Mabo v. Queensland (No 2) [1992]

HCA 23, (1992) 175 CLR 1 · High Court of Australia · Australia

Transnational Lawtransnational-lawTransnational LawNative title; terra nullius; common law recognition of indigenous land rights

Issue

Whether the common law of Australia recognizes a form of native title to land, and whether the doctrine of terra nullius applied.

Held

The common law recognizes native title; the doctrine of terra nullius did not apply to inhabited lands; native title survived annexation subject to extinguishment by inconsistent Crown acts.

Exam use

Summary

Whether the common law of Australia recognizes a form of native title to land, and whether the doctrine of terra nullius applied.

Facts

Issue

Whether the common law of Australia recognizes a form of native title to land, and whether the doctrine of terra nullius applied.

Held

The common law recognizes native title; the doctrine of terra nullius did not apply to inhabited lands; native title survived annexation subject to extinguishment by inconsistent Crown acts.

Ratio Decidendi

The acquisition of sovereignty over inhabited territory does not automatically vest absolute beneficial ownership in the Crown; pre-existing indigenous rights may persist under common law.

Reasoning

Essay-Ready Explanation Generator

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Reference to Mabo v. Queensland (No 2) (HCA 23, (1992) 175 CLR 1) strengthens a Transnational Law answer because the case reflects the principle that The acquisition of sovereignty over inhabited territory does not automatically vest absolute beneficial ownership in the Crown; pre-existing indigenous rights may persist under common law. Applied to a problem question, the case should be used after identifying the issue as Whether the common law of Australia recognizes a form of native title to land, and whether the doctrine of terra nullius applied. The stronger essay move is to connect the material facts to the court's holding, then explain whether the present facts support the same conclusion or justify distinguishing the authority.

Underlying Concepts

  • transnational-law
  • Transnational Law
  • Native title; terra nullius; common law recognition of indigenous land rights
  • case authority
  • exam application

Significance

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