Religion and Belief Systems in Australia Post – 1945

Contemporary Aboriginal Spiritualities

 Aboriginal spirituality is determined by the Dreaming

 A person who [is accepted by] identifies with an Aboriginal community.
 The dreaming is expressed in a physical sense through kinship systems, ceremonial life,
obligations to the land and people.
 Dreaming is the beginning of all things, its refers to events and places, it affect all of life. It is
the past, present and future.
 Aboriginal sacred stories are stories about events of the Dreamtime and how Ancestor formed
the land and founded life on the land.
 Dreaming is the unseen spirit world. It is not obscure and in the past. It is reality – Dreaming is
expressed in ceremonies, dance, song and art. Its is both personal and communal
 Everything in the land is linked to dreaming. Humans and the spirits are connected to it.

The Dreaming is …
o Expressed in rituals
o Seen in the obligations to care for the land of their ancestors
o The stories of the totems of the community and the individual
o Acted out in the obligations between different members of the community
o Reflected upon and shared through artwork
o Expressed in the social organization of the community
o The link to the ancestor spirits of the community
o The sacred spaces that are important to the aboriginal community
o Expressed in right relationships with others in the Aboriginal community
o Stories of the aboriginal peoples explaining who they are and their relationships with the
land
o A guide to what foods can be eaten an where the food comes from
o Spoken in language of each aboriginal community

DISCUSS HOW ABORIGINAL SPIRITUALITY IS DETERMINED BY THE DREAMING

KINSHIP
- Kinship ties identify a complex system of belonging and responsibilities within a clan.
- Aboriginal and TSI people have a complex system of family relations where each person
knows their kin and their land.
- These extended families are central to the way culture is passed on and society is organised.
- Kinship systems define where a person fits into the community binding people together in
relationships of sharing and obligation.
- Set who marries who [skins].
- Defines roles and responsibilities for raising and educating children; provides systems of
moral and financial support.

CEREMONIAL LIFE
- Rites of passage.
- Periodic ceremonies range from enjoying the ceremony to promoting the health and well
being of the whole group.
- Corroboree or ceremonial dance were opportunity for all group members to come together.
- Initiation, death, life cycle.
- Balance rites; food supplies.
- Must be buried in own country.
- Art: is an important way of communicating the dreaming because it illustrates the actions of
the ancestral spirit beings in the land.
- Stories: describe law and lifestyle.
- Rituals: relive activities of ancestor spirits.
- Totems: represent the individual, as they existed in the Dreaming and carry ceremonial
responsibilities.
- Balance of rites: important for hunting, no control over food, responsible to ensure all
requirements of food for group.
- Death and burial rituals: not end of life but final ceremony, believe spirits come back, burial
grounds and spirits held in great fear, the dead must be buried in their own country and sung
 to rest. The body must be able to rest from where it comes so the spirit can return from the
earth it came from.

OBLIGATIONS TO THE LAND AND PEOPLE

- The land and all the forms of life it contains are sacred and must be preserved and passed on
in a timeless cycle of mutual dependence.
- Ritual estate = contains sacred sites.
- A group is responsible for their land.
- In rich environments, they can survive off their own land, however sometimes they may need
to cross into other groups for food.
- Must have permission otherwise they face punishment.
- Each ritual estate has one site left by ancestral beings.
- Elders are responsible for performing relevant rituals.
- Aboriginal people have a strong connection with their land they believe they are one with the
land.

THE CONTINUING EFFECT OF DISPOSSESSION IN RELATION TO:

 Separation from the Land = Loss of cultural heritage

 Separation from kinship groups

- The removal of children not only affected the family but the community as well.
- Children lost a sense of belonging
Never really fit into their surroundings.

 The Stolen Generations = Separation from primary career:

- Cutting off child’s main source of love
- Loss of cultural identity
- Unable to develop values, social skills
- Unable to express opinions, intellectual manner
- Unable to connect a family heritage
- Instability, prevent stable, healthy relationships
- You can’t replace biological parents.

 Mental and Physical health:

- Emotional distress, self-destructive behaviour, addictions, heart disease and diabetes,
psychological damage and emotional numbing

 Undermined parenting skills:

- Children removed experienced difficulties in raising their own children, due to lack of good role
models.
- Strengthened parenting skills
- Fear that their own children would be removed

 Exploitation through work:

- Young children sent to work and indigenous girls – domestic slaves
- Lower wages
- Earnings given to government to be spent on child’s behalf
- Rest of $$ - trust fund until 21 (never received)

 The importance of the Dreaming for the Land Rights movement

- Aboriginal spirituality is founded on the principle that indigenous peoples have an inextricable
connection to the land.
- The declaration made by white settlers that Australia was terra nullius denied these
foundational principals of aboriginal belief systems
- These understandings of the sacred nature of the land underpin all aspects of the Land Rights
movement

OUTLINE THE IMPORTANCE OF THE FOLLOWING FOR THE LAND RIGHTS MOVEMENT:
 Native Title:
- The recognition that aboriginal people who occupy land on which their families have lived
continuously for hundreds of years are the owners of that land.
 - Usually a reference to the rights to use the land but it can also mean the rights to fish in
particular waters.
 Mabo
- The high court of Australia upheld the claim of the Merriam people from the Murray Islands in
the Torres Straight that Australia was not Terra Nullius and that the Merriam people had
continuously inhabited the islands.
- Eddie Mabo V QLD 1992
- To overturn Terra Nullius – land that is uninhabited or that belongs to no one.
- Lead to Native Title Act 1993
- Indigenous people have right to land

 Wik (1996)
- The wik case concerned land that was subject to pastoral leases.
- The high court of Australia decided that native title rights could co exists with the rights of
pastoralists. But when pastoralists and aboriginal rights were in conflict, the pastoralists’ rights
would prevail.

Religious expression in Australia 1945 to the present

 Account for the present religious landscape in Australia in relation to:

– Christianity as the major religious tradition
– Immigration
– Denominational switching
– Rise of New Age religions
– Secularism

Reasons for current landscape:

o People moving from one denomination to another, people seeking answers in new religions or
spiritual movements; an increase in those acknowledges. No religion Law attendance at church
according to National Church Life Survey (2001)
o High attendance in churches of Christ: Baptist, Pentecostal
o Ethnic diversity now in Christian churches esp. Catholic; Italian, Maltese, Vietnamese
o Growth in Hinduism since 1991 reflect immigration of people from an Indian background
o Denominational Switching: moving from one to another with the tradition
Protestants more likely to switch
Pentecostal members stable – greatest switchers in but also equal numbers of switchers out =
drifters
o New Age Religions: not necessarily religious in nature
no divine being or sacred text
no religious hierarchy no obligations
it is a search for understanding, individualization, search for oriented trying to improve self
About the mind, body, soul connection
alternative practices implies harmony, knowing, enlightenment.

Ecumenism:
- When denominations maintain their separate identity but work together for a common cause.
- There have been genuine efforts by the churches to apologies for insensitive activities of the past
and to perform acts of reconciliation.
- Churches are among the most effective advocates for social justice for Indigenous Australians.
- They provide extensive welfare and education programs.

Immigration:
- Immigration restriction act (1901) (the white Australia policy)
- The migrants who were allowed into Australia.
- Migrants were expected to settle into the pre-existing culture and society without causing an
noticeable change: learn English, eat traditionally English style foods and blend in.

OUTLINE CHANGING PATTERNS OF RELIGIOUS ADHERENCE FROM 1945 TO THE PRESENT USING
CENSUS DATA CENSUS FIGURES SHOW DISSATISFACTION WITH TRADITIONAL RELIGIONS.
- Decline in Christian denomination – particularly the larger ones; e.g. Catholic, Anglican, Uniting.
- Increase in the non-catholic faiths – particularly Hinduism, Buddhism.
- Older people identify more with particular religious groups – exception: Pentecostal.
- More identify with a group than actually attend.
- Pentecostal, Churches of Christ have a high percentage of attendance.
 Christianity [Religious Depth Study]

SIGNIFICANT PRACTICES IN THE LIFE OF ADHERENTS: BAPTISM

 Is the sacrament rite that admits a candidate into the Christian Church Community.
 Brings new life think of the symbolism of water – purifying, cleansing, sustaining life
 Basis of the whole Christian life. The door way to other sacraments.
 Through baptism we are freed from all original and future sin and reborn as sons of god.
 Baptism is necessary for salvation
 Is the sacrament of faith which grows after baptism
 We receive the gift of the Holy Spirit at our baptism.
 Blessed in the name of the father and of the son and of the Holy Spirit.
 Baptism seals the Christian with the indelible spiritual mark. That no sin can erase

ELEMENTS OF A BAPTISM
1. Welcome rite
2. Questioning of parents – responsibilities
3. Signing by the priest with the sign of the cross
4. Celebration of the liturgy of the word
5. Exorcism, followed by anointing of the child/adult
6. Blessing of baptismal water
7. Parents renunciation of sin and profession of faith
8. Baptism in the name of the F, S, HS, anointing with oil
9. Clothing, Candles
10. Conclude with lord’s prayer and final blessing

SIGNIFICANT PRACTICE AND THE CHRISTIAN COMMUNITY:

- Baptism is a visible sign of cleansing from sin and personal renewal for the candidate and by
association for the entire congregation.

INDIVIDUALS COMMUNITY SIGNIFICANCE SYMBOLS BELIEFS

- Initiation (body of - Present a baptism - Central to beliefs and - Water - Know the
Christ, Christian (welcome the new ministry of Christianity (cleansing) variants
life, church) adherent to the (opens doorways to - Oil (orthodox,
- Access other rites church) other sacraments) (anointing) Pentecostal,
- Free from sin - Witness and take - Necessary for - White catholic)
- Reborn as a child part in church salvation ( Faith: Act clothing - How the actions
of God activities (Sunday 8:13, Repentance: Act (purity/new link to the beliefs.
- Share in Christian mass and Easter 2:38) life)
heritage (sharing for adults) - Allows participants to - Candle
actions of those in - Sponsors/ participate in (light of
the past; e.g. Godparents (guide life/death/ resurrection Christ)
Jesus’ time) the child in their of Jesus (Romans 6:4)
Christian life) - Form part of body of
Christ (1 Cor 12:13)
- Cleansed from sins (1
Cor 6:11)

ORTHODOX CHURCH
- Initiation (infancy).
- Triple immersion.
- Anointing of forehead, eyes, nostrils, mouth, ears, breast, hands and feet.
- Bread and wine for Eucharist.

PROTESTANT CHRISTIAN
- Initiation (adults).
- Total immersion.
- Only a person who can repent can be ‘born again’.
- Infants ‘who do not understand enough to hold faith in Jesus in their own right’ cannot be
baptized.
 Bioethics
BIOETHICS:
1. The study of the ethical and moral implications of new biological discoveries and biomedical
advances, as in the fields of genetic engineering and drug research
2. Ethics concerned with issues surrounding health care and the biological sciences. These
issues include the morality of abortion, euthanasia, IVF, organ transplants, genetic screening
and the new research in genetic engineering including gene therapy and stem cell research.
3. Ethics that studies the philosophical, social and legal issues arising in medicine and the life
sciences.

CHRISTIAN ETHICAL ISSUES

- Honoring God’s image – [Genesis 1:26-17]; one must consider God’s wisdom and power in
the creation of the mankind.
- Prevention of Suffering – [Acts 10:38, Luke 9:2]; when it comes to embryonic stem cell
harvesting as the embryo is in fact destroyed when the transfer takes place.
- Freedom of choice – People who care capable of making their own decisions should be free to
do so. In the case of euthanasia, all decisions must be made with due consideration for the
common good.
- Stewardship of Creation – [Genesis 1]; Exploitations and manipulations that would destroy
natural balance or degrade God’s created world should be prohibited.
- Human Dignity – [Genesis 1:27, Acts 17:28] – should not be reduced to scientific
investigation only. People (despite their life stage) should be treated with respect for their
individual qualities.
- Healthfulness [1 Corinthians 10:31] – Christians have a responsibility to maintain the health
of their bodies.

Stem Cells
Every organ, tissue and cell has stem cells. The stem cell is the main trunk from which specialized
cells develop. They are able to divide and self renew, they could regenerate the entire organ from a
few cells. Stem Cells may be used to repair or replace damaged tissues – reversing diseases and
injuries such as cancers, heart disease and blood disease

STEM CELL RESEARCH

- Human life begins at fertilisation.
- The sperm from a human male and the ovum from a human female unite to give rise to a
new living human being – a human embryo.
- No therapies in humans have ever been successfully carried out using embryonic stem cells.
- Ethical issues:
- In Australia, legislation states that no embryo may be created for the purpose of this
research or to generate stem cell lines.
- Research Involving Human Embryos Act 2002 (Cth) – allows for regulate use of an
appropriate number of excess embryos in approved search programs.
- In Australia, all research involving humans must be approved by Human research Ethics
Committees.

HUMAN EMBROYS
- Human embryos are a rich source of stem cells.
- Able to differentiate into all types of cells.
- Capable of becoming a more specialised type of cell, e.g. nerve cell, skill cell, etc.
Advantages: Flexible – potential to make any cell; Immortal – endless supply of cells;
Availability – from IVF clinics.
- Disadvantages: likely to be rejected; Tumorigenic; Destruction of developing human life.
- Use human embryos for:
- ‘cell-based’ therapies – replace or heal damage tissues.
- study the development of diseases.
- test drugs or trial new methods of reproductive technology.
- train laboratory technicians.
- New life-saving treatments – death-dealing to the human embryos.

ADULT STEM CELLS

- Divide to replenish dying cells and regenerate damaged tissues.
- Found in children, adults and umbilical cord blood.
 - Advantages: Not experience immune rejection, ease of procurement, non-tumorigenic and no
harm done to donor.
- Disadvantages: Limited quantity, not live as long and less flexible.
- Adult stem cells shown to help more than 70 medical conditions, including Parkinson’s
disease, spinal cord injury, blood diseases and heart damage.
CATHOLIC
SUPPORTS:
- Research and treatments involving
VEPERSPECTI
bone marrow.
- Ongoing research into the use of adult
stem cells.
- Adult stem cell research and therapies
are approved because they do not
destroy life and may provide cure or
improved quality of life for the infirm.
OPPOSED:
- Research using embryonic stem cells
that have been obtained through
standard in-vitro fertilisation
procedures.
- Research using embryonic stem cells
that may in the future be created by
cloning.
- Every human being is precious from
the very beginning of his or her life,
until natural death.
- Human life and dignity should never
be exploited or harmed for the sake of
science.
- Science does not have to kill in order
to cure.
Biblical references:
- Jeremiah 1:5 – “Before I formed you
VIDENCEQUOTES/E
in the womb I knew you, and before
you were born I consecrated you”.
- Exodus 20 – The Ten Commandments
“You Shall not Kill”.
Church Documents:
- Donum vitae I, I – “Human life must
be respected and protected absolutely
from the moment of conception…”
- Domun vitae I, 5 – “It is immoral to
produce human embryos destined to be
exploited as disposable ‘biological
material’”.
ANGLICAN
SUPPORTS A):
- Adult stem cell research and the use of the
therapies that my result.
- The Bible is the principle source of ethical
teaching.
- For and against stem cell research may
use the same biblical text to explain their
stance.
SUPPORTS B):
- Embryonic stem cell research uses a 14
day post-fertilisation criteria.
- Creation, cultural or dominion mandate of
Genesis 1:26-28.
- God has called us to play God, using IVF to
help people have babies and using
embryonic stem cells and genetic research to
heal people and shape humanity’s future.
- Humanity is often seen as co-creator with
God in this example.
OPPOSED B):
- Stem cell research on the basis that it is
never permissible to do wrong (destroy the
life of the embryo) in order that good for
some may result.
- “For God knows that when you eat of it
your eyes will be opened, and you will be
like God, knowing good and evil” [Genesis
3].
- Emphasises that humanity is not to play
God – choosing whose life to save or not and
interfering with the natural order.
Provincial Synod:
IN-VITRO FERTILISATION (IVF)
- Egg cells are fertilised by sperm outside the woman’s womb.
- Removing ova (eggs) from the woman ovaries and letting sperm fertilise them in a fluid
medium. Fertilised egg (zygote) is then transferred into the patients uterus.
- Ethical Issues:
- Bypassing the natural method of conception
- Life in a laboratory
- Fertilization of more embryos than will be needed
- Discarding of excess embryos
- Unnatural environment/substances
- Keeping them in limbo – freezing them
- Destruction of embryos in research
- Create embryos for medical purposes

CATHOLIC
- Opposed to most kinds of in-vitro
fertilisation.
- The use of excess embryos and their
PERSPECTIVE destruction are opposed due to the rights
embryos receive as the earliest stage of life.
Catechism Of The Catholic Church:
2375 – “Research aimed at reducing human
sterility is to be encouraged”.
2376 – “… dissociation of husband and
wife…”
QUOTES/ 2377 – “…They dissociate the sexual act
EVIDENCE from the procreative act…”
Church Documents:
Donum vitae II – “…voluntary destruction of
human embryos occurs too often.”
ANGLICAN
- Differs depending on the diocese.
- The Bible tells of God’s work in
assisting infertile couples to
conceive (e.g. Abraham). Some
fundamentalists interpret IVF as
intervening on God’s behalf and
therefore approve of the use of IVF
in God’s creation.
Anglican Primate, Peter Carnley, in
2002:
- Concern over the loss of fertilized
ova.
- Conception does not occur due to
a nature or God-given reason.
- We are co-creators with god
through IVF and stem cell
research.
- Condemning the use of IVF for
same sex couples.
- The right of the child to have a
mother and a father.

Donum vitae II, 4 – “… deprived of the

meaning and the values which are expressed
in the language of the body and the union of
human persons”.

CLONING
- Precise genetic copy of a molecule, cell, plant, animal or human being is created.
- Reproductive cloning – is the creation of a clone for the purpose of allowing it to progress to
the birth of a living child.
- Therapeutic cloning – creates a clone and then destroys it at an early stage in order to
harvest embryonic stem cells from it or to use it to produce medicines or for research.

CATHOLIC
- Strongly opposed to any form of human cloning.
- Links to stem cell research – the creation of the embryos for the purpose of
PERSPECTIVE experimentation and their destruction are immoral acts.
- Right to be born of a father and mother.
- Separate the reproductive act from the sexual act is morally unacceptable.
 Donum vitae I, 4 – “Medical research must refrain from operations on live
embryos, unless there is a moral certainty of not causing harm to the life of
integrity of the unborn child and the mother…”
QUOTES/
EVIDENCE Pope John Paul II – “…manipulation and destruction of human embryos, are not
morally acceptable…”

“None of us lives to himself, and none of us dies to himself… in life and death we
are the Lord’s” [Romans 14:7-9]

PERSPECTIVES:
ANGLICAN PROTESTANTS PRESBYTERIANS ORTHODOX
- Condemns human cloning. - Same views on - Generally - No situation in
cloning as the disapprove all which cloning human
Provincial Synod: Catholic Church. forms of cloning. beings would be
“… the creation of a human life, acceptable.
either by fertilisation or by any - An attempt to
other means of creation for the create human beings
purpose of destroying that life in in man’s image
research fails to recognise the rather than God’s.
value and purpose God assigns to
human life…”

EUTHANASIA
 Euthanasia: is doing something (giving a fatal injection) or not doing something (not giving
necessary medicine, food or fluids) with the intention of killing another human person, in order
to end his or her suffering.
 Voluntary Euthanasia: is the killing of a patient at their request
 Involuntary euthanasia: the killing of a patient against their will
 Non voluntary euthanasia: the killing of patients who are unable to give consent to be killed
 Assisted suicide: helping someone to kill him/her self.
 Passive euthanasia: the withholding of common treatments or the distribution of a medication to
relive pain, knowing that they may result in death.
 Non aggressive euthanasia: withdrawal of life support

CATHOLIC ANGLICAN
 No support  No support
 “You shall not kill” 5th commandment  Life is a gift of god not to be
 It is I who bring death and life – taken, and is therefore not
PERSPECTIVE Deuteronomy 32:39 subject to matters such as
 Every human life has dignity. Life can freedom of choice.
never be deliberately destroyed
 The church teaches that euthanasia is a
grave violation of the law of god.
1. The system that defines relationships
between members of Aboriginal societies is
known as:
a) Territory
b) Kinship
c) Country
d) Totem
2. Indigenous Australians acknowledge a
______________ in their relationship to the
land.
a) Treaty
b) Ownership
c) Dependence
3. The sophisticated network of relationships
that is the tangible expression of Dreaming
within Aboriginal societies is:
a) Country
b) Kinship
c) Myth
d) Totem
4. The first official policy after European
settlement concerning the place of the
Indigenous people in Australia was:
a) Protection
b) Assimilation
c) Self-determination
d) Expansionism
5. The term 'stolen generations' has been
used to describe:
a) The adoption of convict children by
Indigenous families.
b) The forced separation of Indigenous
children from their families.
c) The imprisonment of Aboriginal
elders.
d) The land rights campaigns of the
1970s.
6. The landmark judgment that acknowledged
the existence of Native Title in Australia was:
a) The Native Title Act 1993
b) The Mabo decision, 1992
c) The Yirrkala Petition, 1963
d) The Wik decision, 1996
7. When was the Aboriginal Embassy (or 'tent
embassy') first erected on the lawns of
Parliament House in Canberra?
a) 1976
b) 1972
c) 1966
d) 1980
8. A major reason for the steep climb in
numbers of Australians affiliating themselves
with no religion in census statistics since 1971
is:
a) The provision of an 'other' category.
b) The prevalence of 'new age'
religions.
c) The introduction of the instruction, 'if
no religion, writes none'.
d) A decrease in spiritual affiliations.
9. What observations about religion in
Australia are revealed by the National Church
Life Survey that is not found in census data?
a) Accurate data about what
Australians believe.
b) Attendance and age profile data for
the various Christian denominations.
c) The numbers of people adhering to
traditions other than Christianity.
d) The numbers of religious Jews in
Australia.
10. 'Denominational switching' refers to the
movement of adherents between Christian
churches. Which of the following churches has
the greatest number of 'switchers' in?
a) Methodist
b) Jehovah's Witness
c) Catholic
d) Pentecostal
11. An example of an interfaith initiative is:
a) The formation of the Uniting Church
b) The Council of Christians and Jews
c) The National Council of Churches in
Australia
d) The Salvation Army
12. Which of the following is an example of
the changing relationship between Indigenous
peoples and churches in Australia?
a) The complete acceptance of
Christianity by Indigenous Australians
b) The incorporation of Aboriginal
ministers in mainstream churches
c) The division of Indigenous spiritual
practices and those of the mainstream
churches
d) The assimilation of Indigenous
spirituality by the Christian churches
13. Aboriginal people believe that death is the
end of life.
a) True
b) False
14. The sacredness of the land for Aboriginal
people is derived from the amount of food it
can supply to sustain a community.
a) True
b) False
 15. The policies of Australian governments 25. Immigration after the Second World War
with regard to Aboriginal people developed led to an increase in affiliates of the
over time in this order – protection, _________ churches.
assimilation, integration, self-determination. a) Protestant
a) True b) Pentecostal
b) False c) Orthodox

16. Recognition of Native Title has enabled all 26. The question on religion in the census is
Aboriginal peoples to make land claims. _________.
a) True a) mandatory
b) False b) suggested
c) not compulsory
17. Immigration after the Second World War
brought new religious traditions to Australia 27. The ________________ is the third
but had little impact on the Christian largest religious community in Australia.
denominations. a) Anglican Church
a) True b) Catholic Church
b) False c) Uniting Church

18. The Uniting Church in Australia was an 28. In what way is the use of the land
ecumenical initiative that unified the different in Aboriginal societies as opposed to
Methodist, Presbyterian and Congregational European land uses?
Churches in 1977. a) They share the same understanding.
a) True There is no difference.
b) False b) Aboriginal societies are concerned
with the ritual responsibilities for the
19. The relationship between Christianity and land, as opposed to the rights to use
Indigenous spirituality is often problematic. and occupy the land.
a) True c) Aboriginal societies acknowledge no
b) False land boundaries.
d) The Aboriginal concept is one of
20. Ecumenism and Interfaith dialogue are the exclusive ownership whilst the
same concept. European idea is concerned with rights
a) True and responsibilities for the land.
b) False

21. The New Age phenomena can be ANSWERS:

characterised by an interest in the body and 1. B 2. C 3. B 4. A 5. B 6. B 7. B
experience, objects and rituals. 8. C 9. B 10. D 11. B 12. B 13. B
a) True 14. B 15. A 16. B 17. B 18. A 19. A
b) False 20. B 21. A 22. A 23. A 24. A 25. C
26. C 27. C 28. B
22. Catholics tend to be more
denominationally loyal than their Protestant
counterparts.
a) True
b) False

23. Aboriginal kinship systems define where a

person fits into the community, binding people
together in relationships of
___________________.
a) sharing and obligation
b) education and learning
c) giving and taking

24. The doctrine of terra nullius was ruled to

be a legal ________ by the High Court of
Australia in 1992.
a) fiction
b) mistake
c) fact