Reproduced here with permission of Charlie Jay.
First appeared on The Independent.co.uk 24/04/21
Brazil contains an unparalleled level of biodiversity. It hosts more species of mammals, freshwater fish and plants than anywhere else in the world and also has the second highest number of reptile species, the third highest number of bird species, and it holds 60 per cent of the Amazon rainforest. But it is extremely culturally diverse too and is home to 305 indigenous ethnicities, who speak more than 160 languages and have legally recognised rights over more than a fifth of the Amazon.
All this is under imminent threat thanks to Bill 191. Dubbed the “death bill” by Bolsonaro’s critics, the Association of Brazil’s Indigenous Peoples (Apib) says the bill “resumes an ethnocidal and genocidal perspective against indigenous people, contrary to what the federal constitution advocates”, and would effectively authorise the invasion of their lands.
Ninety-eight per cent of Brazil’s indigenous land is within the Amazon rainforest, and therefore its preservation is critical not just for preventing irreversible climate collapse, but also for preventing a cultural catastrophe.
“The regulation of mining on indigenous lands has been the subject of discussions for almost 20 years in the National Congress,” said Rosana Miranda, Brazil campaign advisor at Amazon Watch. “But of all the attempts at regulation, proposed law (PL) 191 is by far the worst. So far it has been developed and discussed without any consultation process with indigenous peoples.
“If approved, it might represent an incalculable loss to the 305 indigenous ethnicities in Brazil, bringing nothing but destruction to these communities. And studies show that the approval of the bill will have a strong impact on deforestation in the Amazon.”
Brazil’s far-right and climate-change-denying president, Jair Bolsonaro, has long been known for his complete disregard of the country’s indigenous population and the environment. He came to office on 1 January 2019, promising to open up more of the Amazon to development such as mining and farming. Since then he has hugely rolled back social and environmental protections, putting ecosystems such as the rainforest and indigenous life at great risk.
Bolsonaro has also managed to weaken the structure of these environmental and indigenous agencies by placing people who know nothing about these areas in positions of power. Experts in all types of governmental positions have been replaced by key military officers who know nothing about the environment. In a similar way, Bolsonaro has a great deal of support from the Evangelical sector in congress, and has put these people in key positions within Funai, the country’s National Indian Foundation. These missionaries even tried entering territory belonging to a large concentration of uncontacted tribes during the height of the pandemic last year, but a court ruling thankfully prevented this.
The rate of deforestation within the Brazilian Amazon has surged since Bolsonaro gained power. In 2019 his government abandoned its plan to combat and prevent deforestation in the Amazon: its deforestation instead reached a 12-year high last year. According to new data released in early April by MAAP, an organisation monitoring the deforestation of the Amazon, 65 per cent of Amazon deforestation occurred in Brazil, with this country losing 1.5 million hectares of forest last year alone, the highest primary forest loss of the nine Amazonian countries. Much of this was due to expanding cattle pasture areas.
The Amazon Fund, set up in 2008, is an effort by Brazil to collect funds to stop deforestation in Brazil. Norway has paid $1.2 billion and Germany $68 million, but both countries have now halted the funding because of the rising deforestation, and the unwillingness of Bolsonaro to act in favour of the environment. Brazil is currently requesting £725 million from western nations for preservation of the Amazon, stating that it has already done enough in terms of its preservation to warrant this financial aid. Only a third of this funding would be spent directly on forest protection, with the rest being spent on “economic development”, providing loggers, miners and farmers with alternative livelihoods.
Bolsonaro’s racist rhetoric is adding to already anti-indigenous feeling and is incentivising all sorts of people – garimpeiros (mineral prospectors), miners, loggers, cattle ranchers and land grabbers – to invade indigenous territories; and his policies have severely weakened indigenous law.
Garimpeiros wreak destruction, not just by clearing forests and polluting ecosystems, but their presence exposes indigenous people to alcohol, drugs, prostitution and sexually transmitted diseases
The constitution also ordered the mapping out of all indigenous territories in Brazil by October 1993. Nearly 18 years later, many indigenous territories are still waiting for formal demarcation, and Bolsonaro has not helped the process.
His government, along with the pro-agribusiness lobby, is backing the Marco Temporal, or “Time Limit Trick”, which states that unless indigenous people were living on their ancestral lands on 5 October 1988, (the day the Brazilian Constitution was adopted), they no longer have any right to them. If successful, this would put hundreds of indigenous territories and dozens of uncontacted tribes in grave danger.
Many areas of the country – including indigenous territories – are known to contain valuable undeveloped mineral deposits, including a range of resources such as gold, copper and iron ore, and Brazil is one of the leading mineral producing countries. Brazil’s small-scale informal mining has increased exponentially since Bolsonaro took office, and the garimpeiros are one of the strongest allies in his administration.
Traditionally, these illegal gold mines were quite small scale, but in the past five to 10 years this type of mining has become much more mechanised, industrialised and organised. It is now major-scale mining and has the backing of powerful political and business interests behind it.
They often carry out their work illegally on indigenous lands, and protected areas, with serious consequences. In Brazil, gold is the second most exported mineral after iron, and a combination of its rocketing price, and the fact that Bolsonaro turns a blind eye to their activities, means the garimpeiros have been left undisturbed to continue their illegal work, even during the pandemic. As a result, mercury, which is a neurotoxin, contaminates rivers, builds up in fish and enters the food chain, with serious heath consequences.
In the Tapajos basin, which is home to the Munduruku population, an estimated 30 tons of gold are illegally commercialised every year, six times more than the legal activity in the region, resulting in these indigenous people ingesting up to 18 times more mercury than the safe limit. The garimpeiros wreak destruction, not just from clearing forests and polluting ecosystems, but their presence exposes indigenous people to alcohol, drugs, prostitution and sexually transmitted diseases – as well as Covid – in the territories in which they operate.
Bolsonaro, whose father was a garimpeiro, has done nothing to stop this illegal invasion of indigenous lands. Loggers, ranchers and miners all know they have the government’s blessing to do as they please and, with the focus on Covid, they know they will not be stopped.
“All in all, Bolsonaro’s government has been an utter disaster,” said Fiona Watson, advocacy director for Survival International, “and he’s causing terrible suffering to the indigenous people.
“I’m extremely worried. There are big constitutional battles on the horizon, because if the Supreme Court rules in favour of the Time Limit Trick, people behind Bill 191 will then claim there is lots of land that isn’t indigenous territory. This means Bill 191 will be much more likely to be passed.”
Watson went on to say that the government is at fault for not demarcating indigenous territory in the time frame given, and that this will be seized upon by the mining industry and others to open up indigenous territories for extraction processes, and lead to a massive land grab.
“That’s one of my big fears of this bill,” she said. “This proposed legislation doesn’t give indigenous people any right of veto, which is unconstitutional. If the bill goes through, it will send out a message that it’s a free-for-all. How will this be controlled?”
By dismantling the constitutional protections for indigenous people and protected areas, Bill 191 may well open the floodgates, not just for the garimpeiros but also for the big extractive corporations to come in. As technology has improved, these industries are capable of causing increasing damage to our planet and all the life it supports.
Mining and its associated infrastructure is disastrous, environmentally and socially, causing major deforestation and pollution, and opens up remote indigenous territories to outsiders. Large-scale open-cast mining uses heavy machinery to blast and dig holes in the ground and results in huge amounts of toxic waste, which is stored in tailings dams. The problem of mining waste has grown exponentially as mines have increased in size.
Brazil has had its fair share of mining disasters. In the Mariana dam disaster of 2015, and the country’s worst mining disaster at Brumadinho in 2019, the earth-filled tailings dams – which are supposed to store byproducts of mining – failed, resulting in mud-flow containing toxic waste, travelling vast distances, devastating villages and water sources, heavily polluting land, and leaving many homeless or dead. However, these are not isolated incidents, and there are many who worry that it is only a matter of time before such disasters occur again if the bill goes ahead.
Bolsonaro favours mining and knows that these multinationals will pay huge amounts in taxes, but that tax income just doesn’t reach the people in the street
Andrew Hickman, part of London Mining Network’s Brazil working group, is all too aware of the destruction large-scale mining companies can cause. He visited Brumadinho, a mining town controlled and dominated by the Brazilian mining giant Vale, in 2019, seven months after the tailings dam failed.
“What I experienced was grief like I had never experienced before, anywhere. What I saw was a town that felt completely decimated and in extreme trauma. Brumadinho is a town with a population of around 30,000 people, but the disaster killed 300, meaning everyone in the town was affected somehow,” he said. Since then, many more tailings dams across Brazil have been found to be at risk of collapse.
“These companies have operations around the world and make billions each year. They’re as powerful as small countries and their impact is huge. London Mining Network exists because the comeback to mining company actions are so inadequate, and communities often feel completely powerless against them.
“Bolsonaro favours mining, and knows that these multinationals will pay huge amounts in taxes but, certainly in my experience, that tax income just doesn’t reach the people in the street, particularly all those communities whose lives have been ripped up by living in the shadow of these mines.”
Like Watson, Hickman talks of the repression, intimidation, conflict and surveillance, that people in these mining areas face every day. “The mining companies create havoc, not just to the environment and livelihoods of these people, but socially as well. The normal structures by which a rural society organises itself are ripped apart and conflict becomes commonplace,” he said.
“Mining companies stay within the law because they have to, but if someone like Bolsonaro makes it legal for extractive industries to operate on protected and indigenous lands, then most would take full advantage of this fact and mine on them.”
Despite the existing mining ban, large national and international mining companies have, since the 1990s, filed hundreds of requests with the National Mining Agency for “analysis” of deposits on indigenous land.
According to research by Amazon Watch and Apib, official mining exploration requests in Indigenous Amazonian territory has risen by 91 per cent since the beginning of the Bolsonaro administration. Last year, an investigation by the InfoAmazonia project discovered Brazil’s National Mining Agency (ANM) to be actively entertaining more than 3,000 of these requests. The research uncovered dozens of applications being filed with ANM every year, with the agency not rejecting them immediately as it is obliged to do, but keeping them on file.
Anglo American is one of the multinationals singled out because of the extent of its activities in indigenous lands in the Amazon
In Amazon Watch and Apib’s Complicity in Destruction report, Anglo American is one of the multinationals singled out because of the extent of its activities’ current or potential impact in indigenous lands in the Amazon, and its ties with the international finance sector, which continues to enable this behaviour, and ultimately the destruction of the forest.
Anglo American is one of the biggest multi-national mining companies in the world and, similar to the mining corporation that was involved with the Mariana dam collapse, BHP Billiton, is British listed. Projects include its Minas Rio operation in Brazil, which had to temporarily suspend operations in 2018 due to a leak in its 500km slurry pipeline, the largest in the world.
“Our report identified more than 300 Anglo American research applications that focused on indigenous lands – by far the most requests belonging to one company in the system,” said Miranda. “In our opinion, it clearly indicated Anglo’s intentions to build a market reserve, in case the legislation regarding mining indigenous lands changed.”
Anglo American has repeatedly stated that “it has given up all mineral research requirements located within indigenous lands”, but several of those requests are still on record with the ANM. They have also responded to our (and Apib’s) request to commit to stay out of indigenous lands, regardless of changes in legislation, with a statement that they are “not in a position” to do that. We are particularly concerned about the situation of 27 processes filed by Anglo American that were authorised by the ANM.
“Any research activities there, would directly interfere in the indigenous lands,” said Miranda. “Anglo American has not yet clarified if they have given up on these processes too.” We have been pushing Anglo American to commit to consultation procedures as soon as possible in the prospecting phase, even before registering a research application with ANM. Our first discussions have shown they are not very willing to do that,” she said. Systemic change needs to occur. Between January 2017 and May 2020, Anglo American received no less than 13 billion Euros from 25 financial institutions from around the world. Among these international financiers are British companies Standard Chartered, Barclays and HSBC.
“Anglo American is not carrying out, or planning to carry out, any activity on Indigenous Lands in Brazil,” the company told The Independent in a statement. “We are aware of the difficult history that has existed between Indigenous Peoples and the mining industry. However, we know that mining, when undertaken responsibly, can bring significant economic and social value to host communities. As a matter of principle, Anglo American always adheres to local laws and international standards when engaging with indigenous peoples.”
London is one of the main centres for global industries such as mining giants, agribusiness empires, and oil and gas companies, which all need the money markets, and the backing of corporate investors to finance their projects and continue operating.
International public opinion and shareholder action needs to play an important part in exposing this international web of power and corruption in order to preserve the communities and habitats that Bolsonaro is trying so hard to destroy. International governments, who import these extractive resources and advocate for climate change and protection of the Amazon, need to put these issues higher up on their agenda.


Thousands of art pieces produced by a vanished civilisation have been uncovered on a Caribbean island, shining a light on a long-lost culture from the days before Europeans arrived.
The mix of faces, hybrid human-animal beings, and complex geometric designs marking the walls of Mona Island’s caves has revealed details about the beliefs and lifestyle of a people whom Columbus mistook for Indians, helping their descendants connect with a history buried by time.
Mona Island is a 57 square kilometre (22 square mile) crop of uninhabited limestone and wilderness a little to the west of Puerto Rico.
Today it’s a nature reserve. Wind back the clock five centuries, and it was thriving with an indigenous population who would soon be invaded by the violence and illnesses of the outside world.
The descendants of the Taíno live on, but their historians have been left to pull what they can from the Caribbean’s archaeology to develop an understanding of their practices and beliefs from the days before European contact.
Fortunately, the Taíno of Mona Island literally left their mark on the walls of the island’s caves, painting and scraping images into the limestone.
While examples of the artwork were already known to archaeologists, the astonishing preservation of many of the pieces had led researchers to mistaken their age.
Their uniqueness has also led anthropologists to question their connection with the island’s indigenous cultures.
Researchers have now pushed deeper in some 70 caves on Mona Island, uncovering thousands of additional pieces in the gloomy depths of just under half of them.
“Most of the precolonial pictographs are in very narrow spaces deep in the caves,” says Victor Serrano from the University of Leicester, a student working with the researchers in the field.
It mightn’t be a coincidence that the highest concentration of pre-Columbus cave art was found in some tight spots inside one of the densest networks of caves in the Caribbean.
“For the millions of indigenous peoples living in the Caribbean before European arrival, caves represented portals into a spiritual realm, and therefore these new discoveries of the artists at work within them captures, the essence of their belief systems and the building blocks of their cultural identity,” says researcher Jago Cooper from the British Museum.
Caves are significant features of Taíno religion and mythology, with the Sun and Moon emerging from underground.
Not only do the swirling patterns and monstrous hybrid forms provide hints on the religious and supernatural beliefs of this particular Taíno population, the techniques behind their construction contain valuable information.
Most of the images were described as extractive, formed used tools or even fingers to remove the rock’s dark patina and reveal the lighter layers beneath.
This image below, showing what’s thought to be a feathered head piece worn during ceremonies, was created using this technique.
But a few were paintings or drawings, made charcoal or bat guano which had been mixed with plant resins and had slowly absorbed dustings of pigment from the cave’s floor.
Paintings were found to be created in stages, either by adding new details or touching up faded imagery.
Importantly, the artwork was confirmed to date back to the centuries prior to European contact, affirming that while the technology and iconography stood out as different in the region, it was certainly pre-Columbian Taíno in origin.
Such rich galleries of art inside a unique network of caves makes it easy to imagine that Mona Island was a sacred destination in the Caribbean at the time of Columbus’s arrival.
Not only is this research an academic win, it is important for modern families who connect with Taíno culture to develop a richer understanding of their ancestral past.
“As a Puerto Rican these groups of people that visited and lived in Mona Island are my ancestors, and their story is of utmost importance,” says Serrano.
The Taíno introduced the world to foods like sweet potato, corn, and pineapple. Their words – such as hurricane, canoe, and tobacco – live on in modern languages.
Research such as this provides important insights into a people who influenced the world in such a short time before their culture was wiped from history.
This research was published in the Journal of Archaeological Science.


Physically-fit children are officially brainier than their punier peers, new research has confirmed.
Scientists found that aerobically fit nine and 10-year-olds had denser regions of "white matter" in their brains.
White matter consists of bundles of nerve fibres, or axons, that connect different brain regions.
Previous research has linked physical fitness in children to larger brain volumes of "grey matter" - the cell bodies of neurons.
US lead researcher Dr Laura Chaddock-Heyman, from the University of Illinois, said: "This study extends our previous work and suggests that white-matter structure may be one additional mechanism by which higher-fit children outperform their lower-fit peers on cognitive tasks and in the classroom."
The team used a brain scanning technique called diffusion tensor imaging (DTI) to examine five white-matter tracts in the brains of 24 volunteer children.
The system works by analysing water diffusion into tissues. For white matter, less water diffusion means the tissue is more fibrous and compact - both desirable traits.
Significant fitness-related differences were seen in several key white matter regions, including the corpus callosum which joins the brain's left and right hemispheres.
Two others were the superior longitudinal fasciculus, a pair of structures connecting two of the four major lobes in the brain's cerebral cortex, and the superior corona radiata which links the cerebral cortex to the brain stem.
"All of these tracts have been found to play a role in attention and memory," said Dr Chaddock-Heyman.
The research is reported in the journal Frontiers in Human Neuroscience.
Although the team did not test the children's mental performance, previous research has demonstrated a link between aerobic fitness and increasing thinking ability.


Equipment must be prepared for disassembly after a major break or for maintenance. The pump to be repaired is generally assembled in parallel with other pumps. It must therefore be isolated.
When dismantling a pump for maintenance, it is important to make sure that there are no immediate consequences on production if the pump is stopped. In order to maximize pump efficiency, it is important to respect the assembly suggested by the manufacturer.
This course covers the logical sequence for pump assembly and disassembly as well as the tools to be used.
Topics covered in this course include:
- pumping theory,
- pump characteristics,
- shut-down procedure,
- packing replacement,
- pump disassembly,
- post-disassembly inspection,
- pump assembly,
- start-up procedure,
- centrifugal pump simulation, and
- suggestions for practical exercises.


Changing the color of cut flowers is easy and produces beautiful results.
To change white carnation-type petals to green, stand the long-stemmed flowers in water containing a green aniline dye.
Other suitable aniline dyes may be used to achieve colored stripes on white flowers.
Place flowers over a basin of water which contains a very small amount of ammonia in a bell glass. The petals will usually change. For example, many violet-colored petals will change to green; red colors will become green, white will turn yellow and dark carmine will turn black.
Violet-colored asters can be moistened with a very mild solution of nitric acid. The ray florets will turn red and will also acquire a pleasant scent.


• Digital healthcare strategies must prioritize equity to avoid exacerbating current disparities.
• Rwanda and Chile prove health and fairness can be attained outside of high-income nations.
Virtual health and care facilities, or remote digital connectivity, should make them more accessible to more individuals. This improved access should also enhance health equality and outcomes for everybody.
A recent paper by the ITU/UNESCO -Working group of the Broadband Commission on Virtual Healthcare, co-chaired by the WHO and Novartis Foundation, and prepared with Accenture reveals that putting fairness at the center of state policy is crucial to ensuring the reverse does not happen.
Without suitable rules, individuals may lose out on virtual health and care owing to their poverty, age, gender, race, disability, or connection to broadband internet. Virtual health care might exacerbate existing imbalances.
We have released the entire set of recommendations by the working group of the Broadband Commission on 6 June, but here is a selection of best practices from some countries, we may learn from:
1. Health insurance in Rwanda
Rwanda’s strategy ensures everyone has access to virtual healthcare, regardless of income.
All Rwandans have access to community-based medical insurance, with payments based on socio-economic class. Rwanda is one of the few nations that reimburse virtual services alongside in-person treatment. By 2020, 88% of the population was covered.
2. Digital hospitals in Chile
A Chilean project uses virtual services to address the care gap between urban and rural regions by allowing rural residents to obtain professional medical care remotely via digital hospitals.
Digital hospitals, launched in 2019 by the government of Chile to expedite early illness identification, allow residents in remote locations to receive radiological exams and access specialized health services via virtual interchange of medical information.
3. US allows cross-state care
The US has helped rural people receive specialty treatments. During the COVID-19 epidemic, numerous jurisdictions changed their licensure policies to allow virtual care across state lines. People used to go to cities for specialty consultations. Now, policies will make these changes permanent.
4. Increased minority equity
New Zealand’s health-system changes to guarantee Mori representation help virtual services minimize imbalances for minority communities.
The new governance system includes facilities for additional virtual and digital services, such as phone and video consultations. Special money was given to health and care professionals to build distant working arrangements, including digital community support programs and a Mori telehealth service.
5. Germany’s disability-inclusiveness
Germany shows how to include disability in policymaking. Since 2000, Germany’s national health objectives include health inequalities. Recently, licensing regulations demand digital health apps (including virtual delivery solutions) to enable persons with vision, hearing, and motor skills limitations by incorporating operational aids or supporting the platform’s aids.
6. UK data governance initiatives
A UK strategy shows how to make virtual health and care inclusive. The UK National Health Service has a Data Ethics Framework to minimize unintentional damage or prejudice while creating solutions or providing health and treatment. The framework guides appropriate government and public sector data usage, particularly virtual health and care data. It provides a self-assessment technique to analyse fairness and minimize unintentional discriminatory impacts on people and all social groupings.
The examples are from high-, low-, and intermediate nations. Virtual health and care may improve access and inclusion worldwide.


New technology is helping ExxonMobil PNG (EMPNG) make major improvements in the diagnosis of tuberculosis among our workforce, with two state-of-the-art GeneXpert® diagnostic machines.
With a 40 percent increase in tuberculosis cases reported across PNG over the last decade, the two machines were installed at the LNG Plant and the Hides Gas Conditioning Plant permanent health clinics to help control the spread of the disease among our workforce.
The GeneXpert machine works by analysing sputum samples taken from patients for tuberculosis bacilli, as well as genetic markers that may indicate any resistance to tuberculosis treatment.
Tuberculosis is a contagious disease caused by bacterial infection of the lungs and has the potential to spread to other organs. It is transmitted through the air typically by coughing and sneezing.
Using the machine, initial test results can now be obtained within 24 hours with 98 percent accuracy, compared to the previous month-long waiting time for results using current methods available in PNG.
The technology brings early intervention in tuberculosis cases, reducing the risk of people becoming newly infected with the illness. It also enables higher quality treatment and care for those confirmed with tuberculosis.
Timeliness of results is critical to getting the right treatment and care for the patients, with nearly one quarter of PNG’s 16,000 tuberculosis cases each year estimated to be fatal.
Under the testing process, workers diagnosed with tuberculosis undergo a further series of testing while being isolated and masked to prevent further contamination of others.
After treatment, the patient may be eligible to return to work and remain on treatment if they are no longer infective to others.


- Report year:2016
- Organisation: Danish Institute for Human Rights
This is a toolkit for those conducting, reviewing, or monitoring a human rights impact assessment (HRIA) to ensure the process is consistent with the norms of the United Nations Guiding Principles on Business and Human Rights. The process consists of five iterative phases: planning and scoping, data collection and baseline development, impact analysis, impact mitigation and management, and reporting and evaluation. The document lists 10 key criteria to measure the effectiveness of HRIAs: five dealing with process (such as the nature of the participation process), and five with content (such as the human rights standards used). This toolkit mainly targets businesses and does not have the resource or mining sector as a focus, nor does it specifically address gender issues.


According to the judgment in R v Wedge  1 NSWLR 581, English law recognises three methods of acquisition of foreign land – conquest, cessation and settlement. Settlement occurs when a colony is founded in a land in which there are no settled inhabitants or a settled system of law. In such a case, English law is immediately in force in the new settled colony, and only those laws are applicable. According to the express authority of the Privy Council in Cooper v Stuart (1889) 14 App Cas 286, New South Wales was acquired by settlement, and since it was decided that it was a ‘settled’ colony under the doctrine of terra nullius, the English law was immediately transferred to it and therefore applied to all the inhabitants.
The Colonial Office treated Australia, for the purposes of its acquisition and the application of English law, as a settled colony, that is, one uninhabited by a recognised sovereign or by a people with recognisable institutions and laws. Thus there were no treaties concluded with the Aboriginal group, and no arrangements were made with them to acquire their land, or to regulate dealings between them and the colonists. They were treated as individuals, not as groups or communities. The decision to classify the ‘new’ country of Australia as a settled colony, rather than as conquered or ceded, meant that the new settlers brought with them the general body of English law, including the criminal law.
In Mabo v Queensland (No.2) (1992) 175 CLR 1, the doctrine of terra nullius was finally overturned. If Australia were truly terra nullius, the Crown’s so-termed “radical title” would become absolute beneficial title of the Crown. However, since Australia was not terra nullius, radical title did not imply full beneficial ownership. The High Court concluded that the Crown’s radical title only conferred sovereignty, and sovereignty did not extinguish native title by default. Therefore, while the sovereignty remained with the Crown, the beneficial ownership or title remained with the original inhabitants. Nevertheless, native title only confers what is directed by the Crown, being the sovereign entity representative of the people as a collective.
There have been consistent cases challenging the jurisdiction of the Crown, and asserting Aboriginal sovereignty was never ceded. In Coe v Commonwealth of Australia  HCA 68; 53 ALJR 403 it was stated: “The aboriginal people are subject to the laws of the Commonwealth and of the States or Territories in which they respectively reside. They have no legislative, executive or judicial organs by which sovereignty might be exercised. If such organs existed, they would have no powers, except such as the laws of the Commonwealth, or of a State or Territory, might confer upon them. The contention that there is in Australia an aboriginal nation exercising sovereignty, even of a limited kind, is quite impossible in law to maintain.”
Another such case was Walker v NSW (1994) 126 ALR 321, in which it was argued that Aboriginal customary law survived the assertion of sovereignty by the British, and continued until extinguished by clear and unambiguous legislation. It was claimed that general laws failed to extinguish Indigenous laws in that way. Chief Justice Mason, and Judges Ashley, Neave and Redlich, unanimously rejected the notion that a system of law could operate along side the Australian legal system. It was held the notion of parliamentary sovereignty means that Australian parliaments can pass laws that apply to Aboriginal people, and have the legislative competence to regulate or affect the rights of Aboriginal people, as equally as they do regarding any other race.
Regarding the acquisition of sovereignty, the court has numerous times relied on the principle stated by Gibbs J. in New South Wales v. The Commonwealth (1975) 135 CLR, at p 388, that: “The acquisition of territory by a sovereign state for the first time is an act of state which cannot be challenged, controlled or interfered with by the courts of that state.” and that the principle “…precludes any contest between the executive and the judicial branches of government as to whether a territory is or is not within the Crown’s Dominions.”
The High Court’s single source of authority, and the extent of the parameters of its jurisdiction are derived solely from the Crown itself, therefore it had no authority or jurisdiction to hear challenges to the legitimacy of the Crown’s jurisdiction. As Kenna, J. stated in Mabo (No.2): “There is no indication in Mabo (No.1) that the High Court is prepared to recognize Aboriginal sovereignty, the High Court is unable to inquire into the actual acquisition of sovereignty.” and in Walker: “The Court confirmed received doctrine on sovereignty, putting the matter beyond the reach of review in domestic Australian courts.”
The effect of R v Murrell and Bummaree (1836) 1 Legge 72;  NSWSupC 35:
R v Murrell in 1836 is a landmark case in Australia in two main points. It settled both the question of jurisdiction over the Aboriginal people, and declared that Aboriginal people were British Subjects.
The following is an interesting and detailed historical account on the way this case impacted on future decisions of the courts in Australia.
Source: Recognition Of Aboriginal Customary Laws (Australian Law Reform Committee Report 31) / 4. Aboriginal Customary Laws And Anglo-Australian Law After 1788 / “Australian Law As Applied To Aborigines”
“The application of English law to Aborigines was in practice less certain, especially for offences (especially killings) committed by one Aborigine against another. For some time the practice was to apply English law at least to offences committed by colonists against Aborigines and by Aborigines against colonists, so as to provide a measure of protection for each group against the other. Although these figures are unrepresentative of the actual number of killings during this period, from 1788-1855, 68 whites were committed and 59 tried for murder of Aborigines; 44 Aborigines were committed and 29 tried for murder of whites or other Aborigines. (See B Bridges, ‘The Aborigines and the Law: New South Wales 1788-1855’ (1970) Teaching History 40, 47.)
However the amenability of Aborigines to English law presented many problems, whether the victims were colonists or other Aborigines. The Colonial Office condemned the military execution of two Aborigines in South Australia for the murder of certain whites, as itself murder, because it lacked due process of law. But the judge of the Supreme Court had declared himself without jurisdiction to try the Aborigines. (See SD Lendrum, ‘The Coorong Massacre: Martial Law and the Aborigines at First Settlement’ (1977) 6 Adel L Rev 26; K Hassell, The Relations Between the Settlers and Aborigines in South Australia, 1836-1860, Libraries Board of South Australia, Adelaide, 1966, 52-72.)
In 1829 the New South Wales Supreme Court advised the Attorney-General that it would be unjust to apply English law to the killing of an Aborigine by members of another tribe. (See B Bridges, ‘The Extension of English Law to the Aborigines for Offences Committed Inter Se, 1829-1842’ (1973) 59 JRAHS 264, 264.)
Similar doubts were entertained in South Australia (See Lendrum; Castles (1982) 524-6.) and in Melbourne. (R v Bon Jon (1841); see para 41.)
In Jack Congo Murrell’s Case, that the Aborigines were British subjects seemed to have been conclusively settled, so far as colonial courts were concerned, by the various proclamations and statutes establishing the Australian colonies, but the implications of this status for the application of English law took surprisingly long to establish. The Proclamation of Governor Hindmarsh (28 December 1836) extending ‘the same protection to the native population as to the rest of His Majesty’s subjects’ (See JM Bennett & AC Castles, A Source Book of Australian Legal History, Law Book Co, Sydney, 1979, 258.) Similarly the official proclamation of Western Australia conferred the protection of the law on Aborigines as equals of ‘other of His Majesty’s subjects’ (See R Cranston, ‘The Aborigines and the Law: An Overview’ (1973) 8 U Queens LJ 60, 61 citing H Schapper, Aboriginal Advancement to Integration: Conditions and Plans for Western Australia (1970) 11. also Australian Courts Act 1829 (9 Geo IV c 83) s 3, 24.)
The decisive case was R v Jack Congo Murrell (1836) 1 Legge 72, in which the Full Court of the New South Wales Supreme Court held unanimously that it had jurisdiction to try one Aborigine for the murder of another. The Full Court had to deal with two distinct cases.
In Murrell’s case, the defendant alleged that he was so drunk he could not help killing. In the other case, the defendant relied on Aboriginal customary laws. His victim was, apparently, a member of the group which had killed his brother: ‘this was clearly a case of obedience to the native custom of revenge killing’. (See Bridges (1973) 264.) The argument for the defence was lucidly put by Alfred Stephen:
“This country was not originally desert, or peopled from the mother country, having had a population far more numerous than those that have since arrived from the mother country. Neither can it be called a conquered country as Great Britain was never at war with the natives, not a ceded country either, it, in fact, comes within neither of these, but was a country having a population which had manners and customs of their own, and we have come to reside among them: therefore in point of strictness and analogy ‘to our law, we are bound to obey their laws, not they to obey ours. The reason why subjects of Great Britain are bound by the laws of their own country is, that they are protected by them; the natives are not protected by those laws, they are not admitted as witnesses in Courts of Justice, they cannot claim any civil rights, they cannot obtain recovery of, or compensation for, those lands which have been torn from them, and which they have probably held for centuries. They are not therefore bound by laws which afford them no protection.”
Although not reported in Legge, apparently Stephen also argued from the fact of double jeopardy: ‘even if acquitted, a native would have to face another trial in the bush according to native law’ (See Bridges (1973) 265.)
In response, the Court simply denied that the binding quality of the laws was contingent upon their effectiveness as ‘protection’:
“If the offence had been committed on a white, he would be answerable, was acknowledged on all hands, but the Court could see no distinction between that case and where the offence had been committed upon one of his own tribe. Serious cases might arise if these people were allowed to murder one another with impunity, our laws would be no sanctuary to them. For these reasons the Court had jurisdiction.” (See Bridges (1973) 265-6.)
Despite the reality of the coexistence of two laws for Aborigines, the case came to be regarded as having settled the question for Australian law. It has since been reaffirmed on numerous occasions, Tuckiar v R (1934) 52 CLR 335; Milirrpum v Nabalco Pty Ltd (1971) 17 FLR 141, 261-2 (Blackburn J); R v Wedge  1 NSWLR 581. In the latter case, Rath J concluded at p. 587 that `all the reasons of the court in R v Murrell are as valid today as they were when judgment in that case was given’.
But in practice, both before and after 1836, the law was applied differentially and, especially in remoter areas, haphazardly, so that few killings (whether an Aborigine was offender or victim) were prosecuted. (See RHW Reece, Aborigines and Colonists, 1974, 194-5, 225-7.) Such recognition as was given to Aboriginal customary laws and traditions was thus a matter of ‘administrative flexibility’, or simply the result of a policy of non-involvement in Aboriginal quarrels or disputes which did not affect the British settlements. Colonial Office policy required that every effort be made to live peacefully with and respect local Aborigines. Governor Phillip and later Governors were directed to ‘educate and Christianize the Aborigines, to protect their persons and the enjoyment of their possessions, to prevent and restrain violence and injustices towards them, and to punish any of our subjects who harmed them’. Thus the Aborigines were to be protected by the punishment of white offenders ‘according to the degree of the offence’. (See Instructions to Arthur Phillip Esq (25 April 1787) Historical Records of Australia (hereafter HRA) ser 1 vol 9, 13-4.)
Similarly, Governor King, in his Port Regulations of 1800, warned that ‘If any of the natives are killed, or violence offered to their women, the offenders will be tried for their lives’. (See HRA ser 1 vol 4, 143.) However, official ambivalence soon emerged; it is recorded that during Governor King’s time, ‘(military) officers kept the crowd back to give native duellists room to spear each other, according to native custom, in the streets of Sydney, and then led troops out against the natives for spearing whites’. (See Sydney Gazette (29 December 1805) cited by Bridges (1973) 42.)
In his Port Regulations and Orders of 1810, Governor Macquarie stated:
“The natives of this territory are to be treated in every respect as Europeans; and any injury or violence done or offered to the men or women natives will be punished according to law in-the same manner and in equal degree as if done to any of his Majesty’s subjects or foreigners residing there.” (See Historical Records of New South Wales vol 7, 1901, 418.) But ironically, in the same paragraph he banned the supply of intoxicants to Aborigines.
But Macquarie’s famous Proclamation to the Aborigines of 4 May 1816 (See HRA ser 1 vol 9, 141.) is ambivalent as to whether Aborigines were to be considered British subjects, subject to British law. The proclamation imposed certain restrictions upon Aborigines and stated that those who wished to be considered under the protection of the British Government and who were ‘disposed to conduct themselves in a peaceful, inoffensive, and honest manner’ would, upon application to the Secretary’s office on the first Monday of each month, be provided with a passport signed by the Governor which would entitle them to protection so long as they did not break his regulations against carrying arms. This in effect made protection of the law for an Aborigine a privilege to be granted or withheld at the Governor’s discretion. Macquarie’s Proclamation of 1816 also represented the first explicit regulation of Aboriginal traditional practices as such. The Proclamation prohibited Aborigines from carrying any spears, and prohibited them from pursuing their customary punishment against transgressors of customary law at or near Sydney or other settlements, stating that such practices were repugnant to British laws. (See HRA ser 1 vol 9, 142-3.)
Such prohibitions were legally unnecessary, on the theory, established by Murrell’s case, that Aborigines were British subjects equally subject to British law. Those who argued against this sometimes did so because if Aborigines where amenable to the law this implied that whites could also be punished for killing or harming Aborigines. (See Reece, 182, 194.)
But the reality in many cases was that Aborigines neither understood nor felt allegiance to that law. In such cases, judicial punishments was usually mitigated through the Governor’s exercise of the prerogative of mercy, under which he could remit or mitigate punishment for all offences other than treason and wilful murder (where he was limited to postponing execution until the Monarch’s pleasure was known). Another safeguard for Aborigines lay in the fact that in the Colony, the Attorney-General exercised the functions of a Grand Jury. Without his initiative, an Aborigine would not be sent for trial. Thus both the initiation and final review of criminal prosecutions against Aborigines lay with the Government. According to Bridges (1970) 62:
“On the whole executive review took much of the sting out of major sentences in that a significant proportion of capital sentences imposed on natives were commuted to transportation which in effect often becomes a term for Cockatoo or Goat Islands (in Sydney Harbour) for instruction in secular and religious matter preparatory to an early release. A review of the cases tried (for the period 1788-1855) leads one to believe that with the sole exception of Charley, no Aboriginal was executed who would not have qualified for death also under native laws … Governor Gipps stated explicitly that this was the test applied by the Executive Council in his time.
While the attitude of Gipps’ Executive Council may have been enlightened for its time, in practice, law enforcement and the activities of private citizens were not at all consistent with it. (See Reece, ch 5.)
Meanwhile there was considerable debate and controversy in Britain over the treatment of native peoples in Britain’s overseas colonies, including the Australian Aborigines. In 1835 the Aboriginal Protection Society was established in Britain. The Society helped to bring about the establishment of a Select Committee of the House of Commons to examine the conditions of Aborigines in British settlements. As has been noted, the Committee in its Report in 1837 recognised the absurdity and injustice inherent in applying British notions of law automatically to Aboriginal people. (See House of Commons Select Committee on Aborigines (British Settlements) Report, Parl Paper, House of Commons no 425, 1837, 79-80.) However, the Committee reaffirmed the position that Aborigines should be subject to that law, provided that its full rigours were tempered by the exercise of discretions, for example, by reducing the penalty in certain cases. The Committee stated that:
“…when British law is violated by the Aborigines within the British dominions, it seems right the utmost indulgence compatible with a due regard for the lives and properties of others, should be shown for their ignorance and prejudices. Actions which they have been taught to regard as praiseworthy we consider as meriting the punishment of death. It is of course impossible to adopt or sanction the barbarous notions which have urged the criminal to the commission of the offence, but neither is it just to exclude them from our view in awarding the punishment of his crimes.”
The Committee (at 84.) recommended further study on the possibility of special measures for Aborigines:
“To determine under what special regulations they should be placed is a task to be performed only by those who can study the case with the aid of the most minute and close observation. It should therefore be part of the duty of the Protector to suggest to the Local Government, and through it to the local legislature, such short and simple rules as may form a temporary and provisional code for the regulation of the Aborigines, until advancing knowledge and civilisation shall have superseded the necessity for any such special laws.”
This — one of the first of many suggestions for special laws and special studies — does not appear to have been taken particularly seriously by the Australian colonies.
In 1840, the British Government set out its views on the application of British laws to Aborigines, in a despatch to all Governors in Australia and New Zealand. (See Lord Russell to Sir George Gipps, HRA set 1 vol 21, 33.) These despatches contained a Report from Captain (later Sir George) Grey with the advice that his recommendations:
“…appear … fit for adoption generally within your Government subject to such modifications as the varying circumstances of the Colony may suggest.”
Grey was critical of allowing Aborigines to exercise their customary law in any circumstances. He stated:
“1. The Aborigines of Australia having hitherto resisted all efforts which have been made for their civilization. it would appear that. if they are capable of being civilized. it can be shewn that all the systems, on which these efforts have been founded, contained some common error. or that each of them involved some erroneous principles: the former supposition appears to be the true one, for they all contained one element, they all started with one recognized principle, the presence of which in the scheme must necessarily have entailed its failure.
2. This principle was that. although the Natives should, as far as European property and European subjects were concerned. be amenable to British laws, yet, so long as they only exercised their own customs upon themselves and not too immediately in the presence of Europeans. they should be allowed to do so with impunity.
3. This principle originates in Philanthropic motives and a total ignorance of the peculiar traditional laws of this people.”
In Grey’s view, English law should entirely supersede customary law, in order to protect an Aborigine from the violence of his fellows, and to prevent the older natives from obstructing the civilisation of members of their tribe. (See HRA ser 1 vol 21, 35.) Grey commented:
“… I do not hesitate to assert my full conviction, that whilst those tribes, which are in communication with Europeans, are allowed to execute their barbarous laws and customs upon one another, so long will they remain hopelessly immersed in their present state of barbarism.”
Grey’s views on punishment, which echoed those of the Select Committee, (at 36.) were clear:
“12. To punish the Aborigines severely for the violation of laws to which they are ignorant, would be manifestly cruel and unjust, but to punish them in the first instance slightly for the violation of true laws would inflict no great injury on them…
13. I imagine that this course would be more merciful than that at present adopted, viz., to punish them for the violation of a law they are ignorant of, when this violation affects a European, and yet to allow them to commit this crime as often as they like, when it only regards themselves.”
In addition to the House of Commons inquiry and Captain Grey’s Report, several early inquiries on related questions were conducted within the Australian colonies, though none were specifically concerned with Aboriginal law.
NSW: Select Committee on the Conditions of the Aboriginals, Votes & Proceedings (Legislative Council) (1845); Report from the Select Committee on the Native Police Force, id (1856-7)
Qld: Report of the Select Committee on the Native Police Force and the Conditions of the Aboriginals Generally, Votes & Proceedings (1861)
Vic: Report of the Select Committee on the Aboriginals, Votes and Proceedings (Legislative Council) (1859 no D8)
SA: Select Committee of the Legislative Council on the Aboriginals, Report (Part Papers 1860 no 165).
The Colonial Office entertained no doubts that Aborigines were to be treated as British subjects for all purposes, but the appropriateness and justice of applying this principle was questioned by members of the colonial judiciary even after the decision in R v Jack Congo Murrell. In 1841, (See CSO 511/1840, Advice from Cooper J to the Government of South Australia.) Justice Cooper of the South Australian Supreme Court still held the view that it was:
“… impossible to try according to the forms of English law, people of a wild and savage tribe whose country although within the limits of the province of South Australia, has not been occupied by Settlers, who have never submitted themselves to our dominion and between whom and the Colonists there has been no social intercourse.”
Similar views were expressed by Justice Willis in Melbourne in 1841 in the Bon Jon case. (See Port Phillip Gazette (18 September 1841) Justice Willis stated that ‘there is no express law which makes the Aborigines subject to our Colonial Code’. The case did not proceed and Bon Jon was handed over to the Protectorate to be educated. The Chief Protector, Robinson, was accused by the victim’s kin of being an accessory to his escape (See Dixon Library, Sydney Add 77, Robinson to La Trobe (9 April 1842).) and Bon Jon himself was murdered in a payback killing, (See A Sutherland, Victoria and its Metropolis, Melbourne, 1888, vol 1, 249.) thus lending weight to the argument of Stephen in Murrell’s case that ‘the British were not filling a void with their laws and it was absurd to ignore native law while its practice continued’. (See Bridges (1973) 267.)
Willis requested Governor Gipps to bring the question to Lord Stanley’s notice for reference to the Law Officers. (See Sir George Gipps to Lord Stanley, 24 January 1842: HRA set 1 vol 21, 653-4.) Gipps himself considered having legislation passed to clarify the position that Aborigines were amenable to the courts like any other of Her Majesty’s subjects. (See Colonial Secretary Thomson to Sir James Dowling (4 January 1842): id, 654-5.) However he was advised by the Supreme Court that Murrell’s case had decided the matter and that no legislative action was necessary. (See Sir James Dowling, advice to Sir George Gipps (8 January 1842): id, 656.)
In South Australia Justice Cooper remained unwilling to concede that Aborigines should always be tried for offences under British law. In 1846, an Aborigine was brought before the court for killing another Aborigine. Justice Cooper argued that he required a legislative direction if such cases were to be justiciable and the accused was discharged because no competent interpreter was available. (See Larry v R, The Register 14, 25, 28 November 1846. Cooper J referred the matter to the Governor: CSO 1564 (1851).) In 1848, Justice Cooper accepted jurisdiction but indicated before the trial commenced that ‘in the case of conviction he would stay any execution required by law and specifically refer the case to the Governor’. (See Castles, 530, citing The Register 14, 17 June 1848; Robe to Grey, 10 July 1848, GRG 2/6/4.)
In Western Australia, Captain Grey’s Report, which confirmed the view of the British authorities that Aborigines were and should be subject to European law for offences committed on each other, was rejected by Governor Hurt. According to Hasluck:
“In spite of the indication given by the Secretary of State of his views, Hurt held to his own opinion regarding disputes between natives, and during his term no notice was taken of acts by natives against natives in accordance with their own law.”
(See P Hasluck, Black Australians, Melbourne UP, Melbourne, 1942, 129.) By contrast Hutt’s successor, Governor Fitzgerald, adopted a policy of ‘cognisance of all aggravated cases of assault committed even by bush natives inter se’. This policy produced considerable debate, and attempts were made in successive years to mitigate its effects by reduced sentences or by non-prosecution. But there were cases in which severe penalties were imposed. (See Hasluck 129-34. See generally Castles (1982) 520-42; Bennett & Castles, 247-63.)
Applying British law to Aborigines produced special difficulties in the presentation of Aboriginal evidence. In theory Aborigines were British subjects, but in practice they were not, and perhaps could not be, given the same rights as British subjects in judicial proceedings. The paradox caused considerable concern to colonial administrators. Captain Grey put the problem thus:
15. The greatest obstacle that presents itself in considering the application of British Law to these Aborigines is the fact that, from their ignorance of the nature of an oath, or of the obligations it imposes, they are not competent to give evidence before a Court of Justice …
17. The fact of the Natives being unable to give testimony in a Court of Justice is a great hardship on them, and they consider it as such: the reason that occasions their disability for the performance of this function is at present quite beyond their comprehension and it is impossible to explain it to them. I have been a personal witness to a case in which a Native was most undeservedly punished for the circumstance of the Natives, who were the only persons who could speak as to certain exculpatory fact s, not being permitted to give their evidence …
19. The Natives being ignorant of our Laws, of the forms of our Courts of Justice, of the language in which the proceedings are concluded, and the sentence pronounced upon them, it would appear that but a very imperfect protection is afforded to them by having present in the Court merely an interpreter … who knows nothing of legal proceedings and can be but very imperfectly acquainted with the Native language: it must also be borne in mind that the natives are not tried by a jury of their peers, but by a jury having interests directly opposed to their own and who can scarcely avoid being in some degree prejudiced against Native offenders …”
(See HRA ser 1 vol 21, 37.) Attempts were made in South Australia, New South Wales and Western Australia to relax the rules regarding the administering of oaths and the admissibility of evidence for Aborigines, and in some instances to enable magistrates to award summary punishment in certain offences. (See Bridges (1970) 65-70; Hasluck, 135-43.) But these early attempts were defeated by hostile local legislatures, or disallowed by British law officers as being ‘contrary to the principles of British jurisprudence’. (See Campbell and Wilde to Russell (27 July 1840): HRA ser I vol 20, 756.) Any such special measures for Aborigines, it was said, (Lord John Russell to Hutt (30 April 1841) cited in Hasluck, 136-7.) were:
“…dangerous in its tendency and faulty in principle. By thus establishing inequality in the eye of the law itself between the two classes, on the express ground of national origin, we foster prejudices, and give a countenance to bad passions.”
In 1839 (See HRA ser 1 vol 20, 303.) the British Aboriginal Protection Society commented on the paradox of regarding Aborigines as British subjects while at the same time refusing Aboriginal testimony, unless they had been converted to Christianity:
“It is evident that the rejection of the Evidence of these Natives renders them virtually outlaws in their Native Land which they have never alienated or forfeited. It seems to be a moral impossibility that their existence can be maintained when in the state of weakness and degradation, which their want of civilisation necessarily implies; they have to cope with some of the most cruel and atrocious of out species, who carry on their system of oppression with almost perfect impunity so long as the Evidence of Native Witnesses is excluded from Our Courts.”
Local opponents, echoing WC Wentworth’s comparison of Aboriginal evidence with ‘the chatterings of the ourang-outang’, managed to postpone the enactment of such legislation for many years. (See Reece, 181 for Wentworth’s statement, and generally id, 179-82 for the issue. See further para 605n.)
As this brief account reveals, most, if not all, of the debate was focused on the criminal law (and on problems of Aboriginal evidence in criminal cases). This obscured what was perhaps the more fundamental point, which was never questioned or debated — that is, the complete absence of recognition of Aboriginal rights to land, or of the recognition of Aboriginal customary laws in the civil law. Aborigines were not treated as trespassers on Crown land, but the Crown freely alienated land to settlers who then displaced local Aborigines, often by force. (See para 41-2, 899-902.)
Aboriginal marriages were not recognised (See para 237 for the few early cases.) and rights to the custody of children were precarious or non-existent. Although Aborigines as British subjects had formal capacity to make contracts, to own property, and to sue in the courts, in practice these facilities were irrelevant. These common law rights were modified or removed by legislation under the ‘protection’ policy.
Despite doubts and uncertainties, it was firmly established by 1850 that no formal recognition of Aboriginal customary laws should be accorded. This remained the situation until this century. Instead the emphasis moved to policies based on ‘protection’ (with the underlying expectation that Aboriginal identity and tradition was a rapidly passing phenomenon). But there was a distinguishable phase during the 1920s and 1930s when some attempt was made to recognise Aboriginal customary laws. These legislative and administrative responses are of considerable interest.”
- R v Wedge  1 NSWLR 581 https://jade.io/citation/3076459
- Cooper v Stuart (1889) 14 App Cas 286 https://jade.io/citation/2363018
- Mabo v Queensland (No.2) (1992) 175 CLR 1 https://jade.io/article/67683
- Coe v Commonwealth of Australia  HCA 68; 53 ALJR 403: https://jade.io/article/188346
- Walker v NSW (1994) 126 ALR 321, https://jade.io/citation/2721225
- New South Wales v. The Commonwealth (1975) 135 CLR https://jade.io/article/66566/section/140766
- R v Murrell and Bummaree (1836) 1 Legge 72;  NSWSupC 35 https://www.law.mq.edu.au/research/colonial_case_law/nsw/cases/case_index/1836/r_v_murrell_and_bummaree/?fbclid=IwAR3HajwIg4x-dAFant-u98qzPW6gAqAykg6QTa4SgSiXNfOSW61-lebYogw
- Tuckiar v R (1934) 52 CLR 335 https://jade.io/article/63733
- Milirrpum v Nabalco Pty Ltd (1971) 17 FLR 141 https://jade.io/citation/424624
- R v Wedge  1 NSWLR 581 http://www.unistudyguides.com/wiki/R_v_Wedge


To rousing cheers and tears of relief, envoys from 195 nations approved Saturday an accord to stop global warming, offering hope that humanity can avert catastrophic climate change and usher in an energy revolution.
In the COP 21(Conference of the Parties)- Paris climate conference held from November 30 to December 11, 2015, “The Paris agreement” to combat climate change and take actions towards a low carbon, sustainable future was agreed by 195 nations. Following the adoption of the Paris Agreement by the COP, it will be opened for one year for signature on 22 April 2016--Mother Earth Day. The agreement will enter into force after 55 countries that account for at least 55% of global emissions have deposited their instruments of ratification. The agreement is the global climate framework for the post-2020 world. It will replace the existing Kyoto Protocol which will continue till that time.
Key features of Paris agreement are-
- Agreement calls for holding the increase in the global average temperature to well below 2°C and to pursue efforts to limit the temperature increase to 1.5°C
- An overall assessment of how countries are doing in cutting their emissions compared to their national plans – starting in 2023, every five years. Climate action will also be taken forward in the period before 2020
- By some point after 2050, man-made emissions should be reduced to a level that forests and oceans can absorb. Thus a carbon-neutral world is aimed at after 2050 but before 2100.
- Parties to peak greenhouse gas emissions as soon as possible and achieve a balance between sources and sinks of greenhouse gases in the second half of this century
- The deal requires countries to monitor, verify and report their greenhouse gas emissions
- Only developed countries are expected to slash their emissions in absolute terms; developing nations are "encouraged" to do so as their capabilities evolve over time.
- The deal also calls on developed nations to give $100 billion annually to developing countries by 2020.
In order to reach the long-term goal, countries agreed to set national targets for reducing greenhouse gas emissions every five years. More than 180 countries have already submitted targets for the first cycle beginning in 2020. India has submitted its Intended Nationally Determined Contribution (INDC) to the United Nations Framework Convention on Climate Change. Main points of India INDC are -


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Cleaning ‘On the Go’
The use of cosmetic wipes or “wet wipe” products has dramatically increased in popularity in recent years as they sit comfortably alongside the fast pace of modern life. They provide a convenient solution to helping people keep clean and refreshed when time is short and can often be found in many places outside the home such as the workplace, handbags, sports bags, cars and other places where water and skin cleansing products such as soap or hand washes are not readily available.
Originally developed in the mid 1950s primarily to supply individual wipes to services such as caterers and airlines, wet wipes are now commonly seen in shops all over the world for a number of different uses including:
- baby wipes
- facial skincare wipes
- toddler wipes
- feminine hygiene wipes
- wipes for spots and problem skin
- refreshing hand wipes
- moist toilet tissue
How do wet wipes work?
Wet wipes consist of two main parts; the non-woven wipe and the liquid product. The liquid is classed as a cosmetic product and will be subject to the strict safety laws covering all cosmetics.
Although the cleansing products used in wipes are formulated specifically for wipes, they contain many of the same ingredients found in other skincare products. For example;
- surfactants to help with the removal of dirt from the skin;
- moisturisers and emollients to condition the skin;
- anti-microbial / anti-bacterial agents; and
- pH buffers to ensure that the wipes are matched to the pH of the intended area of application.
Many different types of wipe materials are available, each with different properties that allow them to carry out a particular function.
- Baby and facial wipes are selected for their softness and ability to retain the dirt that is being removed from the skin.
- Exfoliating wipes are slightly less soft and work by gently rubbing away dead cells from the surface of the skin, helping it to look refreshed.
- Moist toilet tissue products are often flushable and will break down over time.
Wet wipe products are carefully developed to ensure that they have the correct level of wetness to do the intended job – not too wet or too dry, while remaining convenient and ready to use throughout their intended shelf life. The thickness of the liquid has to be carefully controlled to ensure that it spreads easily across the whole wipe ready for application on to the skin.
Information on the wipe itself is available from the European association for nonwoven and engineered fabrics, EDANA. The website also highlights EDANA's campaign on flushability.
Remember it is important not to dispose of non-flushable wipes down the toilet. Non-flushable wipes will be clearly identified on-pack either in words and/or via the non-flushable logo.
As the popularity of wet wipes increases so do the types and functions of the products available such as: biodegradable wipes; organic wipes and smaller sizes for use on specific areas of the body such as the nail and around the eyes. From being just cleansing products, wipes are increasingly including additional functions such as anti-ageing, moisturisation and deodorising.


In the last twenty years there have been substantial increases in the use of pharmaceutical opioids in many countries, including Australia which has one of the highest levels of opioid utilisation globally 1. Almost 15 million opioid prescriptions were dispensed in 2015 and our use of high-potency opioids has also increased 2. One of the main drivers is the increased use of prescription opioids for chronic non-caner pain (CNCP) 3. In parallel to escalating use, opioid-related harms have also increased. Since 2000, there has been a shift in both hospitalisations due to opioid poisonings and opioid-related deaths, from predominantly heroin to pharmaceutical opioids4. Extra-medical use (defined as any use of a medication outside the formal medical system or inconsistent with a doctor's prescription5) is also relatively common; the most recent household survey indicates ‘non-medical use’ (the terminology used in this survey) was reported by 4.8% of the Australian population4.
A range of possible strategies to minimise unnecessary opioid exposure and adverse events were highlighted in the National Pharmaceutical Drug Misuse Framework for Action (2012-2015)6 including: coordinated medication management systems (prescription drug monitoring programmes (PDMPs); improvement of access to pain and addiction services; development of resources, and workforce development. To date, few of these strategies have been implemented. We summarise recent and emerging responses in Australia that aim to minimise harms from pharmaceutical opioids.
Regulatory responses aimed at reducing aberrant opioid prescribing and restricting opioid supply
In 2016, the most common analgesics used for ‘non-medical’ purposes by Australians were over-the-counter (OTC) codeine products4. There have been several attempts to reduce extra-medical use and harms from OTC codeine. In May 2010, OTC codeine products were up-scheduled from Schedule 2 (Pharmacy Medicine) to Schedule 3 (Pharmacist Only Medicine). This change, however, had no meaningful impact on codeine poisonings 7. They were subsequently up-scheduled again in February 2018 to Schedule 4 (Prescription-only medicines). The impacts of this decision remain to be seen 8.
Prescription drug monitoring programmes (PDMPs)
PDMPs (programs designed to track prescribing and dispensing of prescription drugs of potential extra-medical use) are being introduced in Australia, although their characteristics remain unclear, and there are likely to be jurisdictional differences, with potentially different outcomes. Differences may include whether the program is: voluntary vs. mandatory; monitors S8 opioids only vs. S8 opioids and benzodiazepines; fully automated vs. requires specific actions from the prescriber or pharmacist (e.g. requesting a record); and real-time vs. time-lagged.
International research on the impacts of PDMPs indicate mixed findings, with effectiveness varying according to programme features 9. For example, some US states with PDMPs report reductions in prescription opioid poisonings, with stronger protective effects where PDMPs monitored more schedules or required more regular reporting10. Less clear is how PDMPs will impact upon other aberrant behaviours (i.e., patient practices that are divergent from those ‘as directed’ by the prescriber5, such as use of opioid medicines for reasons other than pain, or use via unintended routes of administration), other substance use (prescribed or illicit), and opioid use disorders. Other unintended consequences have also been suggested, including stigmatisation of patients and a “chilling effect” where prescribers underuse opioids due to fear of repercussions, rapidly reduce opioid doses or cease opioids altogether, leading to inadequate pain relief or opioid withdrawal 11. Whilst PMPs have intrinsic face validity – in practice there remain many unanswered questions.
An alternative approach to establishing stand-alone PDMPs is the impending expansion of My Health Record (MHR). Many aspects of PDMPs can be incorporated into MHR, however the focus of MHR is to more broadly enhance co-ordination and quality of healthcare, efficiency and patient safety, rather than an emphasis upon medications only, as is the case of PDMPs. This is likely to be less stigmatising and offer better integration into routine healthcare than stand-alone PDMPs requiring their own infrastructure. There is concern among many groups about the manner in which this data could potentially be used, particularly in the criminal justice system. Medical and consumer groups will also need to consider how MHR will address S8 medications – the ability for a patient to ‘opt out’ – or for a doctor to require access to MHR prior to opioid prescribing beyond emergency presentations.
Reponses to minimise harmful patterns of use and harm
Abuse-deterrent opioid formulations are intended to minimise extra-medical use by targeting use involving unintended routes of administration. Examples include making tablets tamper-resistant12 or including naloxone to deter injection13. In Australia, available evidence from convenience samples suggests most individuals tampering with pharmaceutical opioids take these drugs via injection, on an infrequent basis, and use a variety of pharmaceutical opioids and heroin14. Australian post-marketing surveillance studies show reductions in use and tampering amongst people who inject drugs following introduction of abuse-deterrent formulations, with no evidence of switching to other pharmaceutical opioids or heroin14 However, these formulations have not eradicated tampering and injection, and appear to have had limited impacts on overall opioid utilisation and population-level harm14. Unlike the Food and Drug Administration in the US, the Australian Therapeutic Goods Administration is yet to adopt an abuse-deterrent framework to enable the development and propagation of abuse-deterrent formulations over higher-risk opioid formulations.
Other responses to reduce pharmaceutical opioid-related harms
Greater availability of multidisciplinary pain services for people with CNCP and addiction treatment services for opioid dependent people are necessary to direct patients to more effective and safer treatment approaches than a reliance on opioid medications for CNCP. Screening for potential opioid problems is also important, with guidelines currently recommending that people with CNCP be assessed for such problems prior to initiating opioids15.
Access to multidisciplinary services
Contemporary guidelines regarding the management of CNCP emphasise the importance of multidisciplinary approaches that integrate medication, psychological approaches, and physical therapies. Many such services are most effectively and efficiently provided in multi-disciplinary teams, however, few non-medical services are funded by Medicare in the community, and hence out-of-reach for the majority of patients requiring their assistance. There continues to be unmet capacity to deliver multi-disciplinary team approaches within state–funded Local Health Districts or private health services, and much more needs to be done to enhance access. The inability to access effective non-medication-based treatments likely contributes to an overreliance upon opioid medications. There is a need to integrate more addiction services into pain management programs. In a review of 57 pain management services in Australia, only four offered a combined pain and addiction service16. National benchmarks for quality and access to multidisciplinary care for patients suffering persistent pain are lacking. With the National Pain Strategy now back on the agenda, it is hoped that and recommendations to collaborate more with addiction medicines will be become a priority area.
Access to Opioid Substitution Therapy (OST)
Despite increasing concern about pharmaceutical opioid dependence in Australia, the number of patients (per population) in OST (methadone/buprenorphine) has remained static for more than 15 years4. In a recent Australian study, few patients with concurrent chronic pain and opioid dependence 17 reported lifetime enrolment in OST, with participant’s indicating significant stigma associated with OST. The study highlighted the need to better integrate primary health, specialist pain and specialist addiction services.
Both methadone and buprenorphine are effective in the treatment of pharmaceutical opioid use disorders 18,19. High dose buprenorphine/buprenorphine-naloxone is proving a useful approach for patients with chronic pain and opioid use disorder 20. Yet few Australian general practitioners – estimated at no more than 10% - prescribe methadone or buprenorphine/naloxone, despite the recent relaxation in training and credentialing requirements in most jurisdictions. Studies have identified a number of barriers to general practice participation, including feeling ill-equipped to deal with behavioural challenges21, workload concerns21,22, and a lack of accessible specialist support 21,22. Many of these concerns can lessened with improved workforce training and retention 21,23,24. Concerted efforts are required to enhance the uptake of effective treatments by general practitioners, and address many of the perceived barriers. Expansion of specialist addiction services will be required as PDMPs begin to identify patients with opioid use disorders (OUDs).
Interest in the use of ‘take home naloxone’ (THN) as a strategy to reduce opioid overdose deaths has grown in recent years25, and supported by the World Health Organization. In Australia, THN programs are now incorporated in a range of services targeting people who inject drugs, including peer-based, needle and syringe programs, and Alcohol and other Drug (AoD) treatment services 25. However, THN programmes have been less widely established outside of these settings 25. Services targeting people with a history of injecting opioid use reach few CNCP patients, and efforts are required to engage doctors who prescribe opioids to also consider THN interventions for their patients.
Since 1st February 2016, naloxone was re-scheduled to Schedule 3, and is now available OTC, although there has been limited uptake and strategies are urgently needed to improve pharmacists’ knowledge and confidence in educating customers regarding opioid overdose and effective use of naloxone. Although previously only available as an injection, an intra-nasal formulation has recently been registered for use in Australia, which may improve its acceptability and attractiveness for use. However, whilst THN is important in reducing opioid-related overdoses, it is unlikely to impact on overall levels of opioid utilisation.
Education and advocacy for consumers and health care providers
In recent years, various government and non-government organisations have undertaken initiatives to promote education on the quality use of opioids and also an increasing awareness about opioid-related problems through various organisation-based websites and position statements. Examples include the NSW Agency for Clinical Innovation’s Pain Management Network which provides information for consumers and health professionals on the management of chronic pain. Scriptwise is a not-for-profit organisation that aims to prevent extra-medical use of prescription medications and overdose fatalities in Australia. Within the pain management sector, there has also been growing emphasis on the need to ‘deprescribe’ opioids and adopt multidisciplinary non-medication-based approaches to managing pain, as outlined in The Australian Pain Society’s Guiding Principles for Pain Management.
Actions for the future
It is important to reduce harms associated with pharmaceutical opioid use, but equally important that we do not prevent access for those who may benefit from opioid treatment. Our emphasis should be upon enhancing patient outcomes and safety – and recognise that regulatory responses such as rescheduling drugs, introducing PDMPs or abuse deterrent medicines are merely a means to achieve that end, and inadequate on their own. Notably, these responses are required to occur in an environment with many competing interests (e.g. industry vs government), which can be challenging. Overall, we need better education of health provider and consumers, better communication between providers through electronic clinical information systems, and increased availability of specialist pain and addiction services that work collaboratively with primary care providers. We must address the stigma of addiction that prevents patients and their doctors from effectively addressing this issue – much in the same we have made inroads in countering the stigma of mental health problems in the community over the past two decades. As a society we need to reverse our over-reliance on medications as solutions for chronic health problems.
The vastness of the problem and the breadth of required approaches suggests we need to revisit the role of a national policy with clear targets, implementation and evaluation strategies – absent from the last National Framework. Many of the solutions were identified a decade ago but have not been implemented. There are too many Australians experiencing opioid related harms for us to neglect this issue for another decade.
This article first appeared in the Medial Journal of Australia. Campbell, G., Lintzeris, N., Gisev, N., Larance, B., Pearson, S., & Degenhardt, L. (2019). Regulatory and other responses to the pharmaceutical opioid problem. Medical Journal of Australia, 210(1), 6-8.e1. doi:10.5694/mja2.12047
- Berterame S, Erthal J, Thomas J, et al. Use of and barriers to access to opioid analgesics: a worldwide, regional, and national study. Lancet (London, England) 2016;387:1644-56.
- Karanges EA, Blanch B, Buckley NA, Pearson SA. Twenty-five years of prescription opioid use in Australia: a whole-of-population analysis using pharmaceutical claims. British journal of clinical pharmacology 2016;82:255-67.
- Kolodny A, Courtwright DT, Hwang CS, et al. The prescription opioid and heroin crisis: a public health approach to an epidemic of addiction. Annual review of public health 2015;36:559-74.
- Australian Institute of Health and Welfare. Non-medical use of pharmaceuticals: trends, harms and treatment, 2006-07 to 2015-16. In: Welfare AIoHa, ed. Canberra2017.
- Larance B, Degenhardt L, Lintzeris N, Winstock A, Mattick R. Definitions related to the use of pharmaceutical opioids: Extramedical use, diversion, non-adherence and aberrant medication-related behaviours. Drug and Alcohol Review 2011;30:236-45.
- National Pharmaceutical Drug Misuse Framework for Action (2012-2015). National Pharmaceutical Drug Misuse Framework for Action (2012-2015). 2012.
- Cairns R, Brown JA, Buckley NA. The impact of codeine re-scheduling on misuse: a retrospective review of calls to Australia's largest poisons centre. Addiction (Abingdon, England) 2016;111:1848-53.
- Schug SA, Dobbin MD, Pilgrim JL. Caution with the forthcoming rescheduling of over-the-counter codeine-containing analgesics. The Medical journal of Australia 2018;208:51-2.
- Fink DS, Schleimer JP, Sarvet A, et al. Association Between Prescription Drug Monitoring Programs and Nonfatal and Fatal Drug Overdoses. Ann Intern Med 2018;168:783-90.
- Pauly NJ, Slavova S, Delcher C, Freeman PR, Talbert J. Features of prescription drug monitoring programs associated with reduced rates of prescription opioid-related poisonings. Drug and Alcohol Dependence 2018;184:26-32.
- Islam MM, McRae IS. An inevitable wave of prescription drug monitoring programs in the context of prescription opioids: pros, cons and tensions. BMC Pharmacology & Toxicology 2014;15:46-.
- Peacock A, Degenhardt L, Hordern A, et al. Methods and predictors of tampering with a tamper-resistant controlled-release oxycodone formulation. The International journal on drug policy 2015;26:1265-72.
- Larance B, Lintzeris N, Ali R, et al. The diversion and injection of a buprenorphine-naloxone soluble film formulation. Drug Alcohol Depend 2014;136:21-7.
- Larance B, Dobbins T, Peacock A, et al. The effect of a potentially tamper-resistant oxycodone formulation on opioid use and harm: main findings of the National Opioid Medications Abuse Deterrence (NOMAD) study. The Lancet Psychiatry 2018.
- Therapeutic Guidelines. eTG Complete: Analgesic. Therapeutic Guidelines. In: Ltd. TG, ed. Melbourne, Australia2018.
- Hogg MN, Gibson S, Helou A, DeGabriele J, Farrell MJ. Waiting in pain: a systematic investigation into the provision of persistent pain services in Australia. Medical Journal of Australia 2012;196:386.
- Larance B, Campbell G, Moore T, et al. Concerns and Help-Seeking Among Patients Using Opioids for Management of Chronic Noncancer Pain. Pain Medicine 2018:pny078-pny.
- Nielsen S, Larance B, Degenhardt L, Gowing L, Kehler C, Lintzeris N. Opioid agonist treatment for pharmaceutical opioid dependent people. Cochrane Database of Systematic Reviews 2016;CD011117
- Nielsen S, Larance B, Lintzeris N. Opioid Agonist Treatment for Patients With Dependence on Prescription Opioids. JAMA 2017;317:967-8.
- Worley MJ, Heinzerling KG, Shoptaw S, Ling W. Pain volatility and prescription opioid addiction treatment outcomes in patients with chronic pain. Experimental and clinical psychopharmacology 2015;23:428-35.
- Holliday S, Magin P, Oldmeadow C, et al. An examination of the influences on New South Wales general practitioners regarding the provision of opioid substitution therapy. Drug and Alcohol Review 2013;32:495-503.
- Scarborough J, Eliott J, Braunack-Mayer A. Opioid substitution therapy A study of GP participation in prescribing. Australian Family Physician 2011;40:241-5.
- Hotham E, Roche A, Skinner N, Dollman B. The general practitioner pharmacotherapy prescribing workforce: examining sustainability from a systems perspective. Drug and Alcohol Review 2005;24:393-400.
- Longman C, Lintzeris N, Temple-Smith M, Gilchrist G. Methadone and buprenorphine prescribing patterns of Victorian general practitioners: Their first 5 years after authorisation. Drug and Alcohol Review 2011;30:355-9.
- Dwyer R, Olsen A, Fowlie C, et al. An overview of take‐home naloxone programs in Australia. Drug and alcohol review 2018;37:440-9.


iOS Universal Education
Your kids can start watching and listening to the two free fun animations. The Beandolls animated short stories were designed for young children. Stories are simple yet imaginative, and make learning fun and easy for your child. While being entertained, your child will encounter important sentence structures and everyday vocabulary, and learn through conversational context and repetition.
The Beandoll Story
Six little beans ("Beandolls") developed together in a Beanpod. Once they had grown large enough, the Beanpod split open, scattering the Beandolls in different parts of the world. Over time, each Beandoll took on traits from the region where it landed, and each acquired a special power.
But now, their beloved Earth is in danger. The evil Polu is sweeping across the Earth, destroying all that is green and natural. "G-Core" (the Earth's Green Energy Center) calls for help, and the Beandolls heed its call. They reunite in Bean Valley, where they will prepare to use their special powers to fight Polu and save Nature on the Earth.
But first, the Beandolls must get reacquainted after all these years apart, and they must learn to speak the same language--starting with English and Chinese.
Family, Home, Body, Colors, Food, Numbers, Surroundings, Animals, Birthdays, School, Activities, Habits.
**Fun and imaginative!
**Rewind, fast forward, or pause the animation at any time.
**Subtitles always available
**Easy to understand
**Promotes good behavior and values


The Duisburg-based steel producer thyssenkrupp Steel has launched a series of tests into the use of hydrogen in a working blast furnace. They are the first tests of their kind and are aimed at reducing significantly the CO2 emissions arising during steelmaking.
In the classic blast furnace process around 300 kilograms of coke and 200 kilograms of pulverized coal are needed to produce a ton of pig iron. The coal is injected as an additional reducing agent into the bottom of the blast furnace shaft through 28 so-called tuyeres.
At the start of the tests in November 2019 hydrogen was injected through one of these tuyeres into blast furnace 9. It marks the start of a series of tests in which thyssenkrupp Steel plans to gradually extend the use of hydrogen to all 28 tuyeres on blast furnace 9 and then, from 2022, to all three further blast furnaces. The advantage is that whereas injecting coal produces CO2 emissions, using hydrogen generates water vapor. CO2 savings of up to 20 percent are therefore already possible at this point in the production process.
The start of the test phase also marks the project’s transition to industrial scale. “We want to reduce emissions with hydrogen while continuing to produce pig iron of the same quality,” explains Dr. Arnd Köfler, thyssenkrupp Steel Europe’s Chief Technical Officer. “At the same time we are breaking new ground with the tests on blast furnace 9 so it is now a question of continuously analyzing and evaluating the furnace’s operation. The results will help us to widen the use of hydrogen to all 28 tuyeres.”
Hydrogen will be a key driver of thyssenkrupp Steel’s climate strategy in the coming decades. Following the conversion of the blast furnaces, the company plans to build large-scale direct reduction plants, which will then be operating with hydrogen-containing gases, starting in the mid-2020s. The sponge iron they produce will initially be melted down in the existing blast furnaces but in the long term will be processed into crude steel in electric arc furnaces using renewable energies.
In Air Liquide the project has a partner on board for the injection tests who has expertise in the entire hydrogen value chain from production and storage to the development of end consumer uses. Gilles Le Van, CEO of Air Liquide Deutschland: “Hydrogen is the key to both the energy transition and industrial transformation. This special molecule can be both a raw material for industry and a medium for energy storage and recovery.”


The keyword index includes the words in the captions of the pictures which were written by the photographers. The captions frequently include common and scientific names, names of towns and counties, geographical names, and descriptions of vegetation types or of the landscape. For example, areas affected by fire can be located by searching on fire as a keyword. We recommend keyword searches as a way of discovering what is available on this site.
For more comprehensive searches, we recommend searching by geographic quad using quad name or number (note that the quad map is no longer interactive), or by genus or species (see below).
The botanical nomenclature used here is that of the period when the photos were taken, which was in the 1920s and 1930s. For example, if you are searching for Douglas Fir you must search for "Pseudotsuga taxifolia" instead of "Pseudotsuga menziesii." If you do a keyword search using a common name, click on "view details" to see the scientific name that was used at the time. Just click on the scientific name to retrieve all pictures indexed with that species. The best source for botanical nomenclature of the period is the 1923 edition of W. L. Jepson's Manual of the flowering plants of California.
Once you have found the names for quads and species, you can use the search page for combined searches that will find those records where both names appear.


Korean scientists showed that sodium ion exchange with tin was hundreds of times faster than rates seen in current lithium ion technologies, suggesting ultrafast charging may be possible.
Two other papers from China and the US reported that trapping tin–antimony alloy nanoparticles inside carbon structures increased performance and the development of tin-antimony-sulphur materials for new generation solid state batteries was announced.
Sodium ion batteries are based on a compound similar to table salt and could be 80% cheaper than lithium ion technologies.
Papers on trapping tin-antimony nanoparticles in carbon:
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