19 July 2025

Procedure

In Re Thorpe [2025] VSCA 172 the Court states 

 In October 2023, Uncle Robbie Thorpe (‘the applicant’) sought to file a charge sheet and summons in the Magistrates’ Court of Victoria naming King Charles III as the accused and alleging that he had committed ‘continuing acts of genocide ... against First Peoples’. The Magistrates’ Court refused to issue the summons and did not initiate a proceeding. 

By originating motion filed in the Trial Division on 7 March 2024, the applicant sought judicial review of the Magistrates’ Court decision. A trial was conducted on 19 July 2024 and on 5 February 2025 Richards J handed down her judgment. Her Honour held that the charge sheet did not disclose an offence known to law and that the Magistrates’ Court was correct to refuse to issue the proposed proceeding. 

An application for leave to appeal from a decision of Richards J to refuse to accept an affidavit for filing was refused by McLeish JA on 2 August 2024. 

The applicant has since filed an application for leave to appeal Richards J’s decision. He has also filed various applications other than for leave to appeal, which are voluminous and overlapping. Some of these additional applications have been accepted for filing. However, the Registrar refused to accept for filing four of the applications, pursuant to r 64.43 of the Supreme Court (General Civil Procedure) Rules 2015 (the ‘Rules’). Together these four applications seek more than 15 different orders, including orders for the joinder of additional parties, orders concerning intervenors, orders concerning the identity or racial background of the judges who are to hear his applications, and other orders concerning the conduct of the proceedings. 

The applicant now seeks to have a Judge or Judges of Appeal direct the Registrar to accept for filing the four applications that were refused, pursuant to r 64.43(5) of the Rules. 

For the reasons that follow, we will not direct the Registrar to accept the four documents for filing. ... 

The issue in this case is whether the documents fall within r 64.43(1) or (2) — that is, whether: (1) they are irregular (r 64.43(1)(a)); (2) they are frivolous or vexatious on their face or by reference to any materials already filed or submitted for filing (r 64.43(1)(b)); (3) the filing of them would give rise to an abuse of the process of the Court (r 64.43(1)(c)); (4) they do not comply with the Rules or the requirements of any applicable practice note (r 64.43(2)(b)); and/or (5) they are not accompanied by all the documents required by O64 or any applicable practice note (r 64.43(2)(d)). 

Consideration 

In our opinion the four documents that have not been accepted for filing are irregular, and/or frivolous or vexatious on their face and by reference to other materials that have been filed or submitted for filing, and/or would give rise to abuse of process. In addition, some of the documents do not comply with the applicable rules or a practice note, or were not accompanied by all the required documents. 

Document 495374 

As noted above, document 495374 seeks 13 orders (set out in the annexure to these reasons). Many of these orders are not orders that the Court can or would make. In light of that fact, it was appropriate for the Registrar to refuse to accept the document for filing, even if some of the other orders sought might have been orders that the Court can or would make. It is thus necessary only to identify some examples of entirely inappropriate orders in order to make clear that the Registrar was correct not to accept the document for filing. 

Proposed order 1 is that ‘Chief Justice Niall has conduct of these proceedings and this court file’. 

This is not a suitable order to be made by the Court of Appeal on the motion of a party. A party has no entitlement to seek to have an identified judicial officer conduct a proceeding. Nor would a judge or judges of the Court of Appeal make such an order. The application for this order is frivolous, vexatious and irregular. 

Proposed order 2 is that a ‘bench of five Aboriginal judicial officers be assembled to hear the application for leave to appeal and the appeal’. 

Again, this is not a suitable order to be made by the Court of Appeal on the motion of a party. A party has no entitlement to seek to have a bench of a particular size or composition hear a proceeding. Nor would a judge or judges of the Court of Appeal make such an order. The application for this order is frivolous, vexatious and irregular. 

Proposed order 3 is as follows: If there are not sufficient Aboriginal judicial officers in the Supreme Court of Victoria to assemble a bench of five Aboriginal judicial officers, then Chief Justice Niall to write to and seek to meet with the Attorneys-General of the State of Victoria and the Commonwealth of Australia to request the special appointment of sufficient Aboriginal judicial officers including the appointment of (i) Professor Irene Watson, Research Professor of Law, University of South Australia, and (ii) law graduate Dr Jaqui Katona , Moondani Balluk Indigenous Unit, Victoria University, and (iii) lawyer Paul Coe (iv) lawyer Michael Mansell (v) puralia meenamatta (“Uncle Jim Everett”), the Palawa man from the clan plangermairreenner (vi) Dr Aunty Mary Graham, Kombumerri and Hakka Wakka, Adjunct Associate Professor, University of Queensland — six names listed here in case of illness or other unavailability on the hearing dates. 

It is plain that this Court cannot order Niall CJ to take the step sought. The application for this order is frivolous, vexatious and irregular. 

Proposed order 10 is as follows: The Magistrates Court of Victoria is directed to retain counsel and participate properly in these proceedings as a normal party and respondent. 

Again, it is plain that this Court cannot make an order in such terms directed to the Magistrates’ Court of Victoria. The application for this order is frivolous, vexatious and irregular.

In Thorpe v Magistrates' Court of Victoria [2025] VSC 22 the headnote notes that Thorpe sought to file a charge-sheet and summons in the Magistrates’ Court of Victoria to commence private prosecution against King Charles III for crimes of genocide under First Peoples’ sovereign laws, the common law, and div 268 of the Criminal Code Act 1995 (Cth) 

The judgment states

On 20 October 2023, Uncle Robbie Thorpe sought to commence a private prosecution against King Charles III for crimes of genocide. He did so by filing a charge-sheet and summons in the Magistrates’ Court of Victoria, naming himself as the informant and Charles Phillip Arthur George Windsor as the accused. The offences alleged in the charge-sheet were continuing acts of genocide against First Peoples, contrary to First Peoples’ sovereign laws, the common law of Victoria, and div 268 of the Criminal Code Act 1995 (Cth). 

On 29 December 2023, a senior registrar of the Magistrates’ Court refused to issue the proceeding, on the basis that the proper source of law had not been particularised and the proposed accused may be misled or prejudiced by this omission, and in those circumstances the issue of the proceeding would be an abuse of process. The proceeding was therefore returned unissued. 

In this proceeding, Uncle Robbie seeks judicial review of the Magistrates’ Court’s decision. He seeks an order requiring the Magistrates’ Court to accept the charge-sheet and summons for filing and issue the summons. ... 

At a directions hearing on 22 April 2024, I ordered that the Attorney-General of Victoria be joined as second defendant to the proceeding, on the basis that as the first law officer of the State of Victoria, her presence was necessary to ensure that all questions in the proceeding are effectually and completely determined and adjudicated upon. The Attorney-General subsequently filed written submissions and briefed Crown Counsel to appear at the trial of the proceeding on 19 July 2024. 

At the trial, Uncle Robbie applied for me to disqualify myself from further conduct of the proceeding. I refused that application, and provide my reasons for that decision below. 

In the course of his submissions at trial, Uncle Robbie challenged the legal foundation of the State of Victoria, in light of the widely acknowledged truth that the sovereignty of the First Peoples of Victoria was never ceded. He questioned the legitimacy of the Court’s jurisdiction, given the High Court’s rejection of the fiction of terra nullius and the previous use of that fiction to justify the Crown’s acquisition of Victoria. These large and important questions are currently being considered by the Yoorrook Justice Commission, and have prompted the Victorian Government to commence treaty negotiations with Victoria’s First Peoples. 

While acknowledging the significance of the questions raised by Uncle Robbie, the only jurisdiction that I can exercise is the jurisdiction of this Court. I can only do that by applying the law of the State of Victoria to the questions for determination in this proceeding. 

For the reasons that follow, I have concluded that the Magistrates’ Court was correct to refuse to issue the proposed proceeding. The charges alleged in the charge-sheet did not disclose an offence known to the law of Victoria. 

The proceeding must therefore be dismissed. 

Disqualification application   

By summons filed 15 July 2024, Uncle Robbie sought orders including an order that I be disqualified from further conduct of the proceeding. The basis for this application was set out in his accompanying affidavit, as follows: (a) In my decision of Re Thorpe (No 2), I had quoted his submissions in full while making no comment about ongoing Aboriginal genocide and injustice to Aboriginal people at the hands of non-Aboriginal people. This amounted to ‘white denial’ that Aboriginal people would perceive as bias; (b) I am not Aboriginal; (c) There are no documents evidencing that I have accepted that Aboriginal sovereignty has never been ceded and that Aboriginal law is the only true law of this land; (d) I have publicly sworn allegiance to the monarchy, and have not publicly repudiated the Windsor family as genocidal invaders; (e) Consequently, I am reasonably likely to be perceived by Aboriginal peoples and others as biased against Aboriginal peoples. 

The Attorney-General opposed the application, saying that the circumstances relied on by Uncle Robbie did not give rise to a reasonable apprehension of bias. 

A judge is disqualified from hearing a case if a fair-minded lay observer might reasonably apprehend that the judge might not bring an impartial mind to the resolution of the questions for decision in the case. Applying this test involves first identifying what it is said might lead the judge to decide the case other than on its legal and factual merits, and then articulating a logical connection between that matter and the fear that the judge might not decide the case on its merits. The final step in the analysis is assessing the reasonableness of the asserted apprehension of bias.

At the same time, judges are obliged to hear cases assigned to them in which the Court’s jurisdiction has been regularly invoked. Judges ‘do not select the cases they will hear, and they are not at liberty to decline to hear cases without good cause’. In this case, which has been assigned to me to hear and determine, Uncle Robbie has regularly invoked the judicial review jurisdiction of the Supreme Court of Victoria. 

On my appointment to the Court, I pledged allegiance to Her Majesty Queen Elizabeth II and her heirs and successors according to law. I also took the affirmation of office as a judge, to discharge the duties of my office according to law, without fear or favour, affection or ill-will. 

The Court’s jurisdiction is conferred by the Constitution Act 1975 (Vic) and is recognised in ch III of the Commonwealth Constitution. The law to be applied by a judge of the Court is the law of the State of Victoria, in accordance with Victoria’s Constitution Act and the Commonwealth Constitution. 

I do not accept Uncle Robbie’s assertion that pledging allegiance to the Crown and taking the affirmation of office might give rise to a reasonable apprehension that I might not decide this judicial review proceeding on its merits. These promises are essential to the office of a judge of the Supreme Court of Victoria, and have been made by every judge of this Court. One of us must hear and determine the case that Uncle Robbie has brought, and it has been allocated to me.;

17 July 2025

ANAO data governance

The ANAO Governance of Data report states 

Data is any information in a form capable of being communicated, analysed or processed (whether by an individual, a computer or other automated means). Data becomes valuable when it is processed and analysed to extract meaning, leading to insights, decisions or predictions. Governance of Data considers structured data that is measurable, such as a set of observations organised into a table, spreadsheet or database — in contrast to unstructured data that cannot be easily measured, such as records of meeting minutes. 

Data is a valuable asset of every Commonwealth entity, as it underpins informed decision making, efficient and effective business operations and public accountability. This means entities should invest in its governance, quality, security and ethical use to ensure data is trusted, protected and used to drive measurable results and outcomes for citizens. 

Effective governance of data is critical to realising and maximising the economic, social and environmental benefits of data. This includes securely, safely, lawfully and ethically sharing data with other public sector jurisdictions, in accordance with the Intergovernmental Agreement on data sharing between Commonwealth and State and Territory governments. Good data governance is also necessary to meet legislative obligations and policy. 

Through its audit work, the ANAO has observed good practices and fundamental deficiencies in the governance of data across multiple entities. Governance deficiencies have resulted in weaknesses to data integrity (reliability and verifiability), which impacts business processes and can result in reduced capability to make informed decisions, meet reporting requirements and achieve business objectives. Good data governance is essential in analytics, artificial intelligence (AI) and machine learning , to ensure ethical use of data, including avoiding bias in AI models. 

Benefits of good data governance

  • Improved capability to achieve business outcomes. 

  • More robust evidence base for improved decision making and increased public trust. 

  • More consistent, coordinated, accessible and timely services. 

  • More informed policy development and decision-making. 

  • Better reporting and assurance to the Parliament. 

  • Improved information exchange and transparency. 

  • Greater operational efficiency and cost-effectiveness. 

  • Reduced impact of machinery of government and other business continuity changes. 

  • Better understanding and management of regulatory and other risks. 

  • Compliance with legislative requirements, including privacy. 

  • Increased physical, information and personnel security.

Commonwealth legislation and policy on data governance 

  • Privacy Act 1988 - Outlines obligations to protect the identity of individuals an entity holds data about, and the ethical handling of this data. 

  • Data Availability and Transparency Act 2022 - Authorises Australian Government entities to make data assets discoverable and to share data with accredited individuals and organisations, provided certain conditions are met. 

  • Freedom of Information Act 1982 - With some exceptions, provides the public the right to access government held information, including government policies and decisions. 

  • Protective Security Policy Framework - Sets out what Australian Government entities must do to protect people and information assets.

Also relevant are the:

  • Archives Act 1983, which makes National Archives of Australia responsible for identifying the archival resources of the Commonwealth (that is, Commonwealth information of enduring value), and preserving and making publicly available the archival resources of the Commonwealth; 

  • National Archives of Australia’s Building trust in the public record policy, which identifies key requirements for managing Australian Government information assets, including records, information and data; and supports improvement in performance management of public sector data and the use and reuse of data; 

  • the Department of Finance’s Data Ethics Framework, which provides Australian Public Service (APS) guidance on ethical use of public data and analytics; 

  • the Australian Public Service Commission’s APS Data Capability Framework, which outlines 26 data-specific capability areas associated with working with data in the APS; and 

  • the Digital Transformation Agency’s Framework for the Governance of Indigenous Data, which aims to provide Aboriginal and Torres Strait Islander people greater agency over how their data is governed within the APS so government-held data better reflects their priorities and aspirations. 

Whole-of-government data strategy 

Launched in December 2023, the Australian Government’s Data and Digital Government Strategy (the Strategy) aims to provide a blueprint for the use and management of data and digital technologies by the APS through to 2030. The Strategy recognises data as a valuable national asset in realising Australia’s economic and social objectives, and in improving the evidence-base for government policy decisions, with a goal of better outcomes for all people and business. 

To support implementation of the Strategy, and to help entities self-assess their data maturity over time, the Department of Finance developed the Data Maturity Assessment Tool (DMAT). The self-assessment enables entities to: track their data maturity progress over time; identify data management strengths and weaknesses; and improve their ability to meet reporting obligations for promoting accountability and public trust.

The report features 'Questions for reflection'  

Lesson 1: Value data as an asset

  • Does our entity have a culture that values curiosity, evidence and learning from data? 

  • Does our entity have leadership commitment, including a sole authority (Chief Data Officer or equivalent data leadership role) responsible for all entity data and for fostering a culture that values data? 

  • Does our entity consider from the outset what data is required to achieve business objectives? Does our entity collect and use data with a purpose, such as for evidence-based policy, and to evaluate and measure performance? 

  • Does our entity select and design systems based on the required data outputs? 

  • Does our entity have clear methodology documentation (such as standard operating procedures and workflows) that enables users to easily locate required data at any point in a process? 

  • Does our entity have appropriate controls in place to assure the integrity of data, such as regular data checks and sign off by senior staff certifying data quality and integrity? 

  • Does our entity uplift staff data capability through learning? 

  • Does our entity regularly assess its data maturity, such as by using the Data Maturity Assessment Tool?

 

Lesson 2: Develop an information governance framework and data strategy  

  • Does our entity have an information governance framework and a data strategy? 

  • Does our entity’s information governance framework provide broad oversight of our organisation’s data assets and data management approach to achieve business goals? 

  • Does our entity’s information governance framework set out drivers for data, such as

    • legislation, risk and business needs? 

    • the environment within which data is created and/or captured, collected and managed? 

    • the principles that guide data design, capture, management and use? 

    • roles and responsibilities, including leadership, as they relate to data? 

    • consistent understanding and use of data across systems within the organisation and with other entities? 

    • controls to protect against risks to data and to preserve the integrity of data? 

    • how ethical considerations are embedded into data and AI policies? 

    • senior management commitment to uphold data governance? 

  • What actions does our entity take to embed information governance into its culture, such as training and guidance for staff? 

  • Does our entity’s data strategy align with our organisation’s information governance framework, with greater detail on the approach to data creation, capture, collection, management and use of data? 

  • Has our entity considered the Office of the National Data Commissioner’s Foundational Four in establishing data governance and an enterprise-wide data strategy? 

  • Has our entity integrated AI into our information governance framework and data strategy to ensure responsible and secure AI use and alignment with business objectives? 

  • Does our entity regularly review and evolve our information and data framework and strategy? If applicable, does our entity meet the requirements of the Policy for the responsible use of AI in government?

Lesson 3: Establish data leadership and define roles and responsibilities

  • Does our entity have an established data leader and defined data team roles and responsibilities? 

  • Does our entity refer to the SES Accountabilities for Data guidance to establish data roles and responsibilities? 

  • Does our entity have a Chief Data Officer or equivalent who is accountable for enterprise-wide governance and use of data as an asset within the entity, and building entity data capabilities? 

  • Does the role of our entity’s Chief Data Officer or equivalent align with the Chief Data Officer Information Pack? 

  • Does our entity hold SES staff accountable for the proper use of government data within their areas of business responsibility? Does our entity clearly document data roles and responsibilities?

Lesson 4: Document data methodology with data processes mapped end-to-end

  • Does our entity document data methodology with processes mapped end-to-end? 

  • Does our entity classify and categorise data to make it more discoverable and useful? 

  • Does our entity document data sources and systems? 

  • Does our entity document end-to-end processes? 

  • Does our entity manage entire data lifecycles (using the Data Maturity Assessment Tool or the Data Lifecycle View outlined in the APS Data Capability Framework)? 

  • Does our entity implement quality standards and assurance processes? 

  • Does our entity implement auditing and monitoring practices? 

  • Is our entity’s documentation clear and sufficiently detailed to support business continuity and mitigate risks such as loss of knowledge through staffing changes?

Lesson 5: Strengthen assurance over third-party data

  • Does our entity have strong assurance over any third-party data? 

  • Does our entity clearly understand how third parties collect data? 

  • Does our entity have assurance over the quality and integrity of third-party data? 

  • Does our entity implement appropriate controls to identify, mitigate and address data risks? 

  • Does our entity integrate data reporting obligations as part of formal arrangements, such as contracts or grants management agreements? 

  • Does our entity conduct regular due diligence, such as provider risk assessments and audits? 

  • Does our entity integrate third-party data into existing data governance frameworks (e.g. through validation checks, access controls and monitoring)? 

  • Does our entity obtain control reports on the effectiveness of third-party systems, including their reliability and data security measures?