Deanna Davy


Australia is a wealthy country; however, available evidence suggests that food security among Aboriginal and Torres Strait Islander peoples has not yet been achieved. Aboriginal and Torres Strait Islander peoples living in remote, regional, and urban parts of Australia experience food insecurity for a number of reasons that usually include low income and a lack of access to affordable and healthy food. The much higher rate of illness and disease that this population experiences compared to non-indigenous Australians is directly related to food insecurity. This paper examines the food insecurity among Aboriginal and Torres Strait Islander peoples and recent Australian government efforts to combat this problem. The paper first considers what constitutes a human rights-based approach to achieving food security. Second, it describes the food insecurity that currently exists among Aboriginal and Torres Strait Islander peoples across the three pillars of food access, food availability, and food use. Third, the paper critically examines recent and current Australian government policy aimed at improving food security. The paper concludes with some reflections regarding how the Australian government can improve its efforts to achieve food security for Aboriginal and Torres Strait Islander peoples.


Available evidence suggests that food security for Aboriginal and Torres Strait Islander (ATSI) peoples in Australia has not yet been achieved. ATSI peoples living in remote, regional, and urban parts of Australia are vulnerable to food insecurity for a range of reasons that tend to include poverty, low income or welfare dependence, and a lack of access to affordable and healthy food. Food insecurity among ATSI peoples has a long history that began with the colonization of Australia and today is exacerbated by government policy interventions and economic influences.1 The much higher rate of illness and disease that ATSI peoples experience compared to non-indigenous Australians is directly related to food insecurity and is a clear consequence of the barriers related to food availability, access, and use faced by ATSI peoples. There is an unacceptable food-related health gap between ATSI peoples and non-indigenous Australians, revealing an urgent need to improve food security for ATSI peoples throughout the country.

This paper examines food insecurity among ATSI peoples, as well as Australian government efforts, particularly since the early 2000s, to improve their situation. The paper first considers what constitutes a human rights-based approach to achieving food security. Second, it describes the current food insecurity among ATSI peoples in Australia. Third, the paper critically examines recent and current Australian government policy in the area of food security for ATSI peoples. The paper concludes with a discussion of key points and reflects on the way forward for improving food security among ATSI peoples in Australia.

A human rights-based approach to food security

Undertaken under the auspices of the United Nations (UN) Food and Agriculture Organization (FAO) is the recent elaboration of a set of voluntary guidelines outlining key elements of an “enabling environment” for food security.2 The guidelines seek to promote a rights-based approach to food security at the national level that emphasizes “human rights, the obligations of States and the role of relevant stakeholders.”3

As the guidelines point out, a human rights-based approach to food security underscores “universal, interdependent, indivisible and interrelated human rights.”4 Such an approach emphasizes the achievement of food security as an outcome of the realization of existing rights. It includes the principles of individual agency, public participation in decision making and public affairs, the right to freedom of expression, and the right to seek and receive information, including in relation to decision making about policies on realizing the right to adequate food. The guidelines also point out that a human rights-based approach to achieving food security “should take into account the need for emphasis on poor and vulnerable people who are often excluded from the processes that determine policies to promote food security and the need for inclusive societies free from discrimination by the State in meeting their obligations to promote and respect human rights.”5 Under a human rights-based approach to food security,

[p]eople hold their governments accountable and are participants in the process of human development, rather than being passive recipients. A human rights-based approach requires not only addressing the final outcome of abolishing hunger, but also proposing ways and tools by which that goal is achieved. Application of human rights principles is integral to the process.6

Thus, a human rights-based approach to food security involves the active participation of people in determining the best approaches for ensuring equitable food security. It is an approach that highlights individual agency in decision making and the involvement of people in their government’s affairs. When applied to the Australian context of achieving food security for ATSI peoples, a human rights-based approach emphasizes the importance of acknowledging the interrelatedness of key rights, of recognizing the agency of ATSI peoples, and of engaging these peoples, who are often excluded from government decision-making processes, in determining policies and approaches to improve food security.

Food insecurity among ATSI peoples in Australia

According to the Australian Bureau of Statistics, 713,600 of Australia’s 23 million people are indigenous.7 Thus, indigenous Australians represent approximately 3% of the country’s population. Of the indigenous population, approximately 90% self-identify as Aboriginal, 6% as Torres Strait Islander, and 4% as both Aboriginal and Torres Strait Islander.8 The Northern Territory, a vast state covering 1.3 million square kilometers in the north of the country, has the highest percentage of indigenous people, with 29.7% of the territory’s residents self-identifying as indigenous.9

There are no reliable figures on the number of indigenous persons living on the continent prior to European arrival in 1788, but scholars estimate the number to lie somewhere between 315,000 and 750,000.10 During this time, indigenous peoples lived in all parts of the country as nomadic hunter-gatherers.11 Their survival depended on a comprehensive knowledge of local flora and fauna.12 It is believed that indigenous people consumed a varied diet with high nutrient density, in which animal foods were a major component, as well as uncultivated plant foods such as roots, starchy tubers, seeds, fruits, and nuts.13

The arrival of European settlers led to a vast number of land development initiatives, which meant that much of the land that Aboriginal people used to hunt and gather was destroyed.14 Trees and plants were removed, animals were killed or moved elsewhere as their habitat was destroyed, and waterways were polluted.15 Furthermore, with the deaths of Aboriginal people at the hands of settlers, and the forced separation of families, Aboriginal kinship systems suffered, and knowledge of the preparation of traditional foods was lost.16 Thus, European arrival in Australia adversely affected indigenous peoples’ access to and use of traditional foods, as well as the retention of indigenous knowledge of traditional foods—a phenomenon that has contributed, to some extent, to the current food insecurity situation among ATSI peoples.17

Today, food insecurity contributes to inequities in health and life expectancy between indigenous and non-indigenous people in Australia. The Australian Bureau of Statistics estimates that ATSI males born in 2005–2007 could expect to live to 67.2 years, which is 11.5 years less than the expected 78.7 years for non-indigenous males.18 Similarly, the life expectancy for ATSI women born in 2005–2007 is 72.9 years, which is 10 years less than the expected 82.6 years for non-indigenous women.19 Poor nutrition among ATSI peoples has been linked to poor individual and community health outcomes and is recognized as a significant contributing factor to the total burden of disease for indigenous Australians.20 Chronic diseases are estimated to account for 80% of the mortality gap between ATSI and non-indigenous Australians aged 35–74.21

Food insecurity among ATSI peoples varies in severity across the country. Today, there are an estimated 80,000 indigenous Australians living in remote communities, and many have poor access to fresh and nutritious food, largely due to their distance from cities.22 The National Aboriginal and Torres Strait Islander Health Survey has found that nearly 30% of Aboriginal adults worry at least occasionally about going without food; this figure is even higher among people living in remote areas.23 Of ATSI peoples living in remote areas, 36% are likely to run out of food, compared to 20% of indigenous people living in non-remote areas.24 ATSI peoples over 55 years of age are more likely than non-indigenous Australians to go without food, due to a lack of money (17% compared to 2%).25

The World Health Organization’s declaration on food security highlights the three pillars that food security is built on: food access, meaning sufficient financial and other resources for people to obtain appropriate food for a nutritious diet; food availability, meaning sufficient quantities of nutritious food available on a consistent basis; and food use, meaning the appropriate use of food, based on knowledge of basic nutrition and care.26 In this light, ATSI peoples’ capacity for food security is undermined by poor food access (due to, for example, low income) and poor connectivity between communities and food stores; poor food availability (for example, high costs of food and limited availability of nutritious foods); and poor food use (for example, inadequate household infrastructure, including food storage and food cooking facilities).27

Food access

Sue Booth and Alison Smith suggest that ATSI peoples are particularly vulnerable to food insecurity due to welfare dependency, low incomes, and poverty.28 ATSI households are 2.5 times more likely to be in the lowest-income-bracket households than are non-indigenous households.29 The unemployment rate among ATSI peoples is three times higher than it is for non-indigenous Australians.31 The median weekly individual income in 2006 for an ATSI person was AUD278, which was slightly more than half of the median income for a non-indigenous Australian (AUD473).[31] Finally, welfare-dependent families in urban areas of Australia are thought to spend up to 40% of their income on food in order to achieve adequate nutrition.32

International evidence suggests that income is not the only factor that determines food security. Employment status, level of educational attainment, house ownership, and housing costs are also relevant factors in determining a person’s degree of food security.33 In Australia, ATSI peoples are disadvantaged across all socio-economic measures.34

A lack of connectivity to food stores also poses significant challenges for people living in remote areas.35 Furthermore, communities living in remote areas may be forced to go without food for extended periods of time due to adverse weather or poor road conditions. One survey found that in the Northern Territory, 55% of communities lacked access to fresh food for extended periods of time.36 Residents of this vast territory may have to travel up to several hours by vehicle to reach the closest regional center (such cities generally have a medium-sized grocery store) to purchase fresh food, such as fruits and vegetables, when nutritious food is unavailable in local shops due to bad weather or other reasons. Alternatively, they must rely on frozen or prepackaged food, such as instant noodles and chips, which generally lack adequate nutritional value.

Food availability

In certain parts of Australia (with the exception of, for example, remote mining regions), income levels have been found to decrease with geographic remoteness; at the same time, the cost of food, particularly healthy food, rises significantly in remote areas compared to urban centers.37 Statistics from 2011 show that the labor-force participation rate among ATSI peoples was lowest in remote areas, at just 50%.38 Overall, labor-force participation among ATSI peoples of working age declined as geographic remoteness increased.39 Moreover, while approximately 50% of ATSI men aged 15–64 were employed in 2011, only 43% of women were employed.40

Factors that can contribute to higher food prices, particularly in remote areas, include freight charges, store management practices, and reduced retail competition in remote communities with small populations.41 The combination of higher levels of unemployment, lower levels of income, and higher food prices means that the percentage of income spent on food increases, thus making a healthy diet even more difficult to achieve for ATSI peoples living in remote areas of Australia.42

The variety and quality of nutritious food are also much worse in remote community stores compared to stores in major cities.43 Convenience foods, which are energy dense and lacking in nutrition, are often the most readily available source of food for many people in remote communities.44 It thus follows that while awareness-raising campaigns on choosing healthy foods to eat, food preparation and cooking, and budgeting for food purchase play an important role in improving food security among ATSI peoples, the effectiveness of such initiatives is dependent on healthy food actually being available and accessible in the first place.45

Food use

Finally, with regard to the World Health Organization’s pillar of food use, poor environmental health infrastructure is a major impediment to food security. In ATSI communities, only 6% of houses have functioning nutritional hardware, such as a storage space for food, adequate bench space for preparing food, refrigeration, and a functioning stove and sink.46

Australia’s efforts to improve food security among ATSI peoples

There are three tiers of government in Australia: federal, state and territory, and local. In recent decades, interventions to improve food security among ATSI peoples have come from all three levels of government.47 Programs have been implemented to improve food access, food availability, and nutrition status among ATSI peoples, with some positive results and valuable lessons learned for future programs and interventions. However, food insecurity persists for many ATSI peoples, particularly those living in remote parts of Australia.

Close the Gap campaign

In his 2008 apology to the Stolen Generation, former prime minister Kevin Rudd established a series of targets to reduce the economic and social gaps between indigenous and non-indigenous Australians, especially the gap in infant and child mortality rates.48 This commitment is now widely referred to as “Close the Gap” and forms the federal government’s approach to ATSI issues. The Close the Gap campaign for health equity aims to eliminate ATSI health inequalities within a generation. The campaign has introduced a number of initiatives to promote good nutrition and healthy-eating practices, with a focus on the most remote communities. Despite its positive intentions, the campaign has attracted its fair share of criticism. For example, as Sara Hudson has commented, Close the Gap is about reducing inequities and inequalities between indigenous Australians and non-indigenous Australians; however, the government has not introduced policies or programs that reflect an understanding that achieving this goal will require providing indigenous communities with access to the same level of services and facilities that non-indigenous Australians have.49 Indeed, government efforts to close the gap will have to extend beyond the goal of providing the same level of services and facilities between indigenous and non-indigenous Australians to address the many inequities described in this paper, including a lack of access to nutritious and affordable food, poor health indicators, and a lack of employment opportunities.

National Aboriginal and Torres Strait Islander Peoples in Australia Nutrition Strategy and Action Plan

Between 2000 and 2010, the government’s National Aboriginal and Torres Strait Islander Peoples in Australia Nutrition Strategy and Action Plan (NATSINSAP) outlined a framework for improving ATSI peoples’ nutrition through concerted action across all levels of government and in collaboration with the food industry, nongovernmental organizations, and indigenous peoples. Building on existing efforts to improve access to nutritious and affordable food in urban, rural, and remote communities, the strategy focused on seven key areas: food supply in remote and rural communities; food security and socio-economic status; family-focused nutrition promotion; nutrition issues in urban areas; the environment and household infrastructure; training and employment of an indigenous workforce to promote nutrition; and national food and nutrition information systems. The NATSINAP recognized that poor nutrition plays a key role in the poor health of ATSI peoples and the disproportionate burden of chronic disease that they experience.

Jennifer Browne, Sharon Laurence, and Sharon Thorpe suggest that despite limited funding, there was significant progress in some of the priority areas of the NATSINSAP, such as training of a nutrition promotion workforce, and improved food supply in remote communities.50 Other scholars, however, have pointed to the limitations of the NATSINSAP; for example, the strategy lacks an ongoing source of funds, and there has been no formal review of the strategy to evaluate its effectiveness.51 Furthermore, for the strategy’s priority areas of improving food security, nutrition issues in urban areas, and environment and household infrastructure, both government funding and policy action have been limited.52

Hudson posits that the key “achievement” of NATSINSAP was the collaboration between five state and territorial jurisdictions of the Remote Indigenous Stores and Takeaways Project, which consists of guidelines for stocking healthy food and marketing strategies to promote the use of healthy food.53 However, Hudson points out that this project showed only limited evidence of increased sales of fruits and vegetables.54 She argues that healthy-eating programs appear to make a positive change in communities that are already motivated to eat better but are of “limited value in areas where store committees and managers are not motivated to change their food stocking practices.”55

Despite marketing campaigns’ limited ability to change people’s food choices, the federal government continues to commit large amounts of Commonwealth funding to them. In November 2008, the Council of Australian Governments announced an additional AUD40.95 million (in addition to the AUD29.7 million already provided) to extend the Measure Up healthy-eating social marketing campaign by an additional three years.56 Hudson argues that the problem with initiatives such as Measure Up is that they imply that low-income people make poor food choices because they lack the education to know any better.57 Some members of ATSI communities resent the government for assuming that they need to be taught which foods are nutritious and which are not.58 By continually directing Commonwealth money to healthy-eating social marketing campaigns, the federal government fails to address the underlying reasons for ATSI peoples’ unhealthy diets. For example, most healthy-eating campaigns have not considered the lack of sufficient health “hardware,” such as functioning kitchens, refrigerators, and stoves in ATSI communities.59 Many ATSI families purchase takeaway food because they do not have the facilities to store or cook food at home.

Outback Stores

Another government strategy to improve ATSI food security is Outback Stores, a company established by the government in 2006 to manage remote stores in indigenous communities. The company seeks to overcome the factors that inhibit the provision of fresh and competitively priced produce in remote stores, such as financial mismanagement, food stocking policies, and poor infrastructure.60 Indigenous Business Australia, a statutory authority of the federal government, manages the scheme. Since 2006, the federal government has provided AUD8.1 million to implement computerized point-of-sale systems in the Outback Stores, as well as an additional AUD40 million in loans to develop store infrastructure.61

There are currently 27 Outback Stores in the states and territories of Queensland, Western Australia, and the Northern Territory. Under the scheme, stores continue to be owned by the community but community members must sign, on a fee-per-service basis, a long-term agreement with the company. Community members are entitled to receive reports providing information about their store’s financial and social performance, and to submit questions regarding any of the scheme’s decisions that are made on behalf of the community.

In 2008, former prime minister Rudd asked the House of Representatives Standing Committee on Aboriginal and Torres Strait Islander Affairs to conduct an inquiry to examine the effectiveness of Outback Stores in improving the management of stores in remote areas of Australia. In 2009, the committee released its report, Everybody’s Business: Remote Aboriginal and Torres Strait Community Stores, which was based on 112 submissions and evidence heard at hearings. The report offered 33 recommendations for improving the role and management of remote stores, as well as strategies for improving food supply and affordability, transport, and sector regulation. Unfortunately, as Hudson has pointed out, the government has largely ignored the report’s recommendations.62

Amanda Lee et al. highlight the positive elements of Outback Stores, such as the fact that one of the scheme’s key goals is to improve the provision of nutritious food, as well as the fact that the scheme may serve as a potential model to support sustainable employment and economic development in remote communities.63 Other commentators are far less admiring. For example, Hudson argues that despite the company’s assurances that it works with communities to meet their differentiated needs, it also insists that store committees sign over control of the stores’ operations, which leads to these committees being stripped of their decision-making power.64 Without the appropriate application of the human rights principle of community participation, the Outback Stores scheme may be yet another example of the federal government doing something for ATSI communities, instead of with them, leading to the entire scheme ultimately failing.

Hudson suggests that the Outback Stores scheme has also resulted in some unfortunate consequences. For example, the AUD77 million of government funding that has been spent on these stores has made it more challenging for independent community stores to continue operating.65 Government subsidies for Outback Stores have made it less economically attractive for remote communities to start their own stores and for ATSI peoples to pursue other methods of obtaining and selling nutritious food, such as growing fruits and vegetables in gardens.66

National Strategy for Food Security in Remote Indigenous Communities

The Council of Australian Governments’ 2009 National Strategy for Food Security in Remote Indigenous Communities aimed to improve food security among ATSI peoples living in remote communities through sustained, coordinated action around food supply and nutritious food consumption. The strategy’s five key actions consisted of (1) national standards for stores and takeaway shops; (2) a national quality improvement scheme to implement these standards; (3) stores’ incorporation under the Corporations (Aboriginal and Torres Strait Islander) Act; (4) a national healthy-eating action plan; and (5) a national workforce action plan.

The Australian National Audit Office’s 2014 assessment of this strategy found that of the five desired actions, only the national healthy-eating action plan for remote indigenous communities was completed, despite a mid-2010 time frame for the completion of all actions.67 According to the assessment report, the strategy did not establish a framework to coordinate food security initiatives, and, as a result, the Australian government’s food security initiatives continue to operate in isolation from one another; furthermore, they are focused mostly on the Northern Territory, leading other states and territories to receive insufficient attention.68

Welfare quarantining

Under welfare “quarantining,” the federal government segregates welfare payments so that a particular portion may be used only for food purchases. As argued in a submission by several nongovernmental organizations to the UN Committee on Economic, Social and Cultural Rights, while the aim of this policy is to increase access to food among ATSI peoples, its implementation has in some cases actually hindered this access.69 The report explains that under the welfare quarantining system, the purchase of food can be made only from government-approved stores, which means that ATSI peoples may have to travel longer distances to purchase food.70 The policy has also forced many small community stores to shut down due to insufficient revenue, as their customers have redirected to the government-approved stores.71 Furthermore, the high amount of administration required to implement the scheme has led to errors, such as insufficient store vouchers being available at Centrelink offices (the federal government agency responsible for providing services and unemployment benefits to low-income Australians). This has meant that some people have not had vouchers to buy food and others have received vouchers valued at a lower amount than they are actually entitled to.

Also significant is the fact that welfare quarantining greatly reduces ATSI peoples’ ability to determine their own sustenance. Under this policy, ATSI peoples experience great difficulties in accessing government money to pay, for example, for repairs to vehicles that are required for hunting, or for hunting supplies.72 This hinders their ability to use the land for food and to access traditional foods.

Discussion and conclusion

Access to, the availability of, and the quality of food are key concerns for vulnerable groups in Australia. Indigenous Australians enjoy less access to nutritious foods than does the wider population. Remoteness and poverty are more common among indigenous Australians than among their non-indigenous counterparts and are key factors that limit ATSI peoples’ access to nutritious food. The much higher rate of illness and disease related to poor nutrition in ATSI communities is a clear consequence of the barriers related to food availability, access, and use faced by ATSI peoples.

The food security challenges faced by ATSI communities highlight the interconnectedness of human rights. For example, the rights to adequate food and good health are intricately linked to the right to adequate housing. Without adequate housing infrastructure—such as food storage space, refrigerators, and functioning stoves—the rights to adequate food and good health are greatly compromised, as ATSI households cannot cook or store fresh, nutritious foods and are thus forced to rely on takeaway food. Government policies and campaigns to address food insecurity can work, but when governments fail to consider the interdependency of key human rights, the effectiveness of such interventions is reduced. While the Australian government’s interventions to improve food security among ATSI peoples recognize the importance of access to fresh food and nutrition education, these campaigns do not always address the important relationships among key rights. Social marketing nutrition campaigns have been negatively received in ATSI communities because they have been based on the assumptions that these communities do not know how to recognize healthy food and that telling ATSI peoples what food is healthy will solve the current health inequities between indigenous and non-indigenous Australians. The same campaigns have neglected to consider that they will inevitably fail as long as there is a lack of adequate public transportation to reach stores that sell fresh produce, sufficient income to purchase fresh food, or, indeed, good-quality fresh produce to purchase in the first place.

Past and current Australian government policies that have disregarded a human rights-based approach to achieving food security have limited ATSI peoples’ participation in relevant decision-making processes. Food security policies, absent a human rights-based approach, fail to acknowledge ATSI peoples’ agency and perspectives; as a result, decisions are made for ATSI peoples rather than with them. This inevitably limits ATSI peoples’ ability to make decisions about the sources of their food and to make economic decisions about where to spend their money on food. These are rights that are particularly important for indigenous people, who often live on their traditional lands and value the right to hunt and consume traditional foods.

It may be concluded that successive Australian governments’ food security policies for ATSI peoples have had limited success because they have not considered the interrelatedness of key rights and have not adopted a human rights-based approach to achieving food security. Despite some moderate success in specific policy areas, overall, the Australian government’s campaigns have not managed to significantly improve food security among ATSI peoples. Evidence of this can be found in Australia’s five-year reports to the UN Committee on Economic, Social and Cultural Rights describing the country’s progress toward food security. The committee’s review of Australia’s fourth report on the implementation of the International Covenant on Economic, Social and Cultural Rights noted an incomplete and unaddressed assessment of the right to food, suggesting an absence of effective policies in the area of food security.

Improving food security among ATSI peoples in Australia also requires addressing inequities in social status; focusing on issues related to employment, income, welfare, and education; improving access to adequate housing; and improving public transportation in remote communities. The Australian government needs to consider the interrelatedness of key human rights in its attempts to develop policy and build cross-sector collaborations to address food security for ATSI peoples. Coordination across multiple sectors—including health, housing, transportation, education, human services, employment and training, social services, child protection, and food—as well as across all levels of government is necessary to address food insecurity among ATSI peoples in urban, rural, and remote areas of Australia. Success in improving food security requires a closer adherence to a human rights-based approach that invites the active participation of ATSI peoples in determining solutions to food insecurity and health-related inequities.

Deanna Davy is an Independent Research Consultant

Please address correspondence to Deanna Davy. Email:

Competing interests: None declared.

Copyright: © 2016 Davy. This is an open access article distributed under the terms of the Creative Commons Attribution Non-Commercial License (, which permits unrestricted non-commercial use, distribution, and reproduction in any medium, provided the original author and source are credited.


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  2. United Nations Food and Agriculture Organization, Voluntary Guidelines to Support the Progressive Realization of the Right to Adequate Food in the Context of National Food Security (Rome: United Nations Food and Agriculture Organization, 2004).
  3. Ibid.
  4. Ibid.
  5. Ibid.
  6. Ibid.
  7. Australian Bureau of Statistics, “Estimates and projections, Aboriginal and Torres Strait Islander Australians, 2001 to 2026” (2014).
  8. Australian Bureau of Statistics, “Census of population and housing: Counts of Aboriginal and Torres Strait Islander Australians, 2011” (2012).
  9. Ibid.
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  17. Council of Australian Governments, National Strategy for Food Security in Remote Indigenous Communities (Canberra: Council of Australian Governments, 2009).
  18. Australian Bureau of Statistics, “Experimental life tables for Aboriginal and Torres Strait Islander Australians: 2005–2007.”
  19. Ibid.
  20. Menzies School of Health, Research submission (number 12A) to House Standing Committee on Aboriginal and Torres Strait Islander Affairs (2009). Available at House_of_Representatives_Committees?url=atsia/communitystores/subs/sub0012a.pdf.
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  52. Ibid.
  53. Ibid.
  54. Ibid.
  55. Ibid.
  56. Ibid.
  57. Ibid.
  58. T. Lea, Bureaucrats and bleeding hearts: Indigenous health in Northern Australia (Sydney: UNSW Press, 2008).
  59. Hudson (see note 49), p. 6.
  60. Outback Stores, Background. Available at
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  62. Ibid., p. 2.
  63. Lee et al. (see note 35), p. 547.
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  65. Ibid., p. 1.
  66. Ibid.
  67. Australian National Audit Office (see note 22).
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  69. National Association of Community Legal Centres, Human Rights Law Resource Centre, Kingsford Legal Centre, Freedom, respect, equality, dignity: Action; NGO submission to the UN Committee on Economic, Social and Cultural Rights (2008). Available at
  70. Ibid., p. 105.
  71. Ibid.
  72. Ibid.
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