the
(Self-Government) Act or to provide for some

different method of self-government for the

Territory. So that, Your Honours, the power

remains a legislative power of the Commonwealth. Your Honours, if I could go then back to the

same page of Nott Bros. and to the second part of
it, what Your Honours will see is at three-quarters

of the way down the page, His Honour says:

The word "exclusive" means simply

exclusive of State Parliaments, "exclusive" as

opposed to concurrent, "exclusive" in the

sense in which that word is found in section

52 and 107. It was not intended to limit the

ambit of Commonwealth parliamentary power but

to make that power exclusive on the subject

matter.

His Honour goes on to say:

It has no function of hampering the Parliament

in utilizing the necessary offices -

et cetera. Now, Your Honours, if that is the case

and if "exclusive" means that, why, we would ask

Capital(2) 27 3/3/92

hypothetically, does not the principle from

Apollo Candle then come to operate?

Now, Your Honours, one should note about

Nott Bros. members of the Court - there were five members of

that the observations made by

the Court - but it seems plain enough, we would

submit, that when the other two members of the

Court who delivered reasons for judgment, the
Chief Justice and Justice Higgins, spoke of

question 3 - and this is at page 24, Your Honours -

they described question 3, about a quarter of the

way down the page, as being:

that section 8 of the Act was invalid as

amounting to a delegation of legislative power

to an administrative officer;

and then they say about that, towards the bottom of

the page:

As to (3) - this point is concluded against

the plaintiff by the decision in Powell v

Apollo Candle Co.

Your Honours, involved in that, we would submit

with respect, must have been a rejection, albeit
without feeling the need to say a word about it, of
the proposition concerning section 90 to the

contrary.

Now, Your Honours, turning then from that

case, one of the observations which has been

frequently adopted in relation to the function to

be performed by section 90 is that of

Sir Owen Dixon in Parton v Milk Board (Viet.),

(1949) 80 CLR 229 at page 260 and observations to a

similar effect have been adopted. Could I take

Your Honours to that passage. It appears at

page 260 and it is about a quarter of the way down

the page. May I preface what I am about to say by saying this. The observations contains two

elements: one concerning the ambit of the notion of

excise in the context of the purpose of section 90

as broadly speaking a financial control. On that

issue views might differ as to the correctness of the observation. Your Honours, the second aspect of it, however, is where His Honour discusses the purpose of section 90 in terms of exclusivity, and

what His Honour says is this:

In making the power of the Parliament of the

Commonwealth to impose duties of customs and

of excise exclusive it may be assumed that it

was intended to give the Parliament a real

control of the taxation of commodities -

Capital(2) 28 3/3/92

and then he goes on to say to the part for present

purposes relevant:

and to ensure that the execution of whatever

policy it adopted should not be hampered or
defeated by State action.

Your Honours, that passage has been adopted, as I said, on a number of occasions. May I take

Your Honours very briefly to an observation of

Chief Justice Barwick in that regard in

Western Australia v Chamberlain Industries Pty Ltd,

(1970) 121 CLR 1, at page 17. Your Honours will

see that His Honour adopted that passage at page 17

commencing about three-quarters of the way down the

page, where His Honour said:

No doubt Sir Owen Dixon felt similarly when he

was able in Parton v Milk Board (Viet) to

conclude -

et cetera, and then His Honour set out the passage.

TOOHEY J:  The difficulty with some of these passages that

you are taking us to, Mr Jackson, is that they have

to be taken in context, and they are clearly

looking at a Commonwealth-State relationship. But

do any of them go so far as to lay down

exhaustively the operation of section 90 in a way

that forecloses the matter so far as the present

argument is concerned?

MR JACKSON:  Your Honour, I suppose the answer is no, in the

sense that the issue has not been before the Court

before, the precise issue. But may I say, with

respect, that there is really no suggestion

anywhere in the cases, we would submit, to support

the proposition that exclusivity means other than
exclusive of the operation of State power, and all

the indications there are are to the effect of what

I am now submitting.

Your Honours, there are various dicta, of

course, of the kind to which I am now referring,

and why I am seeking to refer to them is to say that if one looks at what dicta there are - and

this is not the only one, of course, it is

expressed in different ways in different cases -

what I am seeking to say is that if one looks at

all the dicta they all support the proposition that

when section 90 speaks of exclusive it means

exclusive of the powers of States, and nothing

more. That is put in different ways in different

cases, but that is the proposition I am seeking to

get to.

Capital(2) 29 3/3/92

I do not want to go through the case ad nauseam, but may I take Your Honours very briefly

to the passages that do support that.

Your Honours, I wanted to refer to that case simply

because it is identified but not set out in another

observation of Chief Justice Barwick. One sees the

proposition referred to in a number of places in

Dickenson's Arcade Pty Ltd v Tasmania, (1974)

130 CLR 177. At page 185, in the second paragraph

on the page, Your Honours will see that in

Chief Justice Barwick's observations in that

paragraph, from the start of it to about a third of

the way down the page he says he adopts what he
said in Western Australia v Chamberlain Industries,

which is the case to which I just referred, the

passage to which I just referred.

Then, Your Honours, at page 199 one sees the issue referred to by Justice McTiernan, commencing

a little above half-way down the page, His Honour

says:

Dixon J. (as he then was) said in the Milk

case -

and then he sets out the long passage.

At page 218, at the bottom of the page,

Justice Gibbs, in a passage which goes through to

about a third of the way down the next page, refers

to the observations of Mr Justice Dixon in Parton v

Milk Board and, at page 222, a little past half-way

down the page, says:

The Constitution is a federal constitution,

ands 90 is intended to effect a distribution

of the power to impose taxation between the

Commonwealth and the States.

BRENNAN J:  But if you go back to what Chief Justice Barwick

said at page 185, and there is reference in the

sentence before the one to which you drew

attention, to the unity of the national economy, it

rather makes the point that Justice Toohey was

making to you a moment ago, does it not?

MR JACKSON: Well, Your Honour, the point about it is this,

that it is clear that there is an exclusive control

of customs and excise and one of the purposes of

doing it is to influence the economy of Australia,

that is one of the purposes of having the power.

Now, if one says that and if one says, at the same

time, that the power is one to be exercised by the

Commonwealth then, Your Honour, it is a question of

the manner in which the power is to be exercised.

So far as the States are concerned, the States have

no power. So far as the Territories are concerned,

Capital(2) 30 3/3/92

the Commonwealth has all the power. If something

happens which, in the Commonwealth's view, would
not influence the economy of Australia in a way

with which the Commonwealth is happy, then it has

the power under section 122 to - I am sorry, I am not expressing myself very clearly in relation to

the Territories. The Parliament can do, in

relation to the Territories, in effect, whatever it

chooses to achieve the aim of having the economy of

Australia influenced.

Now, Your Honours, it may well be that in

respect of a territory the Commonwealth takes the

view that there should or should not be incentives

one way or another imposed in relation to the

carrying on of particular activities in a

territory. That is something that it can do by the

utilization one way or another of the Territory's

power. One of the stages to self-government, in

cases where it is possible for a territory to have

self-government, it may say, "Well, we will allow

the Territory Parliament to make laws which deal
with the topic but, of course, the laws are always

the laws which are subject to the power of the

Parliament under section 122".

BRENNAN J:  So the Northern Territory Government, for

example, could make Darwin a free trade port?

MR JACKSON: Yes, Your Honour.

BRENNAN J: 

And goods which entered there would, under the

protection of the relevant Commonwealth
legislation, have free passage into the rest of
Australia?

MR JACKSON: Well, they could have, Your Honour, yes.

BRENNAN J: Without constitutional limitation at all events?

MR JACKSON:  That is so, Your Honour.
BRENNAN J: Administratively it could be controlled, but not

constitutionally?

MR JACKSON:  Indeed, Your Honour, yes. And, Your Honour,

there is no particular difficulty with the

proposition, we would submit. There may well be -

one has to look at it from the point of view of not

just encouraging but also inhibiting, and it may

well be that, in appropriate cases, for example a

power to impose excise could be used to inhibit the

carrying on of particular activities within a

territory. Your Honour, one does not always, in

the government of a territory, have to exercise the

powers of government against things regarded as

being undesirable in the heaviest way. It is
Capital(2) 31 3/3/92

possible sometimes to discourage in other ways and,

Your Honour, the point I am simply seeking to make

about that is that it is within power to do it and

it may be quite appropriate to do it in relation to

a territory.

In the Australian Capital Territory it might

well be desirable not to encourage the carrying on

of particular rural activities, for example; it

might not be thought to be desirable to permit the

carrying on of forestry activities which would take

a long time in areas that might become needed for

housing, for example; and there are various ways of

doing that. And when one sees the expression

"uniform duties of customs" used in the

Constitution it is speaking in the context of the

States.

Your Honours, I was referring I think to

page 222 in that case to the dictum of

Justice Gibbs, where he said that section 90 was

intended to effect the distribution of the power to

impose taxation between the Commonwealth and the

States. Then, Your Honours, at page 230,

Justice Stephen, commencing a little above half-way

down the page, said:

The degree of certainty which has been

conferred upon the phrase, at least in

relation to that point on the journey of goods

from producer to consumer beyond which a tax

is no longer viewed as an excise, has been

hard won and should not lightly be disturbed

in this important aspect of constitutional law

concerned with the delineation of the boundary
between State and federal legislative

competence in the taxation of the citizen.

That is another observation to the same effect.

Then at page 238, Your Honour the Chief Justice, in

the passage commencing about a third of the way

down the page said:

In place of the doctrine of implied

prohibitions -

and so on, and Your Honour referred to there

being -

an appreciation of the constitutional

significance of the denial to the States of

legislative power with respect to duties of

customs and excise duties -

and then proceeded to quote the passage from

Parton v Milk Board.

Capital(2) 32 3/3/92

Your Honours, one sees observations to the

same effect in Hematite Petroleum Pty Ltd v

Victoria, (1983) 151 CLR 599.

MASON CJ:  Mr Jackson, it seems unnecessary to take us to a

repetition really of the same idea in a number of

judgments. Perhaps you could hand in a list of the

authorities where we could see the relevant pages.

MR JACKSON:  Certainly, Your Honour. I was going to give

Your Honours the pages of these except for one, and

that was a particular observation of

Justice Murphy, and I wondered if I might do that

perhaps in relation to this case.

MASON CJ: Yes.

MR JACKSON:  Your Honours, the other pages are pages 615 to

618 in the judgment of Chief Justice Gibbs,

Your Honour the present Chief Justice at page 631,

and then at page 637, the last paragraph on the

page, Justice Murphy said, in relation to

section 90:

Section 90 provides that, on the

imposition of uniform duties of customs, the

power of the parliament to impose duties of

customs and excise, and to grant bounties on

the production or export of goods, shall

become exclusive (that is, of the power of the

States).

A similar observation was made by His Honour in

Gosford Meats Pty Ltd v New South Wales,

(1985) 155 CLR 368, at page 387.

McHUGH J:  Mr Jackson, what would be the policy reason for

differentiating between excises imposed by

Territories and those imposed by States?

MR JACKSON:  Your Honour, the difference, really, is this,

that so far as the States are concerned there are,

I suppose, really, two reasons for removing the

power to impose duties of excise from the States.

Perhaps I should say there is really one reason,

one suspects, for removing the power from the

States and that is that in the end, whilst the

Commonwealth could at any event under

section 5l(ii) impose duties of excise, to remove

the power from the States avoids any possibility of

there being conflict.

McHUGH J: Except, in Hematite, Mr Justice Mason expressed

the view that under section 5l(ii) the Commonwealth

could legislate so as to prevent the States from

imposing excise duties. Then I think
Capital(2) 33 3/3/92

Mr Justice Murphy expressed the same view in some

other case.

MR JACKSON:  Your Honour, that is true, that is a

combination of Sl(ii) and 109, but His Honour

the Chief Justice also said something rather

broader about it. The passage is at the bottom of

page 631 and the top of page 632 and, after

referring to - Your Honour said,"The possibility",

the last five lines on page 631 and then, at the
top of page 632:

In any case, to make the power exclusive is to free its exercise from some of the political

controversies and constraints which would

inevitably surround any attempt by the

Commonwealth Parliament to pass inconsistent

legislation designed solely to override a

State law.

So, Your Honours, it serves not just a legal but

also a constitutionally political purpose, if I can

put it that way. So it takes away from the States
the power to do it.

So far as the States are concerned, the States

have no relevant power in relation to the

territories. That has the consequence that, in any

event, the only power in relation to the

territories is that of the Commonwealth. It is

then for the Commonwealth to choose whether there

shall be or shall be permitted to be any taxes of a particular kind, whether they be excises or not, in or in relation to the Territory.

So, Your Honour, the purpose, really, if one

is looking at it from a constitutional position, is

to ensure that only the Commonwealth may levy or

permit the levy of such taxes. Without seeking to

go into economic areas, that means that one polity,

the central polity, is the only body which has

course, choosing the rates at which they will be power to impose such taxes and that involves, of imposed and the particular circumstances in which
they will be imposed.

Your Honours, whilst no doubt one could argue, as it were, until the cows come home about the

desirability of uniformity on the one hand and
disparate approaches on the other, this is an area
where it is thought constitutionally desirable for
there to be one.

Your Honours, the other references

Your Honours will see in our written submissions,

except, I think, for a reference to Dennis Hotels v

Victoria, in the Privy Council, 104 CLR 529, at the

Capital(2) 34 3/3/92
bottom of page 631 and the top of page 632. The

passage is, perhaps, a little tortuous when one

comes to understand it but the clear effect of it

is that it involves an acceptance of the

proposition that section 90 is speaking of

exclusivity from the powers of the States.

Now, Your Honours, the argument on behalf of the plaintiffs seeks to rely on the proposition

which has been advanced that a new, albeit

subordinate legislature with power to make laws for

its territories, does not act as a delegate of the

legislature which is establishing it. But,

Your Honours, we would submit that to use that

proposition in that way really seeks to turn it on

its head because the subordinate legislative power,

at least under our Constitution, derives its powers

because they are powers which the legislature,

which is establishing it, may validly either itself

exercise or permit a body established by it to

exercise.

Now, Your Honours have been referred already

to a power in Apollo Candle Co, 10 AC 282, and I

would also refer Your Honours to page 291 of that

in relation to the ability of a legislature to

confer on bodies established by it some of its own

power but, Your Honours, a more recent summary of

the position may be seen in Cobb & Co Ltd v Kropp,

(1967) 1 AC 141 at 157, and the Judicial Committee

there, in the passage commencing between letters C

and D, said that:

The legislature were entitled to use any

agent or any subordinate agency or any

machinery that they considered appropriate for

carrying out the objects and purposes that

they had in mind and which they designated.

They were entitled to use the Commissioner for

Transport as their instrument to fix and

recover the licence and permit fees. They
were not abrogating their power to levy taxes

and were not transferring that power to the

commissioner.

And then it goes on. And, Your Honours, if one

looks at the qualification:

What they created by the passing of the

Transport Acts could not reasonably be

described as a new legislative power or

separate legislative body armed with general

legislative authority -

Your Honours, if one looks at the terms of the

enactment in the present case, the

(Self-Government) Act, any self-government Act

Capital(2) 35 3/3/92

passed in relation to a territory in Australia is

one which itself is subject to the exercise of the

powers conferred by section 122 until one gets to

the point where a territory has become a State.

Now, Your Honours, the remainder of what is

said there is directed to a particular submission

concerning the Queensland Constitution.

BRENNAN J:  What do you mean by that? Do you mean by being

subject to section 122 the powers that are

conferred are capable of recall?

MR JACKSON:  Yes, Your Honour.

BRENNAN J: Is there any difference there from Apollo Candle

and that line of cases?

MR JACKSON:  Your Honour, there is in the sense that if one

is looking at the situation in Apollo Candle and

cases of that kind, what one had was a legislature,

namely, in the end the United Kingdom legislature,

not itself subject to any constitutional restraint

or particular written constitutional conferral of

powers, in relation to that, Your Honour, it then

establishes legislatures of what became

self-governing colonies. Now, Your Honour, in

speaking about the question, whether it was or was

not a delegate, it was directed to a particular

question of the extent to which the United Kingdom

Parliament could delegate, in effect, its own powers.

BRENNAN J: That is not a point of distinction of

section 122, is it?

MR JACKSON: Well, Your Honour, it is in a sense, because

section 122 is a provision which remains in

operation and remains in operation in relation to

any Territory until it becomes a State and,

Your Honour, any power that is given to a

Territory, whether the power be given to a

Territory Governor or Administrator - having no

council or legislature - or given to any of the various stages on the way perhaps to Statehood,

whatever sub-legislative body there might be, is a

power which in the end is subject to section 122

and that is a power of which the Parliament cannot

deprive itself. Your Honour, that is perhaps the

point I am seeking to make.

BRENNAN J: But that was the situation with the

United Kingdom Parliament.

MR JACKSON: Well, Your Honour, that issue did not really

fall to be decided and it may not have resulted in

Capital(2) 36 3/3/92

the answer that Your Honour puts to me, with

respect.

BRENNAN J:  I can see the argument of distinction if there

was a comparison, for example, with the Australia

Act, where the Parliament which was enacting the

law deprived itself of the power that it hitherto

had to recall laws of delegation or creation of

subordinate legislature. I just do not see the
difference at the moment with section 122 in the

context of this legislation.

MR JACKSON: Perhaps I cannot put it beyond what I have said

but, Your Honour, if one is looking at those cases,

they really are not concerned with a question at

all of the nature presently in question here

because, Your Honour, if one assumes that section
90 does apply only to exclude the States and leaves

is, one would think, no more than an exercise of power equivalent to that of the United Kingdom

the power with the Commonwealth, the exercise by
the Commonwealth Parliament of the power to create

a body such as the ACT Legislature and to enact the

Parliament in enacting the Acts pursuant to which

the various colonies obtained self-government.

And, Your Honours, their enactments would not cease

to be valid, because our learned friend's argument

has to make section 90 do a lot of work and it

really means that section 90 means that only the

Parliament and the Parliament as such, can exercise

the power directly to impose duties of excise. Now

Your Honours, if one says that it does not mean

that, it is then necessary for them to go to some

kind of half-way house and that is where they seek

to call in aid the notion of the new Parliament not

being a delegate. But the purpose of the whole

issue of delegation was directed to something else

in those cases.

Your Honours, we would submit that it really

has never been doubted - and Nott Bros is an

ability for the Parliament to delegate or to use indication of it - but the general notion of the
other bodies to exercise its legislative power,
subject to its own powers, that those notions are
applicable to the Commonwealth and, Your Honours,
section 90 uses the expression "the Parliament", as
do sections like section 51 and 52, and the notion
that the term "the Parliament", when used in
section 90 or in section 122, would mean that the
Parliament could not confer legislative power on
subordinate legislative bodies seems curious, we
would submit, when that notion has not been applied
to other provisions which confer legislative power
on the Parliament.
Capital(2) 37 3/3/92

Your Honours, the next thing we would say is

that there is no reason why the power in

section 122 should be treated as being in some way

limited by the presence of section 90, particularly

when the Constitution itself contemplates in

section 121 that new States may be admitted and

they are likely to have been Territories before

admission.

McHUGH J:  Mr Bennett's argument does not seem very

attractive when you think of Territories placed

under Australia's control, perhaps external

Territories, mandated Territories. If you gave

them some form of self-government, it would mean

that the legislatures of those external Territories

could not impose customs duties. It would all have

to be done from Australia.

MR JACKSON:  Your Honour, if one accepts the proposition

that there may be Territories of various kinds, as

indeed there have been, some external, some

internal, in the case of the Territories,

Territories of both kinds, but let us say

particularly those which either have become States

or are to become States or Territories which, in

the end, become self-governing in their own right,
nations in their own right, then what one would
expect there to be is a kind of development of

stages of government; first of all, perhaps some

kind of government by decree by someone appointed

by the Commonwealth, then some form of

representative government and then some form of

responsible government.

Your Honour the Chief Justice, in Berwick Ltd

v Gray, (1976) 133 CLR 603, at page 607, referred

specifically to the ambit of the power of

section 122 in that regard. The relevant passage

is the last paragraph on page 607, where

Your Honour dealt with the ambit of the power in relation to the various forms of government,

including power: 
to enable Parliament to endow a Territory with
separate political, representative and
administrative institutions, having control of
its own fiscus.

Your Honour had in the previous paragraph referred to the fact that:

There is in the Constitution no counterpart provision to s 81 which requires moneys raised

under a law made by the Parliament pursuant to

s 122 to be paid into a Territory revenue

account rather than into Commonwealth

consolidated revenue.

Capital(2) 38 3/3/92

Then Your Honour's reasons for judgment in the case

were agreed in by the other members of the Court,

with separate reasons for judgment being delivered

by Justice Jacobs at page 611.

Your Honours, could I just say that in

relation to the Territories which existed at the

time of Federation, they are referred to,

Your Honours, at page 376 of Quick and Garran.

Your Honours will see that the Territories were

Norfolk Island, where the inhabitants were governed

by a resident magistrate and an elective council of

12 members, subject to the instructions of the

Governor of New South Wales; Lord Howe Island, administered by New South Wales; Fiji, a governor assisted by an executive and a legislative council, and New Guinea, an administrator assisted by an

executive council. Of course, at the top of the
entry: 

Apart from New Zealand and the northern

Territory of South Australia, new States are

hardly likely to be formed except by the

sub-division of existing States.

So the possibility of there being new States was

contemplated at that time, meaning by that that the

possibility of there being ultimately some

self-governing new States being formed from a

Territory was contemplated.

The ambit of the section 122 power and its

width was also referred to in a short passage in

Northern Land Council v The Commonwealth, (1986)

161 CLR 1 at page 6. At the end of the. first

paragraph on that page, about half-way down, the
Court said:

Such a law is clearly supported by the power to make laws for the government of

territories ..... for that is a plenary power

"unlimited and unqualified in point of subject

matter".

Your Honours, somewhat similar questions have

been considered in the United States in three

decisions, and those decisions do not support the

plaintiffs' position in this case. I wonder if I

might take Your Honours to those very briefly. The

first is the decision of the Supreme Court of that

nation in Binns v United States, (1904) 194 US 486.

One of the issues in that case was the validity of

a law of the Congress of the United States, the law

applying, however, only to the then Territory of

Alaska, and the issue which was raised was whether

the law was valid in the light of the requirement

of Article 1, section 8, that all duties, imposts

Capital(2) 39 3/3/92

and excises shall be uniform throughout the United

States.

Your Honours will see at the bottom of

page 487, in the last paragraph, the constitutional
provisions there set out, and then the opinion of

the court commences at page 490, and the relevant

part is at page 491, about point 4. It is a
passage that commences at the paragraph "We shall

assume" and goes through to the next page, about

point 9 on page 492. Your Honours will see, at

page 491, in the paragraph commencing half-way down

is a about the fifth line, the method provided for
the page, there reference to the various forms
of government of the Territories permitted by the

Alaska is set out. If one goes to point 6 on

page 492:

In the exercise of this power Congress, like

any state legislature unrestricted by

constitutional provisions, may at its

discretion wholly exempt certain classes of

property from taxation, or may tax them at a

lower rate than other property.

Their Honours go on to say:

In view of this decision it would not be open to doubt that, if the act had provided

for a local treasurer to whom these local

taxes should be paid and directed that the

proceeds be used solely in payment of the

necessary expenses of the government of

Alaska, its constitutionality would be clear -

and Their Honours really assume, in that case, that

the act would have been valid, the only then
question being whether requirement for payment to

the United States revenue made it invalid.

Your Honours, the second decision is also of the Supreme Court, and it is Inter-Island Steam

Navigation Co v Territory of Hawaii, (1938) 305 US

306. The relevant part of it appears in the opinion of the court at page 313, and Your Honours

will see the second new paragraph on that page

which Scommences with the word italicized, "Second"

and the issue which arose under that argument was

whether the legislation of the Territory, which was

legislation which it was assumed would conflict

with the negative aspect of the commerce clause,

that is a State could not legislate in those terms,

could the Territory do so, and what Their Honours

said, in the fourth-last line on page 313:

Capital(2) 40 3/3/92

Therefore, assuming - but not deciding - that

petitioner is engaged in interstate and

foreign commerce, Congress has exercised its

power in the present case by permitting the

Territory to act upon this commerce by the

imposition of the contested taxes.

And then, in the next paragraph:

Congress has the power to subject

petitioner to this tax by virtue of its

authority over the Territory, in addition to

its power under the Commerce Clause.

"Congress may not only abrogate laws of the

territorial legislatures, but it may itself

legislate directly for the local government.

And they go on to adopt the passage that:

it has full and complete legislative

authority -

and was not bound by the requirements of the

Commerce Clause and could, in effect, have allowed

the Territory to do so.

The third decision, Your Honours, is one of the United States Court of Appeal's, Sakamoto v

Duty Free Shoppers Ltd, (1985) 764 F 2d 1285.

Your Honours, this is a case in which a petition

for certiorari was denied by the Supreme Court.

That appears in 475 US 1081. Your Honours, the

issue in that case was again whether laws made by

the territory legislature which were laws which, if

made by a State, would have conflicted with the

negative aspects of the commerce clause could be

made by it, and it was held that they could.

Your Honours, the discussion commences on

page 1286, the paragraph numbered (2) in the right

column. It goes through to the end of

paragraph (3) on page 1288 in the left column, and

Their Honours say, for example, at the bottom of

page 1287:

This court has never directly addressed the

applicability of the commerce clause's

negative implications to unincorporated

territories like Guam -

et cetera, and the conclusion at which they arrive

appears in the last six lines at page 1288

immediately above paragraph numbered (4).

Now, Your Honours, in the course of the

discussion there is a discussion without there being a final passing on it of some difference

drawn between territories on the way to Statehood

Capital(2) 41 3/3/92

and those that were not, but Your Honours, whatever

be the applicability of that doctrine if it exists,

it could not apply to the Australian Capital

Territory.

Your Honours, we would submit that it is very

difficult to see any purpose being served by the

suggested limitation on Commonwealth power urged by

our learned friends. We have dealt with that

question in our written submissions and,

Your Honours, we would submit the question should

be answered in the negative.

MASON CJ:  Mr Jackson, having regard to the reliance placed

by Mr Bennett on sections 81, 86, 87, it would seem

desirable to amend the question which I referred to

the Full Court, and if the reference to section 90

were deleted and there were substituted a reference

to Chapter IV, that would seem to cover the

question. In other words, it would commence, "Does

Chapter IV of the Commonwealth Constitution".

MR JACKSON:  Yes. Your Honour, could I just say in relation

to that that no separate argument seems to have

been addressed by our learned friend based on, for

example, section 81, nor upon section 86 in the

sense of saying that the particular Act relied on in some way is a contravention of what is said by

those provisions. Your Honour, what seems to be

said, as we would understand the argument that has

been put, is that if one looks at those provisions

they provide some indication to the effect that the
term "exclusive" in section 90 is not referring

just to exclusive of the powers of the States.

Your Honours, if an argument is being

mounted - and perhaps I have misunderstood what is

being put by my learned friend - that in some way

section 81 or section 86 has that effect, then we

would, I think, like to have the opportunity to put

some submissions in writing in relation to that

because it is a rather larger and different

question.

MASON CJ: Well, I am not sure that your narrow view of the

argument presented by Mr Bennett is correct, so we

can get him at this stage to indicate precisely

what his submission is, and then you can determine

what your attitude is. Yes, Mr Bennett.

MR BENNETT:  Your Honour, the submission is that the one

aspect - it is in addition to the other

submissions, and it is that one aspect of what is

exclusively conferred in section 90 is that the

power to impose a duty of excise is limited to an

excise which will go into consolidated revenue. In

other words, that section 90 is tied, in effect, to

Capital(2) 42 3/3/92

the other provisions of Chapter IV dealing with
consolidated revenue, with the result that the
imposition of an excise by any body which is paid

other than into consolidated revenue and to some

other body is something which is excluded by

section 90 by virtue of the other provisions. That

is the way we put it, Your Honour.

BRENNAN J:  The implication of that is that the power to

impose a duty of excise not of that character does

not reside in the Federal Parliament under

section 122.

MR BENNETT:  The power to impose a duty of excise not of

that character is effectively excluded by section

81 because - it is a combination of section 81 and

section 90. Section 90 says that only the

Commonwealth can impose an excise; section 81 says

that all revenues raised by the Commonwealth go

into consolidated revenue. So an excise which does

not go into consolidated revenue is simply excluded

by the combination of the provisions. If the Court

pleases.

MASON CJ:  So you would seek to have the question referred

amended in the way that I have suggested?

MR BENNETT:  Yes, Your Honour. The alternative would be

that it would be dealt with with the question of

whether this particular imposition is an excise,
which has been reserved for the second part of this

case. It would seem more desirable for it to be

dealt with in this part.

MASON CJ: Yes.

MR BENNETT: If Your Honours please.

TOOHEY J: Could I just be clear, Mr Bennett. Put that way,

then, you are not simply praying in aid sections 81

and 86 in support of the proper construction of

section 90, but you are going a step further than
that?
MR BENNETT:  Yes, Your Honour, although no doubt

incorporating them as aids as well.

MASON CJ:  What attitude do you want to take in respect to
this, Mr Jackson?
MR JACKSON:  Your Honour, it is a matter on which I think we

would like to have the opportunity to put some

further submissions in writing to the Court. I say

that, Your Honour, because the proposition that is

advanced by my learned friend does seem to be

inconsistent with what the Court per Your Honour

Capital(2) 43 3/3/92

said in Berwick v Gray, in the passage to which I

referred.

Your Honour, it may be that all we would seek

to do in that regard is rely on what is said there.

But it does seem, with respect, to be a quite separate and rather large issue which I would not

really like - - -

MASON CJ: 

It is large in the sense of being important, there is no question of that.

MR JACKSON:  Your Honour, it is just a point I would not

really like to seek to deal with on the run, as it

were. So we would seek to have the opportunity
to - - -

MASON CJ: 

You are at liberty to put in submissions in writing on that point but it would be desirable

that you lodge them with the Court as soon as
convenient.
MR JACKSON:  Your Honour, if I were able to have until

Friday to do that, to the end of Friday?

MASON CJ: Yes, there is no difficulty about that.

MR BENNETT:  Might we have seven days to answer that, if

Your Honours please?

MASON CJ: Yes. Yes, Mr Solicitor for the Northern

Territory.

MR PAULING:  Thank you, Your Honours. We do not seek to

add, preferring to go over the submissions we have

already put in writing. We took the liberty of

being rather more expansive than usual in them in

the hope that they would be of some assistance.

There are some quick matters that I may deal with.

delegate, or delegated power, that might operate in argument, sought to draw a line somewhere between a Mr Bennett, in explaining the opening of his respect of a territory and, at the other end, a
territory such as the Northern Territory, or to a
lesser extent the Australian Capital Territory,

suggested that at the commencement of the

with powers of self-government. And it was the framers of the Constitution, that this sort of progressive step forward might occur towards

statehood. And can I refer Your Honours to the
debates of 28 January 1898, the constitutional
debates, at page 257, and I will make copies of the
particular passage available. Mr Deakin is
reported as saying:
Capital(2) 44 3/3/92

One point I wish to put to the leader of the

Convention has partly been anticipated, but

not wholly. This clause - clause 53 - defines
exclusive powers which are given to the

Parliament, and a later clause, clause 115, to

which the leader of the Convention has

alluded, refers also to an exclusive power of

legislation which is to be possessed by the

Federal Parliament for the provisional

government of territories, or, as they have

been happily termed, embryo States. What I am

at a loss to discover is why two clauses

should be needed or placed so far apart.

Should not clause 115, as the power of

legislation there conveyed is an exclusive power, be included in clause 53, where the

exclusive powers are supposed to be found, and

not be relegated to another portion of the

Bill, where it seems to me, those powers are

at all events not equally in place?

MR BARTON. - It was thought advisable to leave

that provision regarding territories where it

is - under the head of "New States" - because

it refers particularly to that kind of

territory which afterwards develops into a new

State.

In Quick & Garran - I will merely give the page

reference if I can - I will take Your Honours

please to page 972, that part of the work that is

dealing with section 122. It is half the way down

the page:

GOVERNMENT OF TERRITORY. - The Parliament is

authorized to make laws for the government of

territory however acquired. Such territory

may be ruled by the Federal Authority, acting
not merely as a local government but as a

quasi-sovereign government. It may rule the

territory as a dependency, providing for its

local municipal government as well as for its

national government, in such a manner as may

seem politic, wise, and just, having regard to

its own interests as well as those of the

people of the territory.

Territories may either be ruled by a

Federal department charged to administer

Federal laws therein, or they may be granted

municipal institutions and territorial

legislatures, empowered to make ordinances not

inconsistent with the laws and Constitution of
the Commonwealth. Should such territorial

ordinances be contrary to Federal law, they

may be annulled by the Federal Parliament.

Capital(2) 3/3/92

And this really is the point that Your Honour

the Chief Justice made in Berwick v Gray, about the

Berwick v Gray about the devolution onto a

Territory of separate territorial administrative

institutions, that is separate political

representative and administrative institutions,

having control of its own fiscus. And might I say

that, on the point that Your Honour Justice McHugh

raised concerning an external territory that became

mandated to Australia and the problems that

Mr Bennett's interpretation would impose there, in

Berwick v Gray, Your Honour the Chief Justice has

referred to two passages from Spratt v Hermes;

those are the passages that convincingly make the

point that within the Constitution there is no

basis to draw a distinction between internal and

external territories.

The question about sections 81 and 86,

Your Honours, really picks up the idea of the

exercise of section 122 to create a territory

legislature with control of its own fiscus, because section 81 talks of money raised or received by the

executive government of the Commonwealth and where,

under section 122 - as it has in both the

Australian Capital Territory and the

Northern Territory - a body politic with plenary

powers is established, when they collect money they

do not do it as the executive government of the

Commonwealth, they do it in their own right as a

plenary government established under section 122.

So that section 81 simply has no application. It

is talking to an exercise by the Commonwealth

itself of actually raising and receiving moneys.

And similarly for other sections involved in

Chapter IV.

The question of a free port that Your Honour

Justice Brennan raised - the free port Darwin - of

course, would be covered by the fact that it would

come into collision with the provisions of the

Customs Act.

BRENNAN J: Quite so.

MR PAULING:  If the Customs Act were repealed then there

would be nothing to stop the Northern Territory

from doing something about it.

BRENNAN J: But you would claim a right to put a tax on

Humpty Doo rice, for example?

MR PAULING:  Yes, Your Honour. And a reason for that, when

looked at in the scheme of things - we have, as I

have pointed out, Mr Deakin talking of embryo

States way back in 1898 - one imagines that there

are problems in the way of a particular

Capital(2) 46 3/3/92

geographical area becoming a State, either because

of its lack of development, lack of population,

lack of the resources that would be necessary if it

were to be constrained as States were - and the

States agreed to being constrained in that way - and that in that developmental phase there should

not be any restriction on the power of the body

politic that is created to raise taxes of any sort

and, indeed, before self-government the

Commonwealth had complete power, because it

exercised it in the Northern Territory at least, to

do just that - and before self-government here.

But there are practical reasons that we allude to

in our submissions that really make that point.

I might just also say that in Cobb & Co Ltd v

Kropp, on which we rely, might I indicate, because

it may have surprised some to see a reference in

our submissions to the Bill of Rights, but could I

give Your Honours the reference to the judgment of
the Full Court of the Supreme Court of Queensland

comprised of Justices Stable, Gibbs and Hart. That

is 1965 QR 285. The appeal to the Privy Council

was dismissed, but in there, and particularly His
Honour Justice Gibbs, it makes particular reference
to the Bill of Rights, or that provision of the
Bill of Rights, that required that taxation could

is implicit in the Privy Council's decision but not explicit. In fact, the Bill of Rights is not

only be levied if it was authorized by parliament.

referred to in their advice.

Could I finish on this matter, that it is

quite right to identify as the important element of

the whole issue raised here the meaning of the word

"exclusive" in section 90. Interestingly enough -

because we are contrasting section 90 and

section 122 and saying that a conferral of a taxing

power, including the power to tax goods, would not

offend against section 90 because it is done

pursuant to section 122 - section 122 itself does

not use the term "exclusive".

Could I refer Your Honours to Frost v

Stevenson, 58 CLR 558, the judgment of His Honour

the Chief Justice. It is not on our list of
authorities, Your Honour. The passage I want to
read at 558 is simply this: 

Sec 122, relating to the government of territories, does not use the word

"exclusive", but the effect of sec 122 is that
the Parliament has exclusive power, by virtue

of the Constitution, to make laws for the

territories to which the section applies.

Capital(2) 47 3/3/92

Your Honours, it is our submission that in looking

at the position of section 90 as it is in
chapter IV, dealing with States, looking at the

deliberate position of section 122 in respect of

new States, that it is quite plain that the

restrictions such as they are in chapter IV are not

meant to apply to Territories at all, although of

course, when, following the provisions of the
Constitution, a Territory such as the Northern

Territory became a State, it then would, as part of that evolutionary process, voluntarily become bound

by those restrictions on its powers.

Until a territory becomes a State, the line

that Mr Bennett seeks to draw is not crossed while

so ever that territory, section 122, as Spratt

v Hermes so clearly points out, is an ample and

full power to do in the territory, or for the

territory, what it will.

DEANE J:  Does chapter IV, on your submission, apply to the

legislative powers of the Parliament under

section 122?

MR PAULING:  No, Your Honour, not at all.

DEANE J: That is contrary to what Chief Justice Dixon said

in LaJnshed v Lake, (1958) 99 CLR 141, but at

page 142 it seems to go a bit your way. At the

bottom of page 141 His Honour says that chapter IV

does apply to section 122.

MR PAULING:  Yes, but at 141, His Honour is saying;

To my mind s.122 is a power given to the

national Parliament of Australia as such to

make laws "for", that is to say "with respect

to", the government of the Territory. The

words "the government of any territory" of

course describe the subject matter of the

power. But once the law is shown to be
relevant to that subject matter it operates as
a binding law of the Commonwealth -

DEANE J: 

At page 141, what I was looking at is where His Honour says:

That necessarily refers to s.1 of the

Constitution and carries with it the provisions of Pts. I, II, III and IV of Chap.

I.

I am sorry, I misread it.

MR PAULING:  Yes, it is, it is qualified as of chapter 1,

Your Honours.

Capital(2) 48 3/3/92

DEANE J: But the next page, I notice, strongly supports

what you are saying.

MR PAULING: There he says:

The legislative power given bys 122 to the

federal Parliament is necessarily not a power

to make laws with respect to a subject matter

defined with reference to a description of

conduct, activity or head of law -

It is dealt with, Your Honour, in paragraph 7 of

our submissions, with respect. I do refer to a
number of articles and the like. Would it be

convenient to the Court if, after the Court rises,

I were to give them to the Court officer?

MASON CJ: Yes, it would.

MR PAULING:  I do not refer to the forthcoming article by
Mr Nicholson as though he were authority. I

incorporated it in my argument because it lists the various sections of the Constitution that have been

touched on in the way we have set out.

Your Honours, those are our - - -

MASON CJ:  Yes. Mr Solicitor, the Court would be advantaged

if we could be provided with copies of the Business

Franchise ("X" Videos) Act of the Territory. We
have some copies but it would be convenient, I
think, if the Court were supplied with seven
separate copies.

MR PAULING: That is the Australian Capital Territory

legislation.

MASON CJ: Yes. I am not directing the remarks specifically

at you but rather at the plaintiffs.

MR PAULING:  Thank you, Your Honour.
MASON CJ:  Thank you, Mr Solicitor. Mr Solicitor for the

Commonwealth.

MR GRIFFITH:  I hand the Court our short contentions.

MASON CJ: Thank you. Yes, Mr Solicitor.

MR GRIFFITH:  May I first raise with the Court the problem

arising from the section 81 and section 86 point

now being relied upon by my learned friend,

Mr Bennett. I suppose it is a problem of

section 78B in the sort of situation that has

arisen in Nationwide and Blank Tapes, but it would
seem that this would be another of these cases

which come on before the Court where, in running,

quite independent arguments of validity are raised.

Capital(2) 49 3/3/92
MASON CJ:  It rather suggests that section 78B ought to be
repealed or amended in some way. It is obviously
causing a great deal of difficulty.

MR GRIFFITH: It is, Your Honour, and of course, one tries

to anticipate it by seeking to see what are the
constitutional points in advance, and summonses for

direction before a Justice of this Court seem to

assist. But, Your Honour, it remains that

section 78B is now a problem if my learned friend

relies upon these sections as an independent ground

for invalidity. His notice was confined to

section 90. I am in a position to deal with the

argument so far as - - -

MASON CJ: But there is no difficulty in notifying the

States, is there?

MR GRIFFITH: No, Your Honour, there is no difficulty. It

is just a question about proceeding. I just point

out that the provisions of the Act are what they

are, Your Honour.

Your Honour, so far as section 81 is

concerned, we would adopt the submissions of my

learned friend, the Solicitor-General for the

Northern Territory, and make the point that

sections 81, 82 and 83 deal with the consolidated

revenue of the Commonwealth and the Executive

Government of the Commonwealth, and we say that

does not bespeak at all of the situation in dealing

with the revenue of a subordinate legislature.

So far as section 86 is concerned,

Your Honours, we say that that is a section forming part of a scheme comprising sections 86 to 94 and,

if you like, section 112 and 113, dealing with the

question of collection of revenues on the
establishment of the Commonwealth, and dealing of
course with the accounting period required for five

years and more in respect of those revenues.

DAWSON J: It is a machinery provision?

MR GRIFFITH: It is a spent provision, we would say,

Your Honour, a machinery spent provision, so that

that is our answer to section 86, if that was

relied upon independently. Picking up Your Honour

the Chief Justice's remarks, possibly no party who

has not appeared here today would want to add

anything to that but -

MASON CJ:  I should have thought it unlikely, Mr Solicitor?

MR GRIFFITH: Yes, Your Honour. Your Honour, is it

appropriate to turn to our contentions now, or is

that an appropriate time?

Capital(2) 50 3/3/92
MASON CJ:  We will adjourn now and we will resume at

2.15 pm.

MR GRIFFITH: If Your Honour pleases.

AT 12.45 PM LUNCHEON ADJOURNMENT

UPON RESUMING AT 2.16 PM:

MASON CJ: Yes, Mr Solicitor.

MR GRIFFITH: If the Court pleases, turning to our

submissions, we submit that the object of

section 90 is to exclude the power of the States to

impose excises, not to limit the exclusive power

vested in the Commonwealth. May I refer the Court

briefly to what Quick & Garran say at page 838 with

reference to section 90. Page 838 it is said:

It means that the power to impose customs and

excise is, subject to the Constitution, wholly
vested in the Federal Parliament as against
the States. It means that the power, being
granted to the Federal Parliament, is - from

the moment of the imposition of uniform

duties - taken once and for all from the

States; and that the States can thenceforth

not legislate for that purpose in any way

whatever, even in the absence of Federal

legislation.

This, we submit, is what was said in the passage of

Justice Isaacs in Nott to which the Court have

already been referred twice or three times at

page 29, but we do make the point that at about

point 9 on page 29, what His Honour Justice Isaacs

made clear was that:

It was not intended to limit the ambit of

Commonwealth parliamentary power but to make

that power exclusive -

of the States -

on the subject matter.

Immediately before that His Honour referred to

"exclusive" as being:

in the -

Capital(2) 51 3/3/92

same -

sense in which that word is found in sections

52 and 107.

And I note that at page 656 in Quick & Garran, the

same proposition with respect to "exclusive" in

section 52 is made by the authors as is made in the

terms just read from page 838.

The power over bounties, of course, is subject

to the limitation in section 5l(iii), that bounties

be uniform throughout the Commonwealth. The

limitations on excise, on the other hand, arise

firstly under section 51(ii), where the prohibition

is on discrimination between the States or parts of
the States, and under section 99, where the

prohibition is on giving preference to one State or any part thereof, or another State or part thereof.

We submit that these limitations say nothing

on the imposition of duties of excise in a

Territory. It follows that there is no textual

limitation in the Constitution, nor, we submit, is

there any basis of textual analysis or principle to

imply a limitation as to excise as expressed by

section 5l(iii) in respect of bounties.

This does seem consistent, we submit, with the

framework of the Constitution in what was intended,

namely, that the Commonwealth be vested with powers

exclusive of the States to determine tariff and and

excise policy. The power of course includes the

power to impose uniform duties of excise, but there
also is a legislative choice available to the

parliament, we submit to provide for excise taxes

in the Territories.

So that, referring to what Your Honour the present Chief Justice said in the Hematite case,

151 CLR 632, we submit that it is apposite to say,

in Your Honour's words: 
that the grant of an exclusive power to impose
duties of customs and excise was intended to
give the Parliament a real control over the
taxation of commodities.

With respect, we would submit that the end referred
to by His Honour Justice Deane at page 661,

referring to means of ensuring uniformity of excise

duties throughout Australia, ..... large accepts that

there is a power in the Federal Parliament to

provide for uniformity of excise duties throughout

Australia. But we submit on the plain text of the

Constitution, that is not a Constitutional mandate.

Capital(2) 52 3/3/92

As has already been pointed out to the Court, ther.e may be particular reasons for special taxes

in the Territories, especially, but perhaps not

only, in the external Territories. What the

Constitution does not do, in our submission, is

prohibit taxes by way of excise being imposed in a

Territory which are not uniform with excises being imposed by laws of the Commonwealth applicable in the States.

There is no reason, we submit, to apply

section 90 as requiring that only the Parliament

itself can directly impose duties of customs and

excise. I will not repeat them but we make two

points, in 1.1 and 1.2 of our contentions handed to

the Court to support textual analysis.

It is our submission that the powers of the

Territory legislature are an emanation of the
exercise of legislature power of the Commonwealth

Parliament. All Territory legislation, including

tax laws, are made by a subordinate legislature

which is a creation of Commonwealth law and, as

such, Territory laws are an expression of plenary

power under the Constitution exercised by the

Parliament.

The Commonwealth itself may exercise its

exclusive excise power by vesting it in a

subordinate legislature which is entirely under its

control.

McHUGH J:  Do you draw any distinction as they appear to in

the American cases between territories evolving on

the way to Statehood and territories which have not

yet reached or perhaps are never intended to reach

that stage?

MR GRIFFITH: 

Your Honour, our submission is that the point of transition is when a territory, evolving as it

may, or perhaps even coming from nowhere, if it
were external from Australia becomes a State of the Commonwealth. At that point, Your Honour, it would
make its transaction and be entitled to the
benefits and the burdens of constitutional
provisions with respect to its existence as a
State. But up to that point, Your Honour, we
submit that there is no basis in the Constitution
for making any distinction in respect of
territories.  The provisions on new States would
seem to be framed with that in mind, Your Honour.

McHUGH J: Perhaps you can help me with this, Mr Solicitor.

Nobody has seemed to approach the matter in this

way: the Constitution is concerned with the powers
of the Commonwealth and the States and with the

demarcation of powers between the Commonwealth and

Capital(2) 53 3/3/92

the State. It has got nothing to say about the

powers of territories, it has only got to say that

it is concerned with what the Commonwealth can do

in respect of territories. In that context, what

could section 90 be referring to, other than the
demarcation of power between the Commonwealth and

the States? Is there some flaw in that way of

looking at it?

MR GRIFFITH:  Your Honour, the whole part in which

section 90 occurs, in our submission, is dealing

with that issue of fiscal relationship between the

Commonwealth and the States and we submit,

Your Honour, that the issue of fiscal operation of a territory is a matter just not adumbrated by the reach of that whole chapter, including section 90. The source of power in respect of the Territory, of

course, is wholly, we would submit, section 122,

unless there is reliance on section 52 which, for

the purpose of our submissions, we do not go to

section 52, Your Honour. We say section 122 is the
source of this legislation.
BRENNAN J:  Mr Solicitor, how does it work if, for example,

the present excise Act places, say, a 15 per cent
duty on silicone chips manufactured as they may be,

for all I know, in the Australian Capital

Territory, and the Territory Government then says,

"We impose an excise of 20 per cent on silicone

chips". Is that a case of inconsistency and, if
so, is the inconsistency dealt with by the

provisions of the relevant legislation which seems

to contemplate that provided you can comply with

both, then that is enough?

MR GRIFFITH:  Your Honour, the question of inconsistency is

perhaps one to be argued out by reference to the

terms of the particular legislation. I understand

my learned friend Mr Pauling's submissions to be

that there was no possibility of the imposition of

a customs duty in the Northern Territory, not

because there is an absence of any reference to

customs duty in the Northern Territory legislation

- there is no reference to it - but merely because

it is quite clear, Your Honour, that it would be

inconsistent with the Commonwealth customs

legislation.

Now, Your Honour, with respect, that in a

particular case would be a matter of construction

of the relevant legislation to see whether there

was an inconsistency. If there were not,

Your Honour, it may be possible to admit the

possibility that one could have a State imposition
in respect of a sale of goods within the State up

to the point of final sale or, possibly,

Your Honour, when one looks at the terms of the

Capital(2) 54 3/3/92

Northern Territory legislation even on sale, once

more depending upon arguments of inconsistency

again with respect to Commonwealth sales tax

legislation and, Your Honour, in that case, we

would submit, that the resolution of any issues
which were to arise from that would be a matter for

the Parliament of the Commonwealth because it

could, by specific legislation, exclude that power

from the Territory.

It could, in the case of the Australian

Capital Territory (Self-Government) Act,

Your Honour, merely add duties of excise to the

list of excepted powers under section 23 of that

Act. It could provide in another way for exclusion

or it could, Your Honour, otherwise exercise the

powers of the Parliament to amend or appeal, and

even of course, Your Honour, the power of

disallowance which is provided for in the existing
Act, section 35, could be exercised.

So there are various mechanisms, but our submission is, Your Honour, that is a matter for

the exercise of the power exclusively vested in the

Parliament of the Commonwealth, to determine

whether or not to permit the continuation of the

situation which Your Honour postulates.

TOOHEY J: When you put it that way, Mr Solicitor, it is not

a constitutional question is it? I mean, is there

a constitutional question of inconsistency, or does

it merely go to the pragmatics of the situation and

the power of the Commonwealth to disallow or to

vary or repeal?

MR GRIFFITH:  In the context of Territory, Your Honour, we

say it is a textual issue, not a constitutional

one, but as we understand Your Honour has put

against us that there are constitutional

inhibitions; in effect, Your Honour, it is put

that the same result applies for excise as we would

power in respect of bounties - they must be uniform say is the case of the exercise of the Commonwealth
throughout the Commonwealth. We submit,
Your Honour, that textually that is not so, and
that the word "exclusive" left hanging in the first
paragraph of section 90, in our submission, for the
reasons advanced by my learned friends and also
submitted by us in our submissions does not compel
a different construction other than that
foreshadowed by Quick and Garran and, we submit,
accepted that by a clear majority of this Court in
Nott.
BRENNAN J:  It cannot be right to say that one of the

purposes of section 90 is to create a uniform

economic regime throughout Australia.

Capital(2) 55 3/3/92
MR GRIFFITH:  Your Honour, that can be right to a point, but

what we submit - and this is the distinction we
make in the language used by His Honour

the Chief Justice with His Honour Justice Deane in the Hematite case between saying the mechanism for

that is to give the Parliament the real control.

But we say, Your Honour, in respect of territories,

it is a matter of control and for Parliament to

determine whether to apply this complete uniformity

which the Constitution does not mandate or whether, for particular reasons as they may seem appropriate

to the Parliament, to provide a separate mechanism

for the territories, always subject to the complete

control of the Parliament. As Justice Isaacs said

earlier on page 29 in Nott - he was referring, of

course, to a particular case where there was

ministerial control - but what he did say was:

Parliament ..... is in no sense abandoning any of its power. It has the fullest control -

he says by legislation, and then he goes on to say: not only by legislation, but also by the

ordinary operation of responsible government. His principal proposition is that Parliament is not

abandoning its power, it has got control by

legislation. We submit, Your Honour, that this is

an issue where the desired result of fiscal

uniformity, if you like, is one secured by

centralization of power, but not by compulsion of

result.

Of course there are arguments one can make why

economically it may be regarded as appropriate for

there to be in respect of excise the same mandated

result as is required for bounties, but we submit

that is not what the Constitution has done. It has
vested complete power in the Parliament of the

Commonwealth, and our second limb of submissions,

of course, is it is that power which has been

exercised here. But the result Your Honour

mentions is attainable, but we say it is for the

Parliament to pursue the extent to which that is

unconditionally attained.

We would make a reference to Powell v Apollo Candle Company Ltd, 10 AC 282, to which the Court

has been taken by my learned friends. At page 289

it is made clear by the Judicial Committee that:

"The Indian Legislature has powers expressly

limited by the Act of the Imperial Parliament

which created it, and it can, of course, do

nothing beyond the limits which circumscribe

these powers.

Capital(2) 56 3/3/92

And then the point is made -

when acting within those limits it is not in

any sense an agent or delegate of the Imperial

Parliament -

and it is with reference to that that at page 291

it is said:

It is argued that the tax in question has been

imposed by the Governor, and not by the
Legislature, who alone had power to impose it.

But the duties levied under the Order in Council are really levied by the authority of the Act under which the order is issued. The Legislature has not parted with its perfect control over the Governor, and has the power, of course, at any moment, of withdrawing or altering the power which they have entrusted

to him.

We would mention for the information of the Court

that the relevant section which was referred to at

page 289 is section 52 of Act 24 and 25 Viet which
provides in terms - and I will pass a copy to the

Court after the Court rises - but in terms of

saying:

Nothing in this Act contained shall be held to

derogate from or interfere with except as
herein before expressly provided the rights

vested in Her Majesty or the powers of the

Secretary of State for India in Council in

relation to the government of Her Majesty's

dominions ih India -

et cetera. So that there is a restriction on the

relevant power of the legislature arising from the

Imperial Statute.

So it is our submission that, in this case, the exercise of powers in the terms of section 22

of the Australian Capital Territory

(Self-Government) Act, although being unqualified

in the terms of the section themselves, are
completely and utterly subject to the exercise of

the legislative power of the Parliament and in that

way we submit that the relevant duty, if it is a

duty of excise in this case, which is the second

question before the Court, is one which is imposed

by the Parliament of Commonwealth and thus does

not conflict with section 90.

GAUDRON J:  Does it discriminate?

MR GRIFFITH: Well, Your Honour, we submit that the only

issue of discrimination which could arise would be

Capital(2) 57 3/3/92

discrimination between the States and, as a

territory tax, we submit that that issue could not

arise. If there was a question of discrimination

amongst the States, Your Honour, that would be a

question of enquiry, but we would say it could not

arise in respect of the excise imposed - - -

GAUDRON J: It is not discrimination against the States, is

it?

MR GRIFFITH: Well, it is amongst the States, Your Honour,

within the terms of section Sl(ii), or parts of a

State, or perhaps I should say between the States.
Section 99, of course, is slightly different in its
terms, using the expression "preference to another

State or any part over another", but it is much the

same in consequence.

As to the suggested alteration of the question

by Your Honour the Chief Justice this morning, we

have no objections to the question being rephrased

to cover the matters covered by my learned friend

although, Your Honour, perhaps, having regard to

section 78B, it might be appropriate for the

plaintiffs to give such notice as has not been

given and reserve the right for any party to

indicate that it would desire at least to make

submissions on the wider issue.

MASON CJ: Well, I think notice should be given by the

plaintiffs under section 78B, although the

variation from the question is not large, but at
least the States ought to be given another

opportunity of evincing any interest in the matter.

MR GRIFFITH:  Your Honour, we would be the last to seek the

Court to reconvene to find if there are going to be

any appearances and we would have thought there

would be no objection to the Court adopting the

practice of, perhaps, submissions wholly in

writing on this issue.

MASON CJ: Yes, that may be possible, but what I do is

indicate that I propose to amend the question in

the manner indicated in the absence of any

contention to the contrary.

MR GRIFFITH: Yes. If the Court pleases.

MASON CJ: Thank you, Mr Solicitor. Mr Bennett.

MR BENNETT: If the Court pleases. If I could deal with my

learned friends in inverse order, starting with my

learned friend, the Solicitor-General for the

Commonwealth. We fully accept what Your Honour has
suggested in relation to section 78B. We will

serve amended notices and what I had in mind was

Capital(2) 58 3/3/92

that we might indicate in those notices that, if

the States wish to make submissions, they should do

so by, say Friday week. We will have the notices

out by the end of this week.

My learned friend referred to Powell v Apollo

Candle Company and, in my respectful submission,

the two passages to which he has referred are

referring to totally different things and cannot be

put together to reach the conclusion that is

reached.

Might I just take Your Honours to those passages, because it is an easy misunderstanding to

make in relation to the case. It is volume 10 of

the Appeal Cases. Your Honours will appreciate the

argument in this case was a delegatus non potest

delegare argument. So there are two separate

matters being discussed: the relationship between

the Imperial Parliament and the Indian legislature,

and the relationship one down the track between the

Indian legislature and the governor on whom some

powers were conferred. At page 289, they are

discussing the first of those. When it says:

"The Indian Legislature has powers expressly

limited by the Act of the Imperial

Parliament -

et cetera, that is talking about the relationship

between the Imperial Parliament and the Indian

Parliament. It is that which does not amount to a delegation.

At page 291, in the first full paragraph on

that page, they are dealing with a totally

different question. They are dealing with the

relationship between the Indian legislature and the

sub-delegate, if one likes, the governor. It is

said there:

Legislature, who alone had power to impose it. been imposed by the Governor, and not by the It is argue.ct that the tax in question has

The legislature which alone had power was the

legislature which, under the Imperial Act, had

powers for the peace, order, and good government

but whose acts were subject to disallowance by the

imperial legislature.

But the duties levied under the Order in the Act -

ie, the Indian Act, not the Imperial Act -

Capital(2) 59 3/3/92
under which the order is issued. The
Legislature -

ie, the Indian legislature

has not parted with its perfect control over

the Governor -

My friend is prepared to submit that that was

referring to the imperial legislature and its

control over the Indian body, and it is not talking

about that stage. So the point my learned friend

makes, we respectfully submit, is invalid.

In relation to section 78B, may I just add

this before I leave it. We would say that the

matter under section 78B is the ability of a self-

governing territory, specifically the Australian

Capital Territory, to impose an excise. The matter

is not really the way one gets to the conclusion

under different sections of the Constitution. But,

as I say, we are happy to amend the notice to make

that clear.

Turning to the submissions of my learned

friend, Mr Pauling, there are only two matters I

want to raise. The first is he referred to

difficulties in relation to external territories.

We would submit there are not any specific

difficulties confined to those territories. They

are more likely to be controlled centrally, as in

fact they are at the moment.

McHUGH J: But supposing Fiji had become one of the

territories of Australia?

MR BENNETT:  Then, Your Honour, while it was a

non-self-governing territory the Commonwealth

could, by its own Act, have created excises in

relation to it. When it became a self-governing

territory and was on the way to statehood, if one

be in the same position that the ACT and the likes, or an embryo State, if one likes, it would
Northern Territory are in now.
McHUGH J:  So it could not impose customs duty?

MR BENNETT: 

It could not then, no, but that could be done by the Commonwealth.

And it may be that the

Commonwealth could authorize the local legislature

as its delegate to do it but, because of the Apollo

case and the other cases, merely conferring

self-government upon it and giving it plenary

powers is not authorizing it to act as its

delegate, it is the reverse.

Capital(2) 60 3/3/92
MCHUGH J: You make a large jump then. Let it be assumed

that it is not a delegate, it can still be said
that it enacts an excise duty under the authority

of the Commonwealth, can it not?

MR BENNETT: 

Your Honour, only in the same way that one would say, after Federation, that the Commonwealth

Parliament passed laws under the authority of the
Imperial Parliament.  We submit that the whole
significance of the Apollo line of cases and,
indeed, to a large extent the importance of the way
self-governing dominions have become independent,
is that that line is regarded as an important one.
Once one grants plenary legislative powers and

creates a polity then, while there may or may not be some residual control remaining, the polity is

independent, its Acts are not one's own Acts any
more.

McHUGH J: But in this particular piece of legislation the

Commonwealth can disallow legislation.

MR BENNETT:  Yes, and that was so in all three of the cases

referred to in the last century, each one of them

had that provision, and yet in each one the court

said that it was not a delegate.

McHUGH J:  Can I just ask you this more general question.

What can section 90 be referring to except the

demarcation of power between the Commonwealth and

the State? The Constitution has not got the

slightest interest in what the powers of the

territories are?

MR BENNETT:  No, Your Honour, what that comes back to is

which theory of constitutional interpretation one

then takes. I suppose a number of ways one can

formulate the question. One can start by saying,

"What do the words mean?", taken in abstract, and

if one does that, in a strictly grammatical sense,

we would succeed because "exclusive" simply means

exclusive of anyone else and I went through that

argument.

McHUGH J:  On the literal meaning but you have got to

divorce it from context, and the context is

powerfully against you.

MR BENNETT:  The context merely shows the historical

situation in which the section was put there, but

the second way one can do it is to say, "Well, what

was the original policy behind section 90 and which

interpretation most promotes that policy?" If one

says that, we submit the policy behind the

provision is to enable fiscal uniformity or

uniformity of control by the Commonwealth. That

Capital(2) 61 3/3/92

would be violated if a self-governing territory

were not limited to impose an excise.

Thirdly, one can ask one of the three

different formulations of the question, as to what

was in the minds of the founding fathers or what

one should impute to be in their.minds. One can

say, "What did they intend in relation to an excise

by a self-governing territory?" The answer to that

is very simple: they did not think of it. So that
does not help. One can say, "What would they have

intended if asked whether the excise power was to

be exclusive of self-governing territories?" We

submit, if they had applied their minds to that

question they would probably have said the power

should be exclusive but, again, one cannot supply a

definite answer. And one can ask the question in the way that most suits my learned friends, which

we say is an invalid way of asking it, which is to

say, "What would they have intended if asked the
more general question: is the excise power intended

to be exclusive of territories?" We say that only asks them half the question without disclosing the

hidden premise, the minor premise, and while it is

the most helpful formulation for my friends, we

would submit it really depends on the assumption

that the founding fathers would not have been
conscious of the possibility of the type of

self-governing territory we now have.

Now, when one is faced with that situation,

one has a case where the words are neutral, where

one has a clear original policy, and where one

really has a conception not really thought through

at the time, the conception of a fully

self-governing territory with power to legislate

for peace, order, and good government.

McHUGH J: But your statement of the policies is somewhat

elliptic, is it not? The policy was to prevent the

States from interfering with uniformity of

taxation.

MR BENNETT:  We would submit, with respect, that is
incorrect. We would submits the policy is to

enable the Commonwealth to legislate uniformly and

no doubt, as part of that, to prevent interference

by such others who could interfere. At the time,

the only others who could interfere were the

States, so it is easy to say, as Quick & Garran

say, and as a number of the cases before

self-governing territories say, that it was

designed to prevent interference by the States.

The clearest expression of that is Parton's case

itself. If Your Honours to to the familiar passage

there, 80 CLR 260 about point 3, this is the

clearest example of what we would submit is the

Capital(2) 62 3/3/92

answer to Your Honour's question. Sir Owen Dixon

there says at about line 10, against the words "and
delivery" in the left-hand margin:

In making the power of the Parliament of the Commonwealth to impose duties of customs and

of excise exclusive it may be assumed that it

was intended to give the Parliament a real

control of the taxation of commodities -

Just stopping there for a moment, that is the positive side of it; that is the purpose. Then, in

order to implement that, one adds the negative

side:

and to ensure that the execution of whatever

policy it adopted should not be hampered or

defeated -

now he adds the words -

by State action -

because at the time that was all that one could

contemplate as defeating it, but those words are

supernumerary to the central interpretation of the

provision. They really say nothing more than it

was desired that the policy should not be hampered

and the only people who could hamper it at the time

were the States.

McHUGH J: They are the only people who can do it now, if

you did not have section 90; the Commonwealth can

control the territories.

MR BENNETT:  It has that power, Your Honour, but it might

not in relation to another territory, I suppose, in

the future, have a power of disallowance. It would

always have the power, under section 122, to repeal

self-government, I suppose, or to amend the
self-government legislation. But that sort of

power was held not to be sufficient to make the

body its delegate and, in my submission, it should

not be sufficient for this purpose. The fact that

the Commonwealth can achieve a result, if it sets

out to do so, by indirect means, is not the answer.

We would submit that section 90 simply means that

the Commonwealth Parliament is to retain direct

control over excises. The only excises which can

be imposed are those imposed by it or by its agents

or delegates, which are in substance controlled by

it. Once it is imposed by someone in relation to

whom the Apollo line is drawn, if I may so describe

it, it ceases to be imposed by it. It is a very

short point, and of course one - - -

Capital(2) 63 3/3/92

BRENNAN J: Yes. Section 90 is dealing with the power of

the Parliament, not the power of the Commonwealth,

is it not?

MR BENNETT: Yes. If I used the word "Commonwealth" then

rather than the Commonwealth Parliament, it was a

slip on my part, Your Honour.

My friend is going to provide, as Your Honours

are aware, a list of the various authorities which

refer to States. I therefore will not go through

them for the reverse purpose any more than my

learned friend is going through them, and if

necessary I will deal with it in the submission,

but every one of them is one which can be answered

in terms of the answer which I just gave to

Justice McHugh.

Really what the courts are saying is that it

is the central control which is important, and when the courts refer to States not hampering, or States

not having the power, it is merely in the context

of "Well, they are the people who could have done

it at the time of Federation". But that word was

not put in section 90, and in my respectful

submission it should not now be implied.

I only want to refer to one of the cases in

reply that my friend referred to, and that is Cobb

& Co, because there is one passage in that which

puts the argument rather clearly, and that is the

passage at page 157. Cobb & Co is in (1967)
1 AC 141 at 157.

This is part of the same point I was making in

relation to Apollo in answer to the learned

Solicitor-General for the Commonwealth. At
page 157, they are talking about the lower stage of

delegation, the second stage, if one likes. After

the quotation at point 3, they say: The legislature were entitled to use any agent or any subordinate agency or any
machinery ..... They were entitled to use the
Commissioner for Transport as their instrument
to fix and recover the licence ..... They were
not abrogating their power to levy taxes and
were not transferring that power to the
commissioner.

Here, they are certainly transferring the power and the Commonwealth Parliament is certainly not using the ACT legislature as its instrument to fix and recover licence fees.

Capital(2) 64 3/3/92

What they created by the passing of the Transport Acts could not reasonably be described as a new legislative power or separate legislative body -

and here it is. So one has a very clear contrast

between what the Privy Council was suggesting might

have been different and the present case.

There are two other short matters. My learned

friend referred to the existence of Territories at

Federation. I may have misunderstood what he
submitted. The fact is there were no Territories

at the time of Federation. Quick and Garran refer

to the anticipation that there might have been four

Territories, which are Fiji, Lord Howe Island, New none then, and one wonders how much it was

seriously anticipated that those four Territories

at that stage would have been likely to have had

self-government.

The other matter is the United States cases.

I would submit that they do not really assist at

all, the provisions of the Constitution are very

different and it is dangerous to rely upon them.

But the important point about the United States cases is that none of them refer to the Apollo point and, indeed, Sakamoto expressly takes the

other position because - that is the case in 764 of

the Federal Reporter, 2d, page 1285, and I do not

think Your Honours need to go to it, but at

page 1287, in the first column, there is reference

to "the Governor of the Canal Zone as Congress's

delegate'," in the middle of the first column. The
whole language which is adopted rather suggests
that what is being discussed is a territorial

legislature which operates as a delegate; that is,

the whole point of our submissions is that is not

the case in relation to the Australian Capital

Territory. May it please the Court.
MASON CJ: Thank you, Mr Bennett. Yes, Mr Jackson?
MR JACKSON:  Copies of the Act were asked for and the

Business Franchise ("X" Videos) Act 1990, may I

give those to the Court.

MASON CJ: Yes, thank you. The Court will consider its

decision in this matter and will now adjourn until

10.15 am tomorrow.

AT 2.53 PM THE MATTER WAS ADJOURNED SINE DIE

Captal(2) 65 3/3/92

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