Elizabeth Evatt, Nisuke Ando, Marco Tulio Bruni Celli and Vojin Dimitrijević filed a concurrence stating that the term "minority" shouldn't be interpreted "solely on the basis of the number of members of the group in question in the State party".
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During 1996, the Honourable Elizabeth Evatt AC carried out a comprehensive review of the Australian Government's then Aboriginal and Torres Strait Islander Heritage Act 1984 (Cwlth), and, in the process reviewed the Aboriginal heritage protection arrangements of each State.
She was still the only female judge in South Australia when she retired 18 years later in 1983 although Justices Elizabeth Evatt and Mary Gaudron had been appointed to federal courts by the Whitlam Government.