Human Rights and Equal Opportunity Commission
Annual Report 2000-2001
The primary responsibilities of the Legal Section for the 2000-01 financial year were to:
- schedule and facilitate the hearing of outstanding matters under the Commission’s old inquiry function;
- assist the President and/or the Human Rights Commissioner in the preparation of notices and reports under the Human Rights and Equal Opportunity Commission Act 1986 (Cth);
- act as instructing solicitor for the Commission in Commission interventions in legal proceedings;
- act as instructing solicitor for the Commission in applications to appear as amicus curiae in legal proceedings;
- act as counsel or instructing solicitor for the Commission in external litigation such as applications for review of Commission decisions under the Administrative Decisions (Judicial Review) Act 1977 (Cth);
- provide internal legal advice on discrimination, human rights and other laws relevant to the work of the Commission;
- assist the Commission to examine enactments or proposed enactments under the Human Rights and Equal Opportunity Commission Act 1986 (Cth);
- assist the Commission to consider applications for exemptions under the Sex Discrimination Act 1984 (Cth);
- respond to applications under the Freedom of Information Act 1982 (Cth) on behalf of the Commission;
- monitor the development of the anti-discrimination law jurisprudence in the Federal Court and Federal Magistrates Service. Since 13 April 2000 jurisdiction to hear matters terminated by the President lies with the Federal Court and the Federal Magistrates Service;
- prepare submissions to Senate inquiries and committees, especially where the Commission’s core legislation is involved;
- represent the Commission externally in providing information and education on human rights matters; and to
- represent the Commission in international project work.
Hearings and Determinations by the Commission
Public Hearings
As a result of the enactment of the Human Rights Legislation Amendment Act (No. 1) 1999 (Cth) the jurisdiction of the Commission to conduct public inquiries into complaints was transferred on 13 April 2000 to the Federal Court and Federal Magistrates Service. However, the Commission retained the jurisdiction to complete those public inquiries it had commenced prior to 13 April 2000. During 2000–01, 32 of these matters were finalised. Of those:
- 25 were determined at hearing (16 were substantiated and 9 were dismissed);
- 4 settled; and
- 3 were finalised in other ways including complaints terminated by the Commission at the complainant’s own request and complaints adjourned indefinitely by the Commission, for example where a party could not be located.
The following summaries are of two matters that were determined at hearing in 2000-01.
Mingli Wanjurri, Ben Taylor, Robert Bropho, Edna Bropho and Clarrie Issacs v. Southern Cross Broadcasting Ltd and Howard Sattler
Racial Discrimination Act 1975 (Cth)
Commissioner: Graeme Innes
Date of decision: 7 May 2001The complainants lodged a complaint under the Racial Discrimination Act 1975 (Cth) (“RDA”) against Southern Cross Broadcasting Ltd and Howard Sattler. The complainants alleged that comments made during a segment on the Howard Sattler morning radio talk show on 6PR in Perth were in breach of the racial vilification provisions of the RDA. The segment, broadcast on 3 February 1997, was called “Taxi Talk” and involved Mr Sattler seeking the views of the taxi drivers of Perth.
In the segment there was discussion about protests by Aboriginal people in relation to the redevelopment of the old Swan Brewery site – a sacred site for the Nyungah community. Remarks made during the segment included the following:
“…You know for eighty years while it was brewing grog it didn’t worry the Waugyl , as soon as it stopped brewing grog, up pops Waugyl. Waugyl, Waugyl. Shame the first time he popped up the first workman didn’t clean him up with a shovel ……
“remember a few years ago when they were camping there, no it’s a so called sacred site, isn’t it. Yes. They were urinating, they were defecating and they were fornicating….”
“… Now there’s a great little shrub there in the sandhill overlooking the caravan park where I had my first sexual experience. Now that’s a sacred site to me do you reckon I could put a claim in there and get a nice little plot of land …”
The Waugyl is a significant spiritual figure for the Nyungah Community. The Waugyl was involved in the creation of the land and plays a significant role in their culture.
Commissioner Innes found that the discussion degenerated into a denigration of Nyungah people, their religion and culture. He found that the remarks constituted racial vilification in breach of section 18C of the RDA and were not protected by the exemptions contained in section 18D.
Commissioner Innes said, “The actions of Mr Sattler, in allowing these comments to be made, and in supporting them through his participation in the conversation, shows a gross disrespect for the Nyungah people, and an abuse of his position as a radio broadcaster. The role played by Southern Cross Broadcasting (Aus) Ltd, owners of 6PR, in not preventing such a broadcast by better training of staff and through having policies detailing the relevant laws and banning such broadcasts, demonstrates extreme neglect of their responsibilities as a broadcaster”.
Commissioner Innes declared that the respondents should pay each of the complainants $10,000 for the injury done to them.
Katherine Williams v. Colin Robinson & the Commonwealth of Australia
Sex Discrimination Act 1984 (Cth)
Commissioner John Nader
Date of decision: 13 October 2000Katherine Williams lodged a complaint under the Sex Discrimination Act 1984 (Cth) against Colin Robinson and the Commonwealth of Australia (Australian Defence Force). She alleged that she was sexually harassed by Mr Robinson during the time that she was serving in the Royal Australian Air Force (RAAF).
Ms Williams joined the RAAF in 1985. After completing 13 weeks recruitment training she was posted to Wagga Wagga for clerical training, then to Townsville in November 1985. At the inquiry, Ms Williams gave evidence that during her first month at Townsville, when she was nineteen years old, she was assaulted by two men in her single female quarters. Evidence was led that the two assailants were later identified. But only minor disciplinary action was taken against them. Ms Williams was also advised by her superiors that she would never be required to serve at the same base as either of the men again. She received no counselling or any offer of counselling to assist her to recover from this incident.
In relation to the complaints of sexual harassment against Mr Robinson, Ms Williams alleged that the first act of harassment occurred in April 1996. This occurred while Ms Williams worked in a medical centre and her immediate supervisor was Mr Robinson who was then a sergeant with whom she worked daily. Ms Williams gave evidence that she was standing in the orderly room of the medical centre facing the front desk when she saw her then boyfriend enter through the doorway. Ms Williams said to Mr Robinson “There’s my boyfriend”. Mr Robinson allegedly said “Does this mean he’ll get upset if I do this” and then grabbed her with his arms from behind. He wrapped his right leg around her right leg and pressed his body against her. He held her in this way for a couple of seconds before releasing her and laughing.
The second alleged act of sexual harassment occurred in May 1996. Ms Williams went to a patient and while she was bending over, Mr Robinson came from behind her and grabbed her around the waist. He pulled his body into hers and held her there. He said something, which was muffled because she had the stethoscope in her ears, and laughed before releasing her.
Shortly afterwards Ms Williams reported these incidents to a superior officer.
An EEO Officer was appointed to mediate the complaint and as a result of the mediation Mr Robinson provided a written apology to Ms Williams. Later that year Ms Williams was notified that she was to be transferred to another base. However she discovered that one of the perpetrators of the 1985 assault was working on that base and as she felt scared and worried, she decided to leave the RAAF. She was ultimately discharged from the RAAF on 2 January 1997.
Commissioner Nader found that there was no evidence of any formal or independent investigation of Ms Williams’ allegations by the RAAF and that the failure to institute a formal investigation, either within or outside the service, was a major factor contributing to the damage suffered by her.
He came to the conclusion that on all of the evidence, the alleged acts of sexual harassment did occur and that the subject matter of her complaints was clearly one of assault and should have been dealt with as such by the RAAF. He found that from the time of her complaint, Ms Williams’ superior officers should have taken immediate steps to separate her from any real risk of encountering the perpetrator in the course of her duties. The failure on the part of the RAAF created or permitted circumstances to exist that aggravated and compounded the effect on her.
Commissioner Nader found that Ms Williams’ discharge from the RAAF was the end result of a series of events commencing with the 1985 sexual assault. That assault was followed by the apparent failure of the RAAF to properly prosecute the offenders, and the failure of the RAAF to provide any counselling or other support. After the 1996 assaults, the subsequent conduct of superior officers, “by acts in some instances and by omissions in others, forced her to the edge of a breakdown.”
Both respondents were held jointly and severally liable to pay the combined amount of $130,000.
This amount was made up of general damages of $30,000, which included emotional pain, humiliation, embarrassment and other negative emotions suffered by Ms Williams and for her lost opportunity to fulfil her desire to follow a career in the RAAF; and economic loss of $100,000 covering the loss of income.
Complaints relating to breaches of human rights or discrimination in employment made under the Human Rights & Equal Opportunity Commission Act 1986 (Cth)
Complaints made under the Human Rights & Equal Opportunity Commission Act 1986 (Cth) (the HREOCA) relating to breaches of human rights and discrimination in employment were not affected by the Human Rights Legislation Amendment Act (No. 1) 1999 (Cth). The President may report to the Attorney-General where conciliation cannot resolve the matter and an inquiry has satisfied the President there has been a breach of human rights or discrimination in employment. In dealing with these matters, the Legal Section assists the President in the reporting process of the inquiry into these complaints.
Between 1 July 2000 and 30 June 2001, the following reports were tabled in Parliament by the Minister pursuant to this Commission function:
HRC Report No. 10
Report of an inquiry into a complaint of acts or practices inconsistent with or contrary to human rights in an immigration detention centre (May 2000)
This Report details a complaint by a Nigerian national in relation to his treatment during a period of immigration detention in the Perth Immigration Detention Centre (IDC). The treatment of the detainee was found in some respects to be inconsistent with and contrary to human rights.
In particular:
- the placing of the complainant in an observation room without a window and with twenty-four hour fluorescent lighting where he remained for six days;
- the use of handcuffs for eight and a half hours and the use of shackles around the ankles for seven hours while in the observation room; and
- the conditions of detention of the complainant at the Perth IDC over the period of his immigration detention
- were found to constitute a breach of article 10(1) of the International Covenant on Civil and Political Rights.
A number of detailed recommendations were made to prevent a repetition of such treatment.
HRC Report No. 11
Discrimination on the ground of age (August 2000)
This Report details a complaint to the Commission by an employee of the Japan Travel Bureau. The complainant alleged that a reduction in 1994 in the work allocated to her and subsequent decline in income amounted to discrimination on the basis of her age. The complaint was upheld and a recommendation made that the Japan Travel Bureau to;
i. pay to the complainant $43,385 being damages for loss of income; and
ii. that future decisions on the allocation of work to the complainant be made without discrimination on the ground of age.
The Japan Travel Bureau accepted the recommendations in full.
HRC Report No. 12
Report of an inquiry into a complaint of acts or practices inconsistent with or contrary to human rights in an immigration detention centre (November 2000)
This Report involves an inquiry into complaints by two Chinese nationals (Mrs and Mr Quan) in relation to their treatment during a period of immigration detention at the Port Hedland Detention Centre. The President found that their treatment was inconsistent with and contrary to human rights.
In particular, the President found that:
- the failure to inform the complainants of their right to legal advice when taken into immigration detention;
- the handling of the complainants’ requests for access to legal advice and for application forms for protection visas; and
- holding the complainants in separation detention
breached their human right to be treated humanely and in accordance with human dignity while in detention under article 10(1) of the International Covenant on Civil and Political Rights (ICCPR). The President also found that the complainants’ detention was arbitrary within the meaning of article 9 of the ICCPR.
The President recommended that:
i. in compliance with the ICCPR, detainees should be informed promptly and effectively of their right to apply for a protection visa and to access independent legal advice and assistance;
ii. in compliance with the ICCPR, once a detainee has requested legal advice and assistance, that advice and assistance and any necessary interpretive services should be provided in a timely and effective fashion that does not delay the determination of the detainee’s status or prolong the detention;
iii. separation detention should be used sparingly for the shortest possible period of time and in compliance with the Standard Minimum Rules and the Body of Principles. Detainees who are in separate detention should be informed of the reasons for and the likely time-frame of their separation; and
iv. Mr Su be paid the sum of $20,000 and Mr Quan the sum of $15,000 by way of compensation for the damages each suffered as a result of the human rights violations to which he was subjected.
HRC Report No. 13
Report of an inquiry into a complaint of acts and practices inconsistent with or contrary to human rights relating to the continuing imprisonment of immigration detainees in prisons after completion of their criminal sentences (March 2001)
This Report concerns an inquiry into complaints by ten Vietnamese nationals. At the time of the inquiry each of the complainants were permanent residents of Australia. They had all been convicted of criminal offences and had served criminal sentences in New South Wales. The Department of Immigration and Multicultural Affairs had served the complainants with deportation orders. Each of the complainants was held in “immigration detention” at the Parramatta Correctional Complex and was awaiting deportation to Vietnam.
At the time of the inquiry the complainants had been held in immigration detention for periods ranging from 13 months to two years. In each case, the Minister of the Department had declined to exercise his discretion to release the complainants from such detention pursuant to section 253(9) of the Migration Act 1958 (Cth).
The President found that there were acts and practices of the Commonwealth that were inconsistent with and contrary to human rights. The President found that, although the detention of the complainants was lawful, that detention was arbitrary within the meaning of article 9(1) of the International Covenant on Civil and Political Rights. This was because of the indefinite, indeterminate and unpredictable period for which the complainants had been, and at that time it was supposed that they would continue to be held in detention. This finding was based on the fact that, at that time, the Department was not able to advise of the date on which a Memorandum Of Understanding (“MOU”) with Vietnam would be signed (this MOU was to provide the mechanism for the return of the complainants) and, consequently, the date on which the complainants’ detention would end.
The President recommended that the complainants be immediately released from detention pending deportation.
In the Department’s response to this recommendation the Acting Secretary advised that he had directed “relevant officers to conduct a comprehensive review of the circumstances of each complainant in order to evaluate whether continued detention remains appropriate [but] I cannot give you any assurances that this process will necessarily lead to any releases under section 253(9) of the Migration Act 1958”. He also affirmed the Department’s commitment to the earliest possible resolution of the return arrangements with Vietnam.
On 15 June 2001, the MOU was signed with Vietnam.
External litigation
Applications under the Administrative Decisions (Judicial Review) Act 1977 (Cth);
The Commission is often a party in judicial review legal proceedings. These legal proceedings occur when the Commission is named as a respondent in matters where an application has been made to the Federal Court seeking judicial review of a Commission or Commissioner’s decision – these reviews can be sought pursuant to the Administrative Decisions (Judicial Review) Act 1977 (Cth).
In accordance with established legal principle, the Commission as decision maker usually submits to the jurisdiction of the Court in these matters, leaving the substantive parties (that is, the complainant and respondent to the complaint that was before the Commission) to present the matter to the Court. In a very small number of matters, submission to the jurisdiction of the Court is not practicable. In these cases the Commission attempted to assist the Court rather than act in a way that would appear contentious or adversarial. The numbers of applications made under the Administrative Decisions (Judicial Review) Act for the years 1995–2001 are shown in the table on the following page.Table 35: Trends in numbers of Administrative Decisions (Judicial Review) Act applications where the Commission is named as respondent
Year 95–96 96–97 97–98 98–99 99-00 00-01 Total 9 11 35 19 22 13
If you require this information in a more accessible format, please contact paffairs@humanrights.gov.au
Interventions
The Commission has the power to intervene, with leave of the Court, in proceedings that involve issues of race, sex, marital status, pregnancy and disability discrimination, human rights issues and equal opportunity in employment. The power to seek leave to intervene is contained in:
The Racial Discrimination Act 1975 (Cth), s.20(1)(e)
The Sex Discrimination Act 1984 (Cth), s.48(1)(gb)
The Disability Discrimination Act 1992 (Cth), s.67(1)(l)
The Human Rights and Equal Opportunity Commission Act 1986 (Cth) s.11(1)(o) and s.31(j).
The Commission will consider seeking leave to intervene in cases where the human rights or discrimination issues are significant and central to the proceedings, and where these issues are not being addressed by the parties to the proceedings.
The following two summaries are of matters that the Commission was granted leave to intervene in during the 2000-01 period.
State of WA v Ben Ward & Ors on behalf of the Miriuwung and Gajerrong People (No. P59 of 2000)
Attorney-General of the Northern Territory v Ben Ward & Ors on behalf of the Miriuwung and Gajerrong People (No. P62 of 2000) Cecil Ningarmara & Ors v Attorney-General of the Northern Territory & Ors (No. P63 of 2000)
Ben Ward & Ors on behalf of the Miriuwung and Gajerrong People v State of WA & Ors (No. P67 of 2000)
In March 2001 the Commission sought leave before the High Court of Australia to intervene in the above-mentioned matters. These were appeals heard together before the High Court from 6 to 16 March 2001. They involved applications lodged under the Native Title Act 1993 (Cth) by a number of native title claimants in respect of land and waters in the north of Western Australia and adjacent land in the Northern Territory. Whilst there were numerous grounds of appeal, the important issues of the conceptualisation and extinguishment of native title were before the Court. The majority of the Full Court of the Federal Court decided that native title constitutes a “bundle of rights” rather than an underlying right to land, and that it is possible for only some of those rights to be extinguished by the creation of inconsistent rights by laws or executive acts and that where this happens, partial extinguishment occurs. In a particular case a “bundle of rights” that was so extensive as to be in the nature of a proprietary interest, may be so reduced by partial extinguishment that the rights which remain no longer have that character.
The Commission was granted leave to intervene by way of written and oral submissions and was represented by senior and junior counsel before the Court. The Legal Section of the Commission acted as instructing solicitors.
The Commission’s submissions focused on the relationship between principles of international human rights law and the development of the law relating to native title both pursuant to the Native Title Act and under the common law. The Commission submitted that:
- the “bundle of rights” approach to native title should be rejected and the notion of suspension of native title rights accepted because the exposure of native title so readily to extinguishment runs counter to human rights norms in international treaties to which Australia is a party, in particular articles 5(d)(v) and (vii) of the International Convention on the Elimination of All Forms of Racial Discrimination (“CERD”) (relating to the right of everyone without distinction as to race, to equality before the law including the right to own property alone as well as in association with others and the right to freedom of religion) and article 27 of the International Covenant on Civil and Political Rights (ICCPR) (relating to respect for cultural rights);
- where there are choices in statutory language or ambiguity in common law language, and where there is no binding authority to the contrary, then the Court should as a matter of judicial rule, and not as a matter of taste or preference, find the common law and interpret the statute in accordance with Australia’s international obligations;
- where there are clashes between the enjoyment of aspects of native title and the rights of other title holders, the regime set out in the Native Title Act in many cases provides for the suspension and yielding of native title rights rather than native title being destroyed permanently. This can be seen by the Court to promote the resilience rather than the fragility of native title and to permit a culture to exist in the larger system, both legal and otherwise. It was submitted that this is the correct interpretation of Australia’s obligations under article 5(d) of CERD and article 27 of the ICCPR.
The Court has reserved its decision.
Ming Dung Luu v Minister for Immigration and Multicultural Affairs
The Commission also intervened in proceedings in the Federal Court involving a review of a decision of the Minister for Immigration and Multicultural Affairs (the Minister).
That decision related to Mr Ming Dung Luu who was the subject of a deportation order made by the Minister following his conviction on a serious assault charge. Mr Luu was sentenced by the Victorian County Court to a maximum of three years and six months imprisonment in relation to that charge. After being paroled (on 18 June 1997), Mr Luu was placed in immigration detention pending his deportation. The Department of Immigration and Multicultural Affairs determined that Mr Luu should be detained in a maximum security prison rather than in an immigration detention centre.
Mr Luu has been held in a maximum security prison for four years since he was paroled.
Mr Luu sought to have the Minister exercise his discretion under section 253(9) of the Migration Act 1958 (Cth) to release him or, alternatively, revoke the original deportation order. After Mr Luu commenced Court proceedings in the Federal Court, the Minister determined not to exercise his power to release Mr Luu or revoke the deportation order. Mr Luu sought judicial review, under the Administrative Decisions (Judicial Review) Act 1977 (Cth), of that decision (and certain other matters).
The Commission was granted leave to intervene (by consent) by way of written and oral submissions. It was represented by counsel and the Legal Section of the Commission acted as instructing solicitors.
The Commission’s submissions focussed on the following points regarding the Minister’s decision not to exercise his power under section 253(9) of the Migration Act:
- The Commission submitted that the Minister was bound to take into account relevant norms derived from international law in making his decision. The Commission contended that such a requirement flowed from the purposes of the power conferred by section 253(9), which include the prevention of “injustice” to deportees. The Commission argued that international norms play a key part in identifying such injustice. In that regard, the Commission submitted that the Minister should have considered Australia’s obligations under articles 9(1), 10 and 26 of the International Covenant on Civil and Political Rights (the ICCPR) for the purposes of the decision. In particular, the Commission submitted that the Minister was bound to consider article 9(1) of the ICCPR (which proscribes arbitrary detention).
- The Commission contended that the Minister failed to consider Australia’s obligations under those articles of the ICCPR.
- The Commission further contended that that omission was significant by reason of the fact that the circumstances of Mr Luu’s detention involved breaches by Australia of its international obligations under those articles. The Commission submitted that those matters vitiated the validity of the Minister’s decision.
- As a further or alternative argument, the Commission contended that the Minister was under an obligation to inform Mr Luu that he proposed to proceed in a manner that would involve a failure to conform to relevant international norms.
- Finally, the Commission submitted that the Minister’s decision was vitiated by unreasonableness.
At the time of this report, the Court has reserved its decision.
Amicus
The Commissioners of the Human Rights and Equal Opportunity Commission have the function of assisting the Federal Court or Federal Magistrates Service as amicus curiae in discrimination matters. An amicus curiae is a “friend to the court” who assists the court on points of law in a particular case. An Amicus is not a party to the proceedings, does not file pleadings or lead evidence and may not lodge an appeal.
The Commissioners’ amicus curiae function can only be exercised with the leave of the Court where the Court is hearing an application alleging unlawful discrimination under Division 2, Part IIB of the Human Rights and Equal Opportunity Commission Act 1986 (Cth). The Commissioner/s may seek leave to appear as amicus where:
1. the Commissioner thinks the orders sought may affect to a significant extent the human rights of persons who are not parties to the proceedings; or
2. the proceedings, in the opinion of the Commissioner, have significant implications for the administration of the relevant Act/s; or
3. the proceedings involve special circumstances such that the Commissioner is satisfied that it would be in the public interest for the Commissioner to assist the Court as amicus.
The Legal Section assists the Commissioners in the carrying out of this function.
The Sex Discrimination Commissioner sought the leave of the Federal Court to appear as amicus curiae in a case involving indirect sex discrimination. The applicant in this case alleged that a large corporation had a policy prohibiting part-time work. She asserted that this policy disadvantaged women because they were more likely to need to work part-time than men as women still have primary responsibility for caring for children in our society. This matter settled prior to the Court determining the Commissioner’s application to appear as amicus.
International Project Work
As reported in previous annual reports, the Commission has been working on a technical cooperation project with the South African Commission on Gender Equality (CGE). The Legal Section has been working on one aspect of this project which relates to legal intervention. The aim of this part of the project is to improve the capability of the CGE to participate effectively in relevant litigation in South Africa concerning gender related issues. Two staff members of the legal section attended at the offices of the CGE in Johannesburg from 11 to 15 June 2001. They carried out consultations with staff and Commissioners of the CGE and external NGOs and legal agencies, drafted guidelines for assessing appropriate matters for intervention by the CGE, and developed a procedural strategy for conducting interventions. It is proposed that further work in relation to this activity will be carried out in late 2001, including a training workshop for staff and Commissioners of the CGE on the basis of the previous work completed in June.
National Conference
In November 2000 the Commission’s Legal Section in partnership with the NSW Anti-Discrimination Board, hosted the annual National Legal Officers’ Conference. The Conference was held in the Commission’s offices in Sydney and was attended by representatives from each of the state and territory anti discrimination agencies.
The Conference was opened with a panel discussion concerning the issues of privacy and discrimination issues in relation to genetic testing. This panel was chaired by Malcolm Crompton, the federal Privacy Commissioner, and the speakers included Chris Puplick, President of the NSW Anti-Discrimination Board, Dr Kristine Barlow-Stewart, a genetics counsellor and researcher, and David Mason, Director of the Commission’s Disability Discrimination Unit. Other Conference presentations and papers dealt with a number of issues including recent developments in anti-discrimination and human rights law in Australia and overseas and the relationship between industrial relations law and anti-discrimination law.
Other Activities
Over the 2000-01 period, staff members of the Legal Section also undertook a range of external activities. These included the following:
- Presenting a seminar at the Sole Practitioners Group of the NSW Law Society concerning the Sex Discrimination Act with a particular focus on the difference between direct and indirect discrimination, the operation of exemptions and employers’ obligations to avoid sexual harassment in the workplace.
- Providing human rights training to newly appointed Federal Magistrates.
- Speaking at a “Pro Bono and the Law Conference” hosted by the Federal Attorney-General.
- Making a presentation on the Sex Discrimination Commissioner’s Pregnancy Discrimination Report to a seminar jointly run by Australian Lawyers for Human Rights and Young Lawyers (NSW).
- Speaking at the Sydney meeting of Zonta International on women and international law developments in Australia.
- Speaking at a seminar for legal practitioners organised by the University of Western Sydney and the College of Law on equal opportunity and sexual harassment issues.
- Speaking at the University of Sydney Careers Day.
