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Bourke's proclamation implemented the doctrine of terra nullius by proclaiming that Indigenous Australians could not sell or assign land, nor could an individual person acquire it, other than through distribution by the Crown.
The 1835 proclamation by Governor Richard Bourke implemented the doctrine of "terra nullius" upon which British settlement was based, reinforcing the concept that there was no prior land owner to British possession and that Aboriginal people could not sell or assign the land, and individuals could only acquire it through distribution by the Crown.
One of his most celebrated roles was that of senior counsel in the Mabo case, which abolished the doctrine of terra nullius and recognised Aboriginal land rights in Australian law for the first time.