First published by the Native Title Unit of the Australian Attorney-General’s Department
Submission to Reforms to the Native Title Act 1993: Transparent agreement-making
Submission by:
Michael Swifte
February 2018
Email: mgswifte@yahoo.com.au
Blog: We Suspect Silence
Twitter: http://twitter.com/empathiser
Member: Wrong Kind of Green critical thinking collective
Sections
1. Motivated by understanding Green-Black relations.
2. Auto-didactics and an unstructured methodology.
3. My key themes and areas where I shine a spotlight.
(a) Theme one: Indigenous Land Use Agreements relating to the crucial Adani rail link to the Galilee Basin.
(b) Theme two: Information giving and oversight of negotiation processes.
(c) Theme three: Non PBCs/RNTBCs making ILUAs
List of acronyms
NNTT – National Native Title Tribunal
NTA – Native Title Act
PBC – Prescribed Bodies Corporate
RNTBC – Registered Native Title Bodies Corporate
ORIC – Office of the Registrar of Indigenous Corporations
ILUA – Indigenous Land Use Agreement
NAIF – Northern Australia Infrastructure Facility
KMYAC – Kyburra Munda Yalga Aboriginal Corporation
JEL – Juru Enterprises Limited
NGBR – North Galilee Basin Rail Project
NPIC – Non-Profit Industrial Complex
WKOG – Wrong Kind of Green
CSG – Coal Seam Gas
RTI – Right to Information
1. Motivated by understanding Green-Black relations.
I started out as an anti-CSG (coal seam gas) activist in 2011 working with Generation Alpha and Zombie-A-Frack. I then moved on to be a founding member of the Galilee Blockade group. Around that time I was a shareholder activist against Aurizon as part of the Over Our Dead Bodies campaign. These were the earlier stages of the Queensland based environmental resistance against the development of the Galilee Basin coal complex.
As a member of Galilee Blockade I was focussed on strategy and capacity building for future blockades and direct actions in the Galilee Basin. I fell out with the Galilee Blockade group but maintained an interest in good strategy to inform direct action in the Galilee Basin.
My research into native title issues in the context of large scale coal mining development in the Galilee Basin – which I began tentatively in mid 2015 – was focussed on analysis of the ‘means of export’ and the economic position/agency of Traditional Owners in relation to the development of the Galilee Basin coal complex. At this time I was not conscious of the concept of ‘Aboriginal autonomy’ as articulated by Professor Ciaran O’Faircheallaigh from the School of Government and International Relations, Griffith University. (1)
I have moved from a position of support for stopping the development of the Galilee Basin coal complex ‘at all costs’ to a more nuanced position that takes account of the experience of Traditional Owners and their communities in dealing with the apparatus of the native title system. There is an inherent tension in valuing both Aboriginal autonomy and the prevention of destructive mining developments. It is my belief that in this tension lies the great challenge of decolonisation as it relates to all Indigenous and non-indigenous people. There is no value – in terms of decolonisation – in ignoring particular issues and groups of people when attempting to engage Indigenous and non-indigenous people in support of a particular agenda. Indeed, only thorough and honest assessments of the economic reality of all Traditional Owners as they engage or are excluded from engaging in the negotiation processes afforded to them by the native title system can we properly inform and underpin our fiduciary responsibility to Aboriginal people with regard to the institutions and corporations they are compelled to form and maintain.
Corruption and corporate failure occur in all modern cultural contexts, and as such the expression of these phenomena are a legacy of the post-colonial/colonised era in which our native system operates. Transparent agreement making must be supported by processes and information-giving that allow the general public and more specifically Traditional Owners who have been marginalised from their representative bodies to make assessments about the integrity and effectiveness of the native title system. In the following passages I will make the case that rather than being accountable, accessible and fair, the key institutions that make up the native title system fail to deliver justice through ineffective and poorly defined information-giving, lack of oversight and disclosure regarding negotiation processes, and significant bureaucratic/administrative/institutional failures in attempting to make the native title system navigable.
My involvement with the critical thinking collective Wrong Kind of Green (WKOG) began in 2014 after my first blog post on my blog called We Suspect Silence under my Twitter handle @empathiser. (2) The relationship has deepened since. The non-profit industrial complex (NPIC) critique is at the centre of WKOG’s entirely self funded work. Broadly, the non-profit industrial complex critique contends that through funding relationships with philanthropy, and through networked relationships with a broad range of government, corporate, and non-government institutions, the not-for profit sector effectively captures the efforts of Indigenous and non-indigenous activists for the benefit neo-liberal forces.
2. Auto-didactics and an unstructured methodology.
I subscribe to the understanding of intelligence articulated by anti-war activist Stan Goff in his 2007 essay ‘On Strategy, Tactics & Intelligence’.
“Intelligence is information analyzed for its value to develop plans for action. Most of it, even in the world of government intelligence, doesn’t come from breaking codes or running agents — contrary to the media myths — but from information that is readily available to everyone. Basically, that means if we do intelligence gathering and analysis right, then ours is going to be as good as theirs… maybe better, since we don’t have bureaucratic ambitions and political agendas distorting ours as much.” (3)
My journey has been a learning one. I entered into this area only seeking to get to the truth and as such did not have a predetermined or structured plan. I have had to become an investigative journalist and a pundit to compliment my environmental activism, but it has been my determination to never forget or ignore the economic impacts on all Traditional Owners and their communities that has kept my eyes open. The depth and breadth of economic impacts on Traditional Owner communities and the nature of the negotiating processes that lead to key decision making events have only been revealed to me because I make a special effort of digging around to extract information that Traditional Owners are entitled to know but would otherwise be buried. The decision making events I have investigated – voting meetings, ILUA authorisation meetings, execution meetings – fall under the focus of the ‘Transparent Agreements’ proposals contained in the Reforms to the Native Title Act 1993 Options Paper. I will include information not published by the National Native Title Tribunal (NNTT) but derived from my investigative efforts in the section titled ‘My key themes and areas I spotlight’.
My phone calls to NNTT case workers and other staff helped me get clarification of basic elements of it’s information-giving and information architecture. I was always mindful of the experience of and challenges put before a claim group member who was marginalised from the negotiation process. I routinely asked myself “How much useful information could a blackfella get from calling the NNTT?”.
The process of finding the relevant ILUA documents was haphazard and involved many phone calls to NNTT staff. I encountered issues with information architecture, broken links, and a general lack of guidance for researchers in the online environment. As I outlined in my blog post titled ‘The National Native Title Tribunal: Arbiter or “record keeper”?’ some staff who deal with the public need to seek guidance about which non-privileged information in their possession can be provided to a member of the public. As a record keeper the NNTT is inconsistent.(4) Non-privileged information relating to ILUAs that I was told by one staff member would need to be provided in response to an email request, was freely provided over the phone by other staff members.
3. My key themes and areas where I shine a spotlight.
Rather than attend to the elements of the Native Title Act (NTA) and regulations, I will be presenting particular sets of information gathered since mid 2015, much of which is rarely, if ever, discussed in public forums.
(a) Theme one: Indigenous Land Use Agreements relating to the crucial Adani rail link to the Galilee Basin.
The North Galilee Basin Rail Project (NGBR) is the standard gauge rail project which was the subject of the Northern Australia Infrastructure Facility (NAIF) loan application. This was revealed to me during the inquiry conducted by the Senate Economics References Committee titled ‘Governance and operation of the Northern Australia Infrastructure Facility (NAIF)’. I analysed the revelations presented in this inquiry at length in my blog post titled ‘Confirmation that the North Galilee Basin Rail Project is the Adani rail project being considered by the Northern Australia Infrastructure Facility’.(5)
The NGBR is currently under development by Adani and is the crucial piece of export infrastructure without which the Galilee Basin coal complex could not be developed. As I highlight in my blog post titled ‘Unpacking the Galilee Basin shell game’ the project has been erroneously named the ‘Carmichael Rail Project’ by Adani Australia in the ‘Projects’ section of their website. (6) This is a contradiction of the actual name of the project which appears in the relevant Indigenous Land Use Agreement (ILUA) documents and in the Queensland Department of State Development project listings. One notable environmental organisation echoed this nomenclature in relation to the NAIF in December 2016. Greenpeace Australia Pacific published a document titled “OffTrack: Why NAIF can’t approve the Carmichael Rail Project’. (7)
By capitalising the words “rail” and “project”, both Adani and Greenpeace suggest a formal title for a project which in all official documents has a different name. The actual project name, the ‘North Galilee Basin Rail Project’, can be used as a targeted search term to direct researchers and the general public to documents that would show that negotiations, including voting meetings leading to signed ILUAs, took place between Adani and Traditional Owners in the second half on 2014. The absence of this name from popular discourse could be interpreted as a deliberate tactic to confound and mislead. Questions ought to be asked of Adani Australia and Greenpeace AP about their purpose in using a misleading title in this context.
Three key ILUAs relating to the NGBR have been signed without objection by the Juru, Birriah, and Jannga People’s representative bodies. These ILUAs were never discussed in any form, nor were the Traditional Owner representative groups mentioned by name in the New Matilda five part series titled ‘Killing Country’, which ostensibly focussed on native title issues in the Galilee Basin coal complex (though the Wangan and Jagalingou Traditional Owners Council was placed at the forefront of the story). These unreferenced pieces make no mention of the North Galilee Basin Rail Project. The authors, Kristen Lyons, John Quiggin, and Morgan Brigg were supported by the Global Change Institute at the University of Queensland to write the June 2017 report from which the New Matilda five part series follows on. The report is titled ‘UNFINISHED BUSINESS: ADANI, THE STATE, AND THE INDIGENOUS RIGHTS STRUGGLE OF THE WANGAN AND JAGALINGOU TRADITIONAL OWNERS COUNCIL’. (8)
(b) Theme two: Information giving and oversight of negotiation processes.
All the negotiation meetings in preparation for the registration of an ILUA come down to one or two voting meeting(s). After ascertaining that Adani had two rail projects, one of which was rarely ever named in the media or in government business, I was able to track down and identify – with the help of NNTT staff – the registered ILUAs that made the rarely-named (and sometimes mis-titled) rail project possible.
The below list is taken from my February 2017 blog post titled ‘Why is there so much silence around the North Galilee Basin Rail Project and related Indigenous Land Use Agreements?’. (9)
Indigenous Land Use Agreements applying to the North Galilee Basin Rail Project
QI2014/072 – Kyburra Munda Yalga Aboriginal Corporation RNTBC and Adani Mining North Galilee Basin Rail Project ILUA (10)
QI2014/080 – Birriah People and Adani Mining North Galilee Basin Rail Project ILUA(11)
QI2014/065 – Bulganunna Aboriginal Corporation and Adani Mining Carmichael North Galilee Basin Rail Project ILUA (12)
When I established through a 2014 Right to Information (RTI) disclosure that these ILUAs were significant to the development of the standard gauge rail project that is central to the Galilee Basin coal complex I began to develop a time line and identified key non-commercial-in-confidence data points that would help me ascertain if every effort was made to ensure that each claim group member was able to attend voting meetings on crucial ILUAs. (13) (14) My concern about voting meetings was driven by a single ABC regional article about Juru elder Carol Prior who stated that claim group members who were on Palm Island didn’t know about a crucial voting meeting. (15) She stated that she intended to object to the ILUA. No objection is recorded by the NNTT for any of the three ILUAs that I investigated. (16)
I determined that the dates when voting meetings occurred, the dates when voting meetings were advertised, and the dates when claim group members were notified of their right to object to an ILUA ought to published by the NNTT and be available to any member of the public. With these particular data points I would be able to ascertain if news paper ads had been placed and every effort had been made to notify claim group members.
After my initial requests for various advertising and voting dates was rejected by an NNTT case worker who suggested I write an email request, I decided to try other NNTT staff who were happy to provide me with what dates they were able to find. None were able to find any dates for advertising of authorisation/voting meetings. (17) I later returned to the first case worker with the data I had gathered and was told again that I should send through an email. I created a set of fields which included the data I had gathered and mistakenly did not specify that I was also requesting dates for the advertising of voting meetings. I received a reply to the email which included the dates of the authorisation meetings for each ILUA and an explanation that body corporate agreements – two of the three – did not require a public notification of intention to register an ILUA. (18) Having confirmed the voting meeting dates I was able to discern that for each of the three ILUAs the commencement date was also the date of the second of two voting meetings. My searches based on the execution dates provided by the NNTT case worker provided incomplete and interesting results.
Below are the data fields for voting meetings and advertising of notification periods. All of the information other than the tribunal numbers and registration dates was acquired or clarified through phone conversations and emails with NNTT staff in late 2016 and in 2017. (19) The execution dates for the Birriah and Jannga ILUAs (blue text) was provided via email with the NNTT case worker. (20)
Given the effort it took to gather unpublished dates for voting/authorisation/execution meetings I cannot see how the NNTT can effectively arbitrate a conflict over the delivery of a voting meeting if it does not acquire and retain information regarding the efforts made to ensure all claim group members have an opportunity to attend voting meetings and lodge objections. The lack of published information about meeting advertising dates, notification advertising dates, authorisation meeting dates signifies that the NNTT is neither actively providing oversight in regards to crucial authorisation meetings nor actively capturing and publishing non-commercially sensitive data that is relevant to marginalised Traditional Owners and other researchers.
Juru QI2014/072
Registered: 24/11/14
Votes: 05/08/14 and 16/09/14
Notification: 21/10/14 to 21/11/14
Advertised: Body Corporate Agreement. Not advertised in newspapers. No grounds for objections by claim group members.
Birriah QI2014/080
Registered: 24/04/2015
Votes: Agreement was executed by the parties between 27/09/2014 and 4/11/2014
Notification: 21/01/2015 to 21/04/2015
Advertised (notice of application to register an ILUA): 14/01/15
Jannga/Bulganunna QI2014/065
Registered: 05/01/15
Votes: Agreement was executed by parties on 4/07/2014 and 6/08/2014
Notification: 28/11/14 to 29/12/14
Advertised: Body Corporate Agreement. Not advertised in newspapers. No grounds for objections by claim group members.
Armed with the 6 execution dates for the three NGBR ILUAs I was able to find notices published in the Koori Mail on two dates in 2014. These notices relate to the Juru and Birriah people information sessions and/or authorisation meetings. I was not able to find public notices for the Jannga/Bulganunna authorisation meetings.
Juru
The July 30, 2014 public notice of information sessions in the Koori Mail for the Juru ILUA with Adani relating to the North Galilee Basin Rail Project lists August 5, 2014 as an information session date but not an authorisation meeting. No authorisation meeting dates are specified. No mention is made of any dates scheduled for the September 16 execution meeting.
Here’s is a statement from the July 30, 2014 public notice that clearly reinforces that the dates indicated are specifically for “information sessions”.
“Under the Native Title (Prescribed Bodies Corporate) Regulations 1999 (Cth) Kyburra cannot make a decision to enter into the ILUA unless it has consulted with and obtained the consent of the Juru People to enter into the ILUA. Kyburra must also consult with and consider the views of the native title representative body for the ILUA Project. Kyburra and Adani have organised a number of consultation and consent information sessions (Information Sessions) for the Juru People to attend for this purpose.” (21)
Birriah
There were three public notices of information sessions and authorisation meetings for the Birriah People placed in the Koori Mail on September 10, 2014.
The three public notices relating to Birriah information sessions, a reformulation meeting, and authorisation meetings carried similar headlines texts.
Public notice 1.
PUBLIC NOTICE OF AUTHORISATION MEETING TO CONSIDER PROPOSED INDIGENOUS LAND USE AGREEMENT (AREA AGREEMENT) UNDER THE NATIVE TITLE ACT 1993 (CTH)
Public notice 2
BIRRIAH NATIVE TITLE CLAIM GROUP NATIVE TITLE AUTHORISATION MEETINGS
Public notice 3
BIRRIAH PEOPLE NATIVE TITLE MEETING TO AUTHORISE INDIGENOUS LAND USE AGREEMENTS
Public notice 1 lists the authorisation meeting as September 27, 2014 while public notice 2 and 3 list the authorisation meeting as September 28, 2014.
Public notice 2 lists two meetings, the first of which is a reformulation meeting to change the apical ancestor list. The current and proposed apical ancestor lists are provided in all three notices.
Public notice 3 lists the start time of the authorisation meeting as 8.30am which is the same time listed in public notice 2 as the starting time for the reformulation meeting.
Public notice 2 outlines the order of proceedings as the reformulation meeting followed by the authorisation meeting for those still deemed to have an apical ancestor.
“Meeting 2 – Meeting of the reformulated Birriah Native Title Claim Group If a decision is made to change the description of the Birriah Native Title Claim Group a further meeting of the re-formulated claim group will be held immediately following Meeting 1 for the purpose of authorising an Applicant to deal with all matters arising in relation to the Native Title Claim. Note: If the proposed amendments to the description of the native title claim group are authorised at Meeting 1, then only persons who fall within the re-formulated claim group description may participate in Meeting 2.” (22)
No mention is made in the Birriah public notices of any authorisation meetings scheduled for November 4, 2014.
A public notice announcing that an application to register an area agreement on the Register of Indigenous Land Use Agreements was issued in the Koori Mail on January 14, 2015. Here’s a quote from that notice indicating the a Birriah Traditional Owner could not make an objection to the registration of an ILUA in this particular circumstance unless they made a registered native title determination application during the notification period.
“Responses to an application to register an ILUA—where the application has not been certified: Because this application for registration of the agreement has not been certified by the Representative Aboriginal/Torres Strait Islander Body/ies for the area, there is no opportunity to make a formal objection to its registration. However, if you claim to hold native title in relation to any of the land or waters covered by this agreement, you may wish, within the notice period, to make a native title determination application or equivalent application under a law of a state or territory in respect of any part of the area. The application must be made by 21 April 2015. If that application is registered on the Register of Native Title Claims, the registered native title claimants must be a party to this agreement before it can be registered.” (23)
(c) Theme three: Non PBCs/RNTBCs making ILUAs.
I’ve identified two occasions in the negotiation of ILUAs relating to the development of the Galilee Basin coal complex when Traditional Owners have been represented in ILUA negotiations by groups that are not the claim group, Prescribed Body Corporate (PBC) or the Registered Native Title Body Corporate (RNTBC).
This raises some serious questions about the oversight of the NNTT. While I’m no expert on native title, it seems to me that the claim group ought to be represented by bodies that are subject to regulation by the Office of the Registrar of Indigenous Corporations (ORIC) and were incorporated for the specific purpose of making native title claims and negotiating with parties on behalf of the claim group defined under the native title system.
Juru Enterprises Limited
Juru Enterprises Limited made an ILUA with Adani in January of 2014. The Juru RNTBC, KMYAC were not a party to this ILUA.
The title of the ILUA is ‘Juru People and Adani Abbot Point Terminal ILUA’. NNTT number: QI2013/036 (24)
Juru Enterprises Limited and Kyburra Munda Yalga Aboriginal Corporation are currently in pre-hearing case management in the Federal Circuit Court of Australia.
Case management hearings are being presided over by Justice Steven Rares. (25)
From my research only Geoff Egan, a reporter from Central Queensland is the only person to write about these proceedings in a piece titled ‘Juru missed out on $1m from Adani: court’. (26)
The Queensland Department of State Development Annual Report 2016/17 mentions Juru Enterprises Limited.
“Work is also continuing with the local native title group, through Juru Enterprises Limited, to provide further skills and capacity building while undertaking land management activities within the Abbot Point SDA.” (27)
WJ Corporation
Kate Arnautovic’s honours these provides are very useful background on negotiations between the Wangan and Jagalingou People and Adani. The quote below should interest anyone who is concerned with transparent agreement making during the pre-determination phase.
“In December 2012, Adani attempted to sideline the authority of the applicants and seek authorisation from the Wangan and Jagalingou Traditional Owners Aboriginal Corporation (WJ Corporation). The WJ Corporation is a representative body with a board of Wangan and Jagalingou family representatives (Adani Mining v. Jessie Diver & Others, 2013). While its membership is comprised of many Wangan and Jagalingou claimants, it also represents people who are not claimants. Patrick Malone told the NNTT that the membership of the WJ Corporation included ‘large numbers’ of people who were not descendants of the 12 families that constitute the claim group (Adani Mining v. Jessie Diver & Others, 2013).” (28)
References
(1) O’Faircheallaigh, Ciaran. ‘Mining royalties and Aboriginal autonomy’. Distinguished Lecture presented by the School of Government and International Relations, Griffith University. 9 August 2017 (Broadcast ABC Radio National: September 13, 2017).
(2) Swifte, Michael. ‘Australia’s climate movement has been bought for a pittance.’ Blog: We Suspect Silence, May 13, 2014.
(3) Goff, Stan. ‘On Strategy, Tactics & Intelligence’. Huffington Post: The Blog.
Originally published February 1, 2007. Updated May 25, 2011.https://www.huffingtonpost.com/stan-goff/on-strategy-tactics-intel_b_40222.html
(4) Swifte, Michael. ‘The National Native Title Tribunal: Arbiter or “record keeper”?’ Blog: We Suspect Silence, May 10, 2017.
(5) Swifte, Michael. ‘Confirmation that the North Galilee Basin Rail Project is the Adani rail project being considered by the Northern Australia Infrastructure Facility’. Blog: We Suspect Silence, September 8, 2017.
(6) Swifte, Michael. ‘Unpacking the Galilee Basin shell game’. Blog: We Suspect Silence, December 24, 2017.
https://wesuspectsilence.wordpress.com/2017/12/24/unpacking-the-galilee-basin-shell-game/
(7) Greenpeace Australia Pacific. ‘Off Track: Why NAIF can’t approve the Carmichael Rail Project’. December 2016.
(8) Lyons, Kristen, Brigg, Morgan, and Quiggin, John. ‘UNFINISHED BUSINESS: ADANI, THE STATE, AND THE INDIGENOUS RIGHTS STRUGGLE OF THE WANGAN AND JAGALINGOU TRADITIONAL OWNERS COUNCIL’. 2017.
http://earthjustice.org/sites/default/files/files/Unfinished-Business.pdf
(9) Swifte, Michael. ‘Why is there so much silence around the North Galilee Basin Rail Project and related Indigenous Land Use Agreements?’. Blog: We Suspect Silence, February 17, 2017. https://wesuspectsilence.wordpress.com/2017/02/17/why-is-there-so-much-silence-around-the-north-galilee-basin-rail-project-and-related-indigenous-land-use-agreements/
(10) National Native Title Tribunal: Register of Indigenous Land Use Agreement Details. ‘QI2014/072 – Kyburra Munda Yalga Aboriginal Corporation RNTBC and Adani Mining North Galilee Basin Rail Project ILUA’. November 24, 2014.
(11) National Native Title Tribunal: Register of Indigenous Land Use Agreement Details.
‘QI2014/080 – Birriah People and Adani Mining North Galilee Basin Rail Project ILUA’. April 24, 2015.
(12) National Native Title Tribunal: Register of Indigenous Land Use Agreement Details.
‘QI2014/065 – Bulganunna Aboriginal Corporation and Adani Mining Carmichael North Galilee Basin Rail Project ILUA’. January 5, 2015.
(13) Queensland Treasury: RTI disclosure log – 2016 and earlier. RTI 493. Disclosure made to Jeremy Tager at the North Queensland Conservation Council. Released December 17, 2014.
https://www.treasury.qld.gov.au/about-treasury/right-to-information/previous-disclosure-log-php/
(14) Swifte, Michael. ‘Only a “standard gauge” rail line will deliver the economies of scale to open up the Galilee Basin’. Blog: We Suspect Silence. April 14, 2017.
(15) Roe, Isobel. ‘Native title holders lodge objection to proposed North Galilee Basin rail project’. ABC News. October 20, 2014.
http://www.abc.net.au/news/2014-10-20/native-title-holders-lodge-objection-to-proposed/5826168
(16) Pers, Comm,. NNTT. May 10, 2017.
(17) Pers, Comm,. NNTT. May 10, 2017 and May 23, 2017.
(18) Pers, Comm,. NNTT. October 18, 2017.
(19) Pers, Comm,. NNTT. (multiple occasions in late 2016 and 2017).
(20) Pers, Comm,. NNTT. October 18, 2017.
(21) Koori Mail. Ed 581. July 30, 2014.
(22) Koori Mail. Ed 584. September 10, 2014.https://aiatsis.gov.au/sites/default/files/docs/digitised_collections/the_koori_mail/584.pdf?width=900&height=800&iframe=true
(23) Koori Mail. Ed 592. January 14, 2015.https://aiatsis.gov.au/sites/default/files/docs/digitised_collections/the_koori_mail/592.pdf?width=900&height=800&iframe=true
(24) National Native Title Tribunal. Extract from Register of Indigenous Land Use Agreements. ‘Juru People and Adani Abbot Point Terminal ILUA’. January 20, 2014.http://www.nntt.gov.au/searchRegApps/NativeTitleRegisters/ILUA%20Register/2013/QI2013.036/ILUARegisterExport.pdf
(25) Federal Court of Australia, Queensland Registry. File number: QUD244/2017. JURU ENTERPRISE LIMITED v ADANI AUSTRALIA COMPANY PTY LTD ABN 87 163 221 609 AS TRUSTEE OF ADANI AUSTRALIA HOLDING TRUST& ANOR. Updated February 8, 2018.https://www.comcourts.gov.au/file/Federal/P/QUD244/2017/actions
(26) Egan, Geoff. The Morning Bulletin. ‘Juru missed out on $1m from Adani: court’.June 1, 2017. https://www.themorningbulletin.com.au/news/juru-missed-out-on-1m-from-adani-court/3184689/
(27) Queensland Government. Department of State Development. Annual Report 2016-2017.http://www.parliament.qld.gov.au/documents/tableOffice/TabledPapers/2017/5517T1706.pdf
(28) Arnautovic, K. (2017). Resources, race and rights: A case study of Native Title and the Adani Carmichael coal mine. Retrieved fromhttp://ro.ecu.edu.au/theses_hons/1503
