Procedures under the right to negotiate scheme

Explanatory memorandum

(Please note: Any amendments to the following procedures are highlighted in red and show the date the changes were made.)

  1. The National Native Title Tribunal has reviewed its Procedures under the Right To Negotiate System - last issued on 20 April 2000 - in relation to expedited procedure objection applications.

  2. The right to negotiate provisions in the Native Title Act 1993 (Cwlth) (the Act), and the Procedures developed by the Tribunal, should be considered in their statutory context. The main objects of the Act include:
    1. to provide for the recognition and protection of native title; and
    2. to establish ways in which future dealings affecting native title may proceed and to set standards for those dealings (s 3).

    Those objects, and the substantive provisions of the Act that give effect to them, reflect the policy set out in the Preamble to the Act which states, in part:

    'It is particularly important to ensure that native title holders are now able to enjoy fully their rights and interests. Their rights and interests under the common law of Australia need to be significantly supplemented. In future acts that affect native title should only be able to be validly done if, typically, they can also be done to freehold land and if, when appropriate, every reasonable effort has been made to secure the agreement of the native title holders through a special right to negotiate. It is also important that the broader Australian community be provided with certainty that such acts may be validly done.'

  3. The Tribunal accepts that Parliament intended that proposals to do future acts which are subject to the right to negotiate provisions of the Act (particularly the grant of mining tenements) should be dealt with in a timely manner. This is apparent from:
    • The Statutory Provisions. Section 35(1) of the Act provides that a future act determination application can be made 6 months after the giving of the notice under s 29 of the Act of the Government party's intention to do the future act. Section 36 requires the Tribunal to take all reasonable steps to make a determination as soon as practicable (s 36(1)) and advise the relevant Commonwealth Minister if it does not do so within 6 months of the application (s 36(3)). The Minister may request the Tribunal to make a determination within a specified period (s 36(4)).
    • The Second Reading Speech of the Prime Minister on 16 November 1994 (Hansard pp 2880-2881). The Prime Minister noted that:
      • the right to negotiate was not a veto;
      • the timeframes set for notifications negotiation and arbitration are tight but fair; and
      • the Act imposed clear statutory rules for land use and did not set up complicated barriers to mining exploration and operations.

  4. In Western Australia v Thomas the Tribunal, when explaining the purpose of the right to negotiate provisions of the Act, said:

    'We accept that the legislation was enacted with knowledge of the importance of the Australian mining and resources industry, and that the right to negotiate provisions were intended to deal with the ongoing grant of mining and petroleum titles, which is the largest and most significant aspect of the future dealings covered by the Act.

    In general the Tribunal accepts the importance of achieving certainty for the mining industry, provided this can be done consistently with giving effect to the important rights which are now accorded to native title parties. (1996) 133 FLR 124 at 149.

  5. With respect to the expedited procedure the Tribunal accepts that, in a procedural sense, expedited procedure objection applications are also to be dealt with expeditiously. This is supported by judicial comment in Western Australia v Ward & Ors where Lee J said:

    'The context of the subdivision suggests that a determination whether "the expedited procedure" is attracted is to be made as speedily as possible...' (1996) 70 FCR 265 at 278, 141 ALR 753 at 766.

    This approach was confirmed recently by the Federal Court (RD Nicholson J) in Little v Western Australia [2001] FCA 1706 (at [84]-[85]).

  6. This policy was reflected in the original Procedures which provided for:
    • notice of receipt of the objection application to be given to the Government and grantee parties within 7 days and for a preliminary conference to be convened within 14 days; and
    • the Tribunal to take all reasonable steps to conduct the inquiry and make a determination within 2 months of the preliminary conference.

  7. In 1997 two factors caused the Tribunal (with the general acquiescence of parties appearing before it) to change its procedures to permit a period for negotiations between the grantee party and native title party to see if an agreement could be reached about whether the expedited procedure was attracted. These factors were that:
    • the Western Australian Government changed its approach to consent determinations and was prepared to consent to a determination that the expedited procedure was not attracted where both the native title party and grantee party agreed; and
    • the decision of the Federal Court in Dann v Western Australia (1997) 144 ALR 1, 74 FCR 39 (8 May 1999) meant that it was more difficult to make a determination that the expedited procedure is attracted.

  8. As a consequence of these factors many grantee parties expressed the wish to attempt to negotiate within the context of an expedited procedure application rather than through the normal negotiation procedures under s 31(1) of the Act. Although this had a positive effect in that it resulted in a considerable number of objections being withdrawn, it had the negative consequence of creating a backlog of matters and permitting expedited procedure objection application matters to remain unresolved before the Tribunal for longer than desirable. Given these problems the Tribunal decided that a more flexible approach to dealing with expedited procedure objection applications should be devised.

  9. The Procedures under the Right to Negotiate Scheme - last issued on 20 April 2000 - provided for directions to be made by a Member for an inquiry at the same time as the parties are notified of receipt of the objection application and advised of the time of a preliminary conference. They were designed to restrict the number of preliminary conferences to one in normal circumstances and allow parties sufficient time to negotiate if they wished to. The Directions permitted a 14 week period (from the closing date for objections) for negotiations to occur to explore whether an agreement could be reached on the objection before compliance with directions made for an inquiry was required.

  10. The Tribunal has now decided that further amendments should be made to the Procedures under the Right to Negotiate Scheme to emphasise the importance of negotiations, streamline the inquiry process while maintaining the objective of resolving objections in as timely a manner as possible. The further amendments:
    • continue the practice generally supported by parties of allowing a period of negotiation before compliance with directions for an inquiry is required;
    • extend the time permitted for these negotiations to 16 weeks from the closing date;
    • provide for the Tribunal to accept an objection within 14 days of its receipt (rather than waiting until the end of the objection period) and to notify the parties of it thus extending the period available for negotiations.
    • only require attendance at a Preliminary Conference if the parties do not agree to negotiate and do not undertake to do so actively with a view to reaching agreement before the Status Conference;
    • require attendance at a Status Conference 4 weeks before the Tribunal's directions are to be complied with, to ascertain whether the negotiations have been or are likely to be successful; and
    • emphasise that parties are expected to comply with the Tribunal's directions and that failure to do so may result in dismissal of the objection particularly when non-compliance occurs after the period for negotiation has elapsed.

C J Sumner
Deputy President
8 February 2002

Original issue: 7 June 1995
First revised issue: 8 September 1995
Second revised issue: 20 August 1996
Third revised issue: 11 November 1997
Fourth revised issue: 20 April 2000
Fifth revised issue: 8 February 2002