The jailing of
PAULINE HANSON
A victory for democracy?
Michael Head
Regardless of One Nation Ys
politics: the legal hounding of
Hanson sets a dangerous
precedent.
The conviction and jailing, in August this year, of former MP Pauline
Hanson and one of her One Nation Party co-founders, David Ettridge,
on charges of fraud set a dangerous precedent for use against any
electoral grouping considered a threat to the political establishment.
This author has fundamental differences with One Nation and its
right-wing nationalist politics. But a careful review of the case shows
that after a protracted political and legal campaign, involving senior
members ofthe Howard government, the law was misused to remove an
opposition party from the political scene, violating basic democratic
rights in the process.
As reviewed in the concluding part of this article, the Queensland
Court of Appeal concluded on 6 November 2003 that the convictions
had no legal foundation whatsoever. The court quashed the convictions
and directed that verdicts of acquittal be entered. It took less than a day
of hearings for the three Supreme Court justices to determine that the
charges against the pair flew in the face of long-established legal
principles. I
Hanson and Ettridge were each sentenced to three years jail without
parole under the Criminal Code (Qld) ('the C ~ d e ' )Both
. ~ would have
been barred from standing for parliament, for the duration of their
sentence^.^ Their alleged crime arose from registering Pauline Hanson's
One Nation as a party under Queensland's electoral laws in December
1997. They were found guilty of supplying the names and addresses of
500 party members whom the jury and an earlier civil case found to be
merely supporters. Hanson was also convicted on two further counts
relating to electoral funding paid to One Nation as a result of its
registration.
In handing down the sentences, District Court Chief Judge Patsy
Wolfe admitted that neither Hanson nor Ettridge had obtained any
personal financial benefit from the party's registration or electoral
funding. She specifically referred to the fact that Hanson, with Ettridge's
likely support, had organised a public appeal to repay the half million
dollars in electoral funding paid to One Natiom4 Yet, the two were
convicted, under the vague wording of s 408C(l)(d) of the Code, of
'dishonestly gain[ing] a benefit or advantage'.
Michael Head teaches Law at the University of Western
Sydney.
This article draws in part from reports previously
published by the author and Linda Tenenbaum on the
World Socialist Web Site.
email: [email protected]
O 2003 Michael Head (text)
O 2003 Stuart Roth (cartoon)
264
The only 'advantage' accruing to Hanson and Ettridge was acquiring
the right to have their party's name on the Queensland ballot and to
claim reimbursement for electoral expenses. Forming a political party
and standing for election under its banner are fundamental democratic
rights that should be freely available to all. They have been transformed
into a 'benefit or advantage' because of anti-democratic electoral laws
adopted in the 1980s and early 1990s in order to erect considerable
barriers to ordinary people challenging the major parties.
Moreover, voters have a right to know the political affiliations of the
candidates standing in an election. It is also a traditional democratic
principle that internal party affairs, including a party's organisational
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structure and dispute-settling mechanisms, are matters for
that party's members, free from official interference.
In her brief sentencing remarks, Judge Wolfe pointed to
the political basis of the proceedings. She ruled that lengthy
jail terms were necessary because the pair had undermined
the present political system. Judge Wolfe stated: 'The crimes
you have committed affect the confidence of people in the
~ further suggested that One Nation's
electoral p r o ~ e s s ' .She
registration had possibly affected the outcome of the 1998
Queensland state election, helping to defeat a Coalition
government and replace it with a Labor government holding
office with the help of one independent.But One Nation won
nearly a quarter of the votes in that election because of
popular dissatisfaction with the two major parties, which
Hanson exploited in a populist manner, not because she
deceived voters about her party's structure.
How the case unfolded
The chronology of the case reveals that its course was
determined by definite political calculations, not by
concerns for legality. Every turning point in the proceedings
against Hanson and Ettridge was preceded by fears in the
political and media establishment that One Nation's
electoral successes would destabilise the parliamentary
order.
Hanson, Ettridge and a third figure, David Oldfield,
established Pauline Hanson's One Nation following
Hanson's unexpected election to federal parliament in 1996.
In that year, the Labor government was defeated in a
landslide, a result of the anger and resentment generated by
years of declining living standards for many working people.
Having been disendorsed by the Liberal Party, Hanson won a
previously safe Labor seat by presenting herself as an
anti-establishment candidate, making populist appeals to
anti-Asian and anti-Aboriginal ~entiment.~
Howard's Liberal-National coalition won office by
appealing to ordinary 'battlers' but its industrial relations
legislation and first budget, which slashed education and
social spending, provoked widespread hostility, including a
storming of Parliament House by trade unionists and
supporters. In the aftermath of these events, both Howard and
the media began giving prominence to Hanson's reactionary
views, which served somewhat to divert the backlash against
the government by blaming social deprivation on Aborigines,
welfare recipients and immigrants. Howard defended
Hanson's right to 'speak about certain things without being
branded as a bigot and a r a c i ~ t ' . ~
It was in this context that Hanson, buoyed by her
new-found fame and as a sitting MP, registered Pauline
Hanson's One Nation as a federal party. Registration was a
simple process. At the time, the Commonwealth Electoral
Act 1918 provided for almost automatic registration of
parties that had a parliamentary member, while making it
considerably more difticult for other parties to achieve that
statu~.~
In October 1997, Hanson and Ettridge also applied to
register the party for state elections under the similar
provisions of the Electoral Act 1992 (Qld) ('the Queensland
Act'). They submitted a substantially similar party
constitution as that lodged to register the party federally.
Section 3 of that Act defines 'registrable political party' as
one that either is a parliamentary party or has at least 500
members who are electors. 'Parliamentary party' is defined
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as 'apolitical party of which at least 1 member is a member of
an Australian parliament' (emphasis added). This would
appear to entitle a party represented in any Australian
parliament to be registered. In an apparent contradiction,
however, s 70 of the Act requires parties without
representationin the QueenslandParliament to lodge at least
500 members' names when applying for registration.
Whether Hansen and Ettridge ought to have been able to
rely on s 3 to apply for registration, in any case, they sought
to fulfil the requirements of s 70, lodging 1000 members'
names -twice the requisite number -to register the party.
The Queensland Electoral Commissioner Des O'Shea
verified that a significant proportion of those on the list
believed themselves to be members, requested adjustments
to the party constitution and granted the registration, without
receiving any objections, in early December 1997.9
Following the Queensland state elections in June 1998,
however, the official response to Hanson shifted abruptly. In
the elections, One Nation attracted almost 23% of the vote,
won 11 seats, outpolled the Liberal party and the National
party and helped oust the Borbidge Coalition Government.
If that result were replicated in the federal election due
later that year, One Nation could have potentially controlled
the Senate and taken seats in the House of Representatives,
undermining the two-party system. Almost immediately, the
Howard Government and the media turned against Hanson,
highlighting One Nation's links to ultra-right wing outfits,
its unusual organisational structure and its internal disputes
over election expenses and finances.1°
The Howard government had its own specific concerns:
One Nation threatened to destroy its electoral base, just as it
had ravaged that of the Borbidge Government. One of Prime
Minister Howard's closest protegks, Tony Abbott, then a
cabinet parliamentary secretary,declared his intention to fight
for the deregistration of One Nation, both in Queensland and
federally. One Nation was 'not a validly registered political
party', he told the House of Representatives, but 'a couple of
political and financial brigands trying to hoodwink decent
patriotic Australians'.I1
Unable or unwilling to combat One Nation politically,the
Howard Government adopted a two-track strategy. On the
one hand, it set about implementing One Nation's agenda in
order to win back the constituency that had shifted to
Hanson, notably small business and rural voters traditional Liberal and National party supporters -who had
become disaffected with the government's program. The
government adopted many of Hanson's policies: refugee
rights were reduced, welfare programs subjected to 'mutual
obligation' impositions and Aboriginal funding cut.
On the other hand, Abbott turned to more secretive
manoeuvres, meeting disgruntled ex-One Nation members
to solicit litigation. At one point, he supported a former One
Nation candidate, Gold Coast accountant Teny Sharples, to
spearhead a deregistrationcase, personally guaranteeingthat
Sharples would not be 'out of pocket' . I 2 Abbott worked with
ex-New South Wales Liberal leader, Peter Coleman -who
is also Treasurer Peter Costello's father-in-law - and a
former Labor federal minister, John Wheeldon, to set up a
secretive 'Australians for Honest Politics' fund of at least
$100,000 to finance legal bids to de-register the party.
Liberal Party state president Paul Everingham, National
Party leader Tim Fischer, National Party Senate leader Ron
Boswell and Senator Bill O'Chee were also involved in
265
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encouraging or assisting ex-One Nation members to take
legal action."
The immediate mechanism for the legal campaign was
the Queensland Act. Similar legislation was introduced in
most Australian jurisdictions in the 1980s and 1990s,
providing for public funding of election campaigns and party
registration, to shore up the two-party system. During the
second half of the 1980s, the proportion of votes going to
independents and minor parties rose steadily amid mounting
discontent with both major parties. In 1987, the Hawke
Labor Government clung to office only by obtaining the
second preference votes of minor parties and barely survived
the 1990 election, polling a near-record low of less than 40%
in first preference votes.
The electoral laws have served to augment the flagging
finances of the old parties -Labor and the Liberal-National
Coalition received $32 million for the 200 1 federal election
- while handing the electoral authorities considerable
powers to interfere in the affairs of new parties. Established
parties with sitting MPs are entitled to registration, and
therefore to control funding for election campaigns. But
parties not represented in parliament must submit lists of
names and addresses of hundreds of members, and
invariably are less able to bear the registration fee.
Membership lists submitted for registration become
available for public inspection, potentially opening the
members up to media, government and intelligence prying.
Even if they do not qualify for funding, registered parties are
required to file extensive annual returns, supply other
documents or information demanded by authorities, publicly
name their financial contributors and submit to invasive
inspections.I4
Aided by the media campaign against One Nation and the
rifts, resignations and expulsions wracking the party,
Howard's government narrowly survived the 1998 federal
election, despite polling fewer votes than Labor, while
Hanson lost her seat. One Nation still obtained a million
votes, but only one of its candidates, Heather Hill, won a
Senate seat. As part of the legal campaign, One Nation
opponents challenged Hill's election in the High Court. The
Court stripped Hill of her seat in June 1999 on the technical
ground that she held dual Australian-British citizenship and
did not renounce her British citizenship until after the
election." The High Court held that Hill was a citizen of a
'foreign power' within the meaning of s 44(i) of the
Constitution, although Britain was not a foreign power when
the Constitution was written. Acting as the Court of Disputed
Returns, the High Court subsequently declared another One
Nation candidate, Len Harris, elected to the resulting Senate
vacancy.
The main focus remained the deregistration case mounted
by Sharples, even though he subsequently fell out with
Abbott. Sharples did not commence his application for
judicial review of One Nation's registration until early July
1998, well after the time limit of one month after the
registration had come to his notice.I6 Initially he wrote to
Commissioner O'Shea requesting the cancellation of the
registration. O'Shea replied that after careful consideration
he was satisfied the registration was made in accordance
with the Queensland Act.
Despite the delay, Queensland Supreme Court Justice
Roslyn Atkinson permitted Sharples to proceed with an
application for judicial review of O'Shea's decision to
register One Nation. In August 1999, Atkinson J upheld
266
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Sharples' claim that One Nation's registration had been
'induced by fraud and mi~representation'.'~
There was no
doubt that the 1000 people whose names were lodged by
Hanson and Ettridge regarded themselves as One Nation
members and supported its registration. Atkinson J
conceded that 'the evidence shows that it [the party] had
more than 500 people who believed themselves to be
members'.18 Yet, she concluded that they were not, in fact,
members because 'those who controlled Pauline Hanson's
One Nation Ltd' intended to restrict membership of the party
to only Hanson, Ettridge, Oldfield 'and perhaps other elected
members of Parliament'.19
In effect, Atkinson J overrode the stated intentions of
Hanson's supporters -to register the party -by declaring
that because of its autocratic structure, One Nation
technically had only three members: Hanson, Ettridge and
Oldfield. All other members had purportedly been reduced
to the status of members of another legal entity, the Pauline
Hanson Support Movement Inc, by then renamed the
Pauline Hanson One Nation Members Inc. In law, however,
as was later argued before the Queensland Court of Appeal,
the rank-and-file members may have in fact obtained
contractually enforceable party membership rights despite
the authoritarian constitution devised by Hanson, Ettridge
and Oldfield.20
Under the Queensland Act, making false statements to the
electoral authorities is punishable by a maximum of six
months jail or a fine ofup to 20 penalty units, and improperly
influencing the Electoral Commissioner is punishable by
but the time limit for prosecuting
one years impri~onment,~~
under that Act had passed. Instead of dropping the matter, it
was referred via the state's Crown Law Officer to the police
for investigation under the far more serious fraud provisions
of the Criminal Code, which provides for maximum
sentences of up to ten years imprisonment.
Four months later, in January 2000, highly-publicised
police raids were conducted against One Nation offices in
Ipswich, near Brisbane, and Sydney. Police tipped off the
media in advance, ensuring that pictures of the raids were
splashed all over the tabloid press.22Mounted on the pretext
of investigating the case against the One Nation leaders, the
raids were timed to occur just before a three-member
Supreme Court panel handed down its judgment on an
appeal lodged against Atkinson J's ruling.
In February 2000 the Court of Appeal ruled against One
In the same month, Commissioner O'Shea
Nation's
increased the legal stakes by taking Hanson and Ettridge to
court to make them personally liable to repay nearly
$500,000 in electoral funding that One Nation had received,
even though the money had already been largely spent on
reimbursing election expenses.
The criminal prosecutions
The next turning point came with the February 2001 state
elections in Western Australia and Queensland. After being
written off by the media as a spent force, One Nation again
shocked official circles by winning nearly 10% of the vote,
and close to 20% in rural areas, contributing toward crushing
defeats for the Coalition parties. The party advanced little in
the way of program or policies and barely campaigned. But
its call to place all incumbent candidates last on the ballot
paper resonated with alienated voters.24
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The decision to prosecute Hanson and Ettridge followed
soon after. The Queensland police issued the fraud
summonses in July 200 1, a full 18 months after the Ipswich
and Sydney raids, and just four months before the next
federal election, in which Hanson was standing for the
Senate. In the campaign for the election, Howard stepped up
his implementation of Hanson's agenda, appealing to her
constituency. Supported by Labor, his government
mobilised the armed forces to repel the Tampa and refugee
a policy first advocated by Hanson. The government
also seized on the September 11 terrorist attacks in the
United States to declare the necessity for far-reaching
'anti-terrorism' legislation, which erodes basic democratic
echoing Hanson's calls for tougher 'law and order'
policies.
In this charged political atmosphere, in late November
2001, Queensland Police raided the electorate office of One
Nation's remaining federal Senator, Len Harris, seizing
documents and computer files, supposedly as part of their
investigation into Hanson and Ettridge. A Senate Privileges
Committee report, only released on the day the pair was
jailed, found that the seizures were unlawful because none of
the 74,098 pages c0nfiscated.b~police were related to
election reimbursement expenses.27
In May 2002, two days before a Brisbane magistrate
committed Hanson and Ettridge for trial, the authorities
further blackened their names by charging Hanson with
dishonestly spending $17,000 from the fighting fund set up
to pay back the Queensland Electoral Commission. This
charge was dropped several days after Hanson and Ettridge
were imprisoned, even though the Queensland Director of
Prosecutions, Leanne Clare, insisted there had been a prima
.~~
lawyer,
facie case of fraud against H a n s ~ n Hanson's
Chris Nyst, protested that this further charge served to
publicly paint Hanson as a 'cheat and a liar and a fraud' in the
lead up to her triaLZy
The successful appeal
Hanson and Ettridge immediately appealed against their
convictions. They unsuccessfully applied for bail pending
the outcome of their appeal, with their applications being
refused by Brisbane Supreme Court Justice Richard
Chesterman, the Queensland Court of Appeal and ultimately
High Court Justice Ian Callinan.
In rejecting the bail applications, the Queensland Court of
Appeal nevertheless stated that Hanson and Ettridge
appeared to have a substantial case for overturning their
conviction^.^^ The Court said admissions by Crown
prosecutor Brendan Campbell that One Nation supporters
may have had party membership rights appeared to destroy
the basis for the convictions, as the Crown may have
conceded that One Nation members could have enforced
their limited rights by legal action, and were in law thus
members of One Nation.31
On November 6, the Court of Appeal in quashing the
convictions ultimately confirmed these observations. There
was never any dispute that more than 1000 people - twice
the requirement under the Electoral Act - supported the
registration. The Court of Appeal reviewed, in its judgment,
the process by which they had joined the party.
On the evidence here, each person whose name appears on the
contentious list provided to the Electoral Commissioner filled in
an application form headed 'Pauline Hanson's One Nation',
which is the name of the political party, and sent it, as requested
VOL. 28, NO. 6, DECEMBER. 2003
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on the form, to 'Pauline Hanson's One Nation' at a post office
address at Manly, New South Wales. The membership fee paid
by those applicants was of the order of $40150. The application
was processed at the Manly office ... the applicant was issued
with a receipt in the name of the political party, and a
membership card ...32
Applying 'orthodox contract theory', the judges ruled
that the 'aggregation of these objective circumstances
suggests strongly that the applicant offered to join the
political party, which then communicated its acceptance of
the offer by the provision of the membership card'.33
Thus, the list of signatories became members and
objectively retained rights under the party constitution,
regardless of the subjective intentions of the party's leaders
or their subsequent conduct in seeking to deny those
membership rights. The judges cited several leading cases
By not making
that make this point legally indi~putable.~~
this elementary legal distinction, the trial judge, District
Court Chief Judge Patsy Wolfe, had erred.35
But they went even further. Chief Justice Paul de Jersey
concludedthat the 'preponderance of the available evidence'
indicated that the party's recruits probably became members
of both the party and the Support Movement - the body
which contained branches and gave them voting rights.
Nevertheless, even if they were deemed only to be members
of the support group, that would still mean they were
members of a 'related political party' under ss 3 and 6 of the
Queensland Act, entitling One Nation to be registered under
s 70(4)(e).36Whilst One Nation did not raise this at the civil
case (because it was not the basis on which they applied for
registration), Ettridge raised this precise issue at an early
stage in the criminal trial, yet Judge Wolfe decided not to
refer it to the jury to consider. By itself, this defect also
'warranted the quashing of the c o n ~ i c t i o n s ' . ~ ~
In addition, de Jersey CJ observed that Judge Wolfe had
failed to instruct the jury that Ettridge, who was One
Nation's chief administrator, could not be convicted of
'aiding' Hanson under s 7 of the Code unless it was proved
that he knew her actions had a dishonest purpose.
In summary, on every count, the Court of Appeal
concluded that the convictions had no legal basis whatever.
Nevertheless, de Jersey CJ emphasised that the process
remained lawful.3xHanson and Ettridge are unlikely to
receive compensation for their 78 days - nearly three
months -behind bars.
Despite the ultimate acquittals, the five-year legal and
political offensive against One Nation raises disturbing
questions. Leading figures associated with both major
parties came together, using secret funds, and the police,
prosecuting authorities and the media came to the party to
use the electoral laws to eliminate a political formation that
had become a danger to them. They had no fundamental
differences with Hanson's policies, but spared no effort to
destroy her party.
The Court of Appeal judges were aware that the obvious
question remained - why and how were Hanson and
Ettridgejailed in the first place? 'Members of the public will
undoubtedly, however, query why the crystallisation of the
appellants' current position need have awaited a lengthy trial
- approximately five weeks, and then an appea', de Jersey
CJ ackn~wledged.~~
There was, he noted, 'no easy answer to that question'. He
sought to blame the pair's lack of experienced legal counsel
at their trial, as well as poor preparation and presentation of
267
T H E J A I L I N G OF
the case by the Director of Public Prosecutions (DPP). He
suggested that government under-funding of the DPP's
office had prevented it from hiring 'highly talented lawyers'
who could have avoided 'the vresent difficult^'.^^
McMurdo P seemed to attempt to distance the judiciary
from the political machinations that led to the convictions,
going out of her way to indicate that the court's quashing of
the convictions was not affected by political considerations.
She condemned various government leaders, including
Prime Minister Howard and New South Wales Premier Bob
Carr, for commenting publicly on the severity of the
sentences handed down by the District Court.
The politicians' comments 'could reasonably be seen
as an attempt to influence the judicial appellate process
and to interfere with the independence of the judiciary-for
cynical political motives'. She warned that 'a failure by
legislators to act with similar restraint in the future, whether
out of carelessness or for cynical short-term political gain,
will only undermine confidence in the judiciary and
consequentially the democratic government of this state and
nati~n'.~'
The fact remains, however, that the jailing of Hanson and
Ettridge cannot be explained as an extraordinary series of
breakdowns in the legal understanding of prosecutors, lawyers
and judges.
Regardless of one's opinion of Hanson, Ettridge and
One Nation, the operation against them constitutes a
warning of the ruthless and anti-democratic methods that
may be used in the future against parties which, unlike
Hanson's, advance a genuine and progressive alternative to
the political establishment.
References
P A U L I N E
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
HANSON
Sharpies v O'Shea [I9991 QSC 190 [1301.
Sharples v O'Shea [I9991 QSC 190 [129].
See the discussion of R v Hanson; R v Ettridge, text at nn 32-43.
Electoral ACI 1992 ( ~ l dss
) 153, 157.
L Tenenbaum, 'Police Raids on Ultra-right Party set Dangerous
Precedent', World S o c i a l i s t Web S i t e , 7 February 2000
<http://www.wsws.org/articles/2000/fcb2000/ham.shtml~.
Sharples v O'Shea [2000] QCA 23.
L Tencnbaum, 'Conscrvativc Parties Routed in anothcr Australian
Election', World Socialist Web Site, 23 February 2001 <http://www.
wsws.org/articles/200 l lfeb200l/qld-f23 .shtml>.
M. Head, 'The High Court and the Tampa Refugccs' (2002) I1 GrifJith
Law Review 23.
M . Head, 'Counter-terrorism Laws: a Threat to Political Frcedom,
Civil Libcrties and Constitutional Rights' (2002) 26 Melbourne
University Law Review 666.
Senate Committee of Privileges, Executron of Search Warrants zn
Senators ' Offices
Senator Harris, 114th Report, August 2003,
Parliament of Australia, 2003 ~http://www.aph.gov.au/scnatc/
committee/priv~cttclreport_l14lreport.pdB.
A Wilson and A McGregor, 'Further Hanson Charge is Dropped', The
Australian, 26 August 2003,4.
Ibid.
Hanson v DPP [2003] QCA 409.
Ibid [I81 and [20].
R v Hanson; R v Ettridge [2003] QCA 488, [I 41.
Ibid [l5].
Taylor v Johnson (1982-1983) 151 CLR 422, 429; Codelfa
Construction Pty Ltd v State Rail Authority o f New South Wales
(1981-1982) 149 CLR 337, 352-353; Australian E n e r a Limited v
Lennard Oil NL [I9861 2 Qd R 216,238.
R v Hanson; R v Ettridge [2003] QCA 488, [50].
Ibid [30].
Ibid [34].
Ibid [39].
Ibid [40].
Ibid [40,41].
Ibid [57, 591.
-
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.
I. R v Hanson; R v Ettridge [2003] QCA 488.
2. R v Ettridge and Hanson, District Court of Queensland, Wolfe CJ, 20
August 2003 ~http://www.courts.qId.gov.au/qjudgment/
ettridge%20hanson.pdP.
3. See, eg, Constitution s 44(ii) disqualifying from the Australian
Parliament anyone who is under sentence for an offence punishable by
more than one years imprisonment.
4. Above n 1,6.
5. Ibid.
6. Editorial Board, 'The Pauline Hanson Phenomenon', World Socialist
Web Site, 25 April 1997 <http:/lwww.wsws.orglnewsll997
/apr1997hans-a25.~hhnl>.
7. Ibid. For an inside account of thc media promotion of Hanson, see M
Kingston, OfftheRails, ThePaulineHanson Trip (l999)ix-xix, 3-17,
8. Commonwealth Electoral Act 1918 (Cth) s 123: the favouring of
'parliamentary parties' has been narrowed since to cover onlyfederal
parliamentary parties.
9. Sharples v O'Shea [I9991 QSC 190 [45-761.
10. Kingston, above n 7, xvii-xix, 1-17.
11. Commonwealth,Parliamentary Debates, House of Representativcs,2
July 1998,5971.
12. Australian Broadcasting Corporation, 'More Evidence Upturned on
Tony Abbott's Involvement in Hanson Conviction', PM, 26 August
2003 ~http://www.abc.net.au/pm/content/2003/s932599.htm~.
Sharples was not able to make good that guarantee and was later
bankrupted.
13. P Kelly, 'Tony Abbott's Holey Crusadc', The Australian, 30 August
2003 <http://www.theaustralian.news.com.adcommodstory~agc/
0,5744,710271 2%255E12250,00.html>.
14. Commonwealth Electoral Act 1918 (Cth) Part X X -Election Funding
and Financial Disclosure.
15. Sue v Hill (1999) 163 ALR 648.
16. Electoral Act 1992 (Qld) s 180(2)(c).
17. Sharples v O'Shea [I 9991 QSC 190 [I 321.
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