FEDERAL COURT OF AUSTRALIA
Kemppi v Adani Mining Pty Ltd (No 4) [2018] FCA 1245
File number: QUD 194 of 2017 Judge: REEVES J Date of judgment: 17 August 2018 Catchwords: NATIVE TITLE – where a native title representative body issued a certificate under s 203BE(1)(b) of the Native Title Act 1993 (Cth) (the NTA) certifying an application for registration of an indigenous land use agreement (ILUA) – where that ILUA was subsequently registered by the Native Title Registrar on the Register of ILUAs under Part 8A of the NTA – where the applicant sought to challenge the validity of the certificate and registration – whether the native title representative body acted unreasonably or failed to take into account relevant considerations in deciding to issue the certificate – the principles on legal unreasonableness and relevant considerations – whether the application to register the ILUA contained a “complete description” of the area in which native title rights were to be surrendered and extinguished in accordance with regs 5 and 7(2)(e) of the Native Title (Indigenous Land Use Agreements) Regulations 1999 (Cth) – the primary purpose of the NTA – the relationship between and purposes of ss 24CG, 203BE and 251A of the NTA – the functions of native title representative bodies – the significance of the phrases “persons who hold or may hold native title in relation to land and waters” in ss 24CG(3)(b)(i) and 203BE(5)(a) and “the persons who hold or may hold the common or group rights comprising the native title” in s 251A
PRACTICE AND PROCEDURE – the application of r 20.03 of the Federal Court Rules 2011 (Cth) – when the “implied undertaking” not to use any document disclosed in a proceeding for any purpose otherwise than in relation to that proceeding applies
Held: application dismissed
Legislation: Native Title Act 1993 (Cth)
Federal Court Rules 2011 (Cth)Native Title (Indigenous Land Use Agreements) Regulations 1999 (Cth)
Cases cited: Alcan (NT) Alumina Pty Ltd v Commissioner of Territory Revenue (Northern Territory) (2009) 239 CLR 27; [2009] HCA 41
Bright v Northern Land Council [2018] FCA 752
Buck v Bavone (1976) 135 CLR 110
Burragubba on behalf of the Wangan and Jagalingou People v State of Queensland [2017] FCA 373
Certain Lloyd’s Underwriters v Cross (2012) 248 CLR 378; [2012] HCA 56
Commissioner of Taxation of the Commonwealth of Australia v Consolidated Media Holdings Ltd (2012) 250 CLR 503; [2012] HCA 55
Esposito v Commonwealth (2015) 235 FCR 1; [2015] FCAFC 160
Esso Australia Resources Ltd v Plowman (1994) 183 CLR 10
Fesl v Delegate of the Native Title Registrar (2008) 173 FCR 150; [2008] FCA 1469
Kemp v Native Title Registrar (2006) 153 FCR 38; [2006] FCA 939
Minister for Aboriginal Affairs v Peko-Wallsend Limited (1986) 162 CLR 24
Minister for Immigration and Border Protection v Singh (2014) 231 FCR 437; [2014] FCAFC 1
Minister for Immigration and Border Protection v SZVFW [2018] HCA 30
Minister for Immigration and Citizenship v…
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- Case
- [2018] FCA 1245
- Decision Date
CaseChat Overview and Summary
The court found that Ms Kemppi's challenge did not have merit, as the native title representative body had not acted unreasonably or failed to take into account relevant considerations in issuing the certificate. The court found that the native title representative body had followed the correct process in issuing the certificate and had considered relevant factors in making their decision. Furthermore, the court found that the application to register the ILUA contained a complete description of the area in which native title rights were to be surrendered and extinguished. The court also found that the relationship between and purposes of sections 24CG, 203BE and 251A of the Native Title Act 1993 (Cth) were properly understood by the native title representative body, and that their functions were not misapplied in this case.
The court dismissed the application and ordered that the applicants pay the respondents' costs. This decision highlights the importance of following the correct process and considering relevant factors when issuing a certificate for the registration of an ILUA, and the need for applicants to provide a complete description of the area in which native title rights are to be surrendered and extinguished.
Orders
Orders of the court
1. The applicants’ further amended originating application filed 18 December 2017 is dismissed.
2. The applicants pay the respondents’ costs to be agreed or assessed.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
Background
Background to the litigation
Full text does not contain this section.
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
For these reasons, I do not consider Ms Kemppi’s unreasonableness ground has any merit.THE RELEVANT CONSIDERATIONS GROUND HAS NO MERITThe pleading on the relevant consideration ground Next, I turn to consider the second of Ms Kemppi’s grounds of challenge to the registration of the Adani ILUA, the relevant considerations ground (see at [4] above). In that ground of challenge, Ms Kemppi claimed that Mr Smith had failed to take account of certain relevant considerations when issuing the Certificate. She identified two such considerations. Together with their particulars, those two considerations were set out at 35A of the FASC as follows:35A.When it made the decision to issue the 203BE Certificate, including both elements (a) and (b) of that certificate as pleaded in [34] of this statement of claim, [QSNTS] failed to consider certain relevant considerations being:(a)the laws and customs of the Wangan and Jagalingou People concerning the criteria by which a person is entitled to Wangan and Jagalingou membership;PARTICULARS(i)[QSNTS] was aware that the Native Title Claim Group was “… made up of families whose members identify as Wangan & Jagalingou, in accordance with traditional laws acknowledged and traditional customs observed by them. … Membership of the native title group must be in accordance with traditional laws acknowledged and traditional customs observed by them”;(ii)The reasons given by [QSNTS] for being of the opinion as certified in the 203BE certificate, in section [2](g) and (h), referred to registration of adult members of the Wangan & Jagalingou People and to 340 adult members of the Wangan & Jagalingou People comprising descendants of 12 of the 14 apical ancestors;(iii)The reasons make no reference to whether the persons allowed to register and participate as members of the Wangan & Jagalingou People identified as such in accord with the traditional laws and customs of the Wangan & Jagalingou People nor whether their claimed membership was in accord with those traditional laws and customs and accepted by acknowledged Wangan & Jagalingou People;(iv)The reasons make no reference, and [QSNTS] did not advert, to the absence in the meeting agenda of, and in the resolutions passed at, the 16 April 2016 authorisation meeting of any process by which the meeting could discuss and rule upon the claims of persons to Wangan & Jagalingou identity, particularly, whether persons who claimed to qualify by reference to descent from an apical ancestor, in fact, also had a history of identifying as a Wangan & Jagalingou people, and were in fact accepted by other members of the Wangan & Jagalingou people as members of the group;(v)The reasons make no reference, and [QSNTS] did not advert, to the absence, in the procedures for registration process for the meeting of requests for identification; of any cross-checking of registrants against the database maintained by [QSNTS]; any questions as to whether the person identified as a member of the Wangan & Jagalingou People; any questions as to whether the person was accepted by the acknowledged body of Wangan & Jagalingou People as a member; any process of questioning whether registrants identified as members of other Indigenous Peoples or whether they were members of any other Native Title Claim Group.(c)the extent to which persons who asserted Wangan and Jagalingou identity but were not entitled to that status voted and participated in deliberations as if they were Wangan and Jagalingou persons at the 16 April 2016 authorisation meeting;PARTICULARS(i)The reasons make no reference, and [QSNTS] did not advert, to the circumstance that the 340-people claiming to be Wangan & Jagalingou people who attended the 16 April 2016 authorisation meeting was many more than had attended previously properly advertised meetings of the members of the Wangan & Jagalingou Native Title Claim Group;(ii)The reasons make no reference, and [QSNTS] did not advert, to the circumstance that many of the people who attended the authorisation claiming to be members of the Wangan & Jagalingou People and took part in the meeting purporting to be members of the Wangan & Jagalingou Native Title Claim Group were people whose information had not previously been recorded in the database of details concerning the identification of Wangan & Jagalingou people referred to in sub-paragraph 34C(f) of this statement of claim;(iii)The reasons make no reference, and [QSNTS] did not advert, to the circumstance that many more people attended the 16 April 2016 authorisation meeting claiming to be members of the Wangan & Jagalingou People and took part in the meeting purporting to be members of the Wangan & Jagalingou Native Title Claim Group than had attended previously properly advertised meetings of the members of the Wangan & Jagalingou Native Title Claim Group;(iv)The reasons make no reference, and [QSNTS] did not advert, to the circumstance that a number of people who attended the authorisation [meeting] claiming to be members of the Wangan & Jagalingou People and took part in the meeting purporting to be members of the Wangan & Jagalingou Native Title Claim Group were people known to [QSNTS] as persons who claimed identity as members of other Native Title Claim Groups and as members of Indigenous Peoples whose identification as members of those other groups and peoples were inconsistent with their identification as members of the Wangan & Jagalingou People and as members of the Native Title Claim Group;(v)The reasons make no reference, and [QSNTS] did not advert, to the circumstance that a number of people who attended the authorisation [meeting] claiming to be members of the Wangan & Jagalingou People and took part in the meeting purporting to be members of the Wangan & Jagalingou Native Title Claim Group were people known to [QSNTS] as persons who were not descendants of the apical ancestors of the Wangan & Jagalingou People and who did not identify as Wangan & Jagalingou People.The principles on relevant considerations