Alternative Law Journal
In 2000, Graham Willett wrote that legal and social equality for lesbians and gay men are 'firmly on the agenda and achievable in our lifetimes'. In the last five years, progress in lesbian and gay law reform in Australia has seemed unstoppable. ln all states and territories, gay sex has been decriminalised and in most states and territories, laws outlaw discrimination on the basis of sexual orientation and recognise lesbian and gay relationships.
In this article, I reflect on gay and lesbian law reform in Victoria, particularly the work of the Victorian Gay and Lesbian Rights Lobby (VGLRL) in the relationship campaign of 2000-2001. The Equal Opportunity Act 1995 (Vic) passed by the Kennett Liberal Government outlawed discrimination on the basis of 'lawful sexual activity', The VGLRL was established in 1997 and it successfully lobbied the new Bracks Labor Government to replace the dubious notion of 'lawful sexual activity' with the term 'sexual orientation' and also extend protection to transgender people. In 2001, after an extended law reform consultation and lobbying process, legal recognition of lesbian and gay relationships was achieved.
I discuss some 'technical' strategies that we used in the law reform process. I also discuss the wins -and losses - of law reform. Ian Parsons observes that law reform for human rights produces 'gains that will carry with them some losses as, almost always, legal solutions involve some compromise' and, more fundamentally, because law reform requires that we 'reshape human rights issues into legal issues'. Finally, I ask what are some important issues for gay and lesbian activists in the future.
No politician is going to do this out of the goodness of their hearts, even if they know it IS the right thing to do. We have to make it happen.
The VGLR was formed after a public meeting in 1997 that identified the need for a lobby group for gay, lesbian and transgender communities. The previous organisation, Gays and Lesbians Against Discrimination (GLAD) had faded away after the achievement of antidiscrimination laws in 1995. After much discussion, it was decided that the VGLRL would directly represent only 'lesbians and gays' but would work closely with the transgender community and others of the queer community on issues that concerned them. While I do not have space to discuss it here, the debate about definition, naming and community representation was difficult, reflecting the perennial problem of how to lobby effectively for a 'constituency' while still respecting diversity. The VGLRL has achieved law reforms that have benefited all members of queer and transgender communities. Although there have been tensions between lesbians and gay men, it has been particularly important that the VGLRL is a 'coalitionist' movement, reflected in the requirement in its rules that it have both a lesbian and a gay co-convenor.
From the beginning, the VGLRL focused on achieving 'equality and social justice for lesbians and gay men by working in all areas of government and policy, with the media, and with our communities'. Its reformist stance was clear in its goal to maintain 'effective relationships with decision makers'. It has directly lobbied government bodies, including the Equal Opportunity Commission (EOC) and all political parties. In 1999,the Victorian Labor Government established ministerial advisory committees on lesbian, gay and transgender issues, in which the VGLRL and other community organisations have participated.
The VGLRL has also sought to educate lesbians and gay men about the state ofthe law and to find out what our community wanted. Paid membership of the VGLRL has only ever numbered a few hundred (it currently stands at about 330), but it has a fairly high profile in the community. Its greatest achievement' was surveying nearly 1000 lesbians and gay men in urban and rural Victoria on their experiences of discrimination and abuse, reported in Enough is Enough in 2000, following a previous survey by GLAD in 1994. Enough is Enough showed that 84% of lesbians and gay men had experienced at least one form of discrimination or abuse and also highlighted the very high rate of abuse experienced by transgendered people.
Enough is Enough received widespread media coverage as a result of a carefully publicised launch, and became a point of reference for the media in the law reform debate. The VGLRL has had a public profile and good relationship with community and mainstream media. This has been facilitated by careful preparation. and wide distribution of press releases and media packages. It is also the result of the accessibility of VGLRL co-convenors for media comment on all sorts of issues pertaining to lesbians and gay men. While availability for public comment raises the tricky problem of how to 'speak for' the gay and lesbian community, my experience with the media during the heated parliamentary debates surrounding relationship reform showed that cultivating good relationships with journalists was worthwhile.
The other strategy used by the VGLRL involved surveying polit1cal parties and individual politicians, in particular the Labor Party, in the 1999 election campaign. The VGLRL held 'meet the candidates' forums and published party views on lesbian and gay issues. The Labor Party promised reform of antidiscrimination laws and relationship recognition in the 1999 campaign and the timing was right: Labor was on the verge of obtaining power for the first time in nearly a decade. This work enabled the co-convenors to get to know politicians and others in the political process. Such personal contacts have been important in achieving law reform.
Lesbian and gay domestic partnerships are not afforded the same rights and do not 1ncur the same responsibilities under the law as unmanned heterosexual domestic partnerships (de factos)... it's time for lesbian and gay love to become legal too.
The VGLRL campaign for relationship recognition was a classic 'equality' rights campaign, as illustrated by the above quotation from Making Love Legal, the booklet printed and distributed by the VGLRL to all politicians, media and members of the community in the midst of the parliamentary process. The booklet emphasised both rights and responsibilities and the 'practical consequences' of the unequal law for lesbians, gay men and their families, especially 'in times of crisis'. It even went so far as to explain that 'in some areas of the law, this inequality creates unfair advantages for same-sex couples over heterosexual couples'.
The relationship campaign grew out of the anti-discrimination reforms of the 1990s. After representations by lesbian and gay lobbyists, the EOC held an inquiry based on a Discussion Paper on Same Sex Relationships and the Law in May 1997. The EOC expressed concern that the possible lack of coverage of gay and lesbian relationships by the Equal Opportunity Act 'has the potential to severely limit the application of the Act to redress discrimination'. Its inquiry received approximately 500 submissions and the final EOC Report, Same Sex Relationships and the Law, concluded that 'submissions confirmed broad based support for elimination of discrimination against people in same sex relationships in most areas' and recommended immediate legislative reform.
Because of its wide consultation, the EOC Report provided authoritative support for the reform and, with the VGLRL's Enough is Enough, was the most influential document in the reform process. It was crucial for the success of the campaign that the EOC championed lesbian and gay law reform in its capacity as a general human rights body, as this gave legitimacy to the campaigning taking place outside government, including lobbying with politicians and persuading the community.
At the same time, the EOC Report effectively established what was going to be possible in the relationship campaign. First, gay marriage was off the agenda. The EOC Report said that 'legalising marriage for same sex couples did not enjoy broad based support from either the community at large or the gay and lesbian community'. This became an important motif in the campaign. Second, the EOC Report effectively removed from the agenda the reform of discriminatory laws concerning access to reproductive (fertility) services, adoption and care of children. It found that these were the most contentious areas of discrimination and called for 'more consideration and consultation' on these topics.
The EOC Report also revealed differences in opinion as to the kind of legal recognition that could be adopted for lesbian and gay relationships. The easiest reform would be to extend de facto recognition to lesbian and gay couples. Many lesbians with knowledge of previous feminist campaigns supported de facto recognition because it provided legal protection for the weaker person in a relationship, without any legal steps needing to be taken. It would also cover lesbians and gay men in relationships even when they had not 'come out' (although it might require evidence of the relationship). On the other hand, a significant number of people (possibly more gay men than lesbians) preferred a registration system. They opposed the 'colonisation' of their relationships by the legal system. There were also differences in view about recognising only 'marriage-like' relationships or providing recognition for a diversity of caring and supportive relationships. There was no consensus as to whether a de facto approach was appropriate for non-cohabiting non-couple relationships.
The VGLRL in the end supported the de facto approach, but we sought to broaden it to include a range of diverse caring relationships. This position was largely pragmatic, based on discussions with Labor politicians before the 1999 election and the Equal Opportunity (Same Sex Relationships) Bill1999 introduced as a private member's Bill by Labor MP John Thwaites before the election. However, the VGLRL also supported this model because we thought it would provide greater substantive equality to lesbians and gay men in relationships.
The Labor Party has not always supported lesbian and gay law reform. Why did the Bracks Labor Government (and Labor governments around the country) support the relationship reform? Davina Cooper's insights about lesbian and gay activism and Labour politics in the United Kingdom are pertinent. She observes that the shift towards a discourse of 'equal opportunity' in the late 1980s and 1990s (in the UK and Australia) provided a 'powerful ideological framework for government as well as for "disadvantaged" groups'. This equal opportunity and anti-discrimination framework enabled the EOC to advocate for gay and lesbian relationship recognition. It also provided the context for Labor's support of law reform. This is shown in the parliamentary speeches on passage of the reform. Parliamentary Secretary, Richard Wynne MP, said:
The bill contains simple principles, one being that all sections of the community should enjoy equal rights under the law, regardless of their personal, sexual relationships. The Labor Party stands for that simple proposition - for equality-and it will not tolerate discrimination.
The equal opportunity paradigm appealed to Independent Susan Davies MP, who supported the Bill with amendments. It also appealed to many in the Liberal Party. Their support (or non-opposition) was essential because the Labor Party had a minority in both :houses of parliament. Although the Liberal Party retained a majority in the Legislative Council in the 1999 election (with the National Party, whose members voted against the reform), its popularity was at its lowest ebb in many years. Then Liberal leader Dennis Napthine and shadow Attorney General Robert Dean were inconsistent and unpredictable in negotiations about the reform. However, a core of Liberals supported the reform, some of whom had vocal gay constituencies, and eventually carried the day. Their views, and the power of the equal opportunity discourse, are illustrated in the speech of Andrea McCall, Liberal MP for Frankston:
The bill we are debating today ... is not about party politics or philosophies; it is about a community and a society that has moved forward in 2001 and recognised where discrimination lies ... It is unfortunate that most of us have bought into a political argument when the bill is a community issue. I would not be stand1ng 1n th1s chamber as a female Member of Parliament if I did not believe in equity, equality, rights of access and the right to be regarded in exactly the same way as and by any other member of the community.
Parliamentary speeches on final passage of the law reform were overwhelmingly supportive, but the process of the law reform was anything but smooth. The VGLRL was involved in detailed lobbying with both the Government and members of the Liberal Party right up until the final vote.
One influential opponent of reform was Catholic Archbishop of Melbourne George Pell (now a Cardinal based in Sydney). Pell wrote a confidential letter to members of parliament on both sides of politics opposing the reform. The letter was leaked to a newspaper and was faxed Immediately by the newspaper to the VGLRL: we had reason to be grateful for our good relations with the media! The Pell letter stated that the 'pla1n consequence' of the reform was
'to subvert the centrality of marriage'. He expressed concern about 1ts symbolic effects and said that legal recognition of same-sex relationships would radically undermine public policy about the family and 1ts care for children, 'by promoting the view that homosexual activity is equivalent to or as acceptable as the expression of conjugal love in marriage. It would nun counter to the nature and rights of the family in our society and do irreparable harm.'
Rather than countering the substance of Pell's letter, the VGLf<.L and the government responded to it with the bland assertion that the reform did not affect marriage and that it was about equality and ending discrimination. This was effective. Yet, in some respects, Pell was asking the right question (albeit with the wrong answer). The relationship reform was not just about formal discrimination, although that was the language of the campaign. It was a battle to change the meaning of family; symbolically and in practice we were se king legal validation and support for lesbian and gay families of choice and for our caring responsibilities.
The most significant opposition to the law reform came from within the Liberal Party itself. This was manifested in a series of technical yet inflammatory legal objections to the Bill as drafted, including assertions by the shadow Attorney General that it would expand recognition to friendly caring neighbour relationships, and would oust spouses (and former spouses) from their rightful positions in inheritance and other laws. The VGLRL turneCI to its legal contacts and to the power of legal discourse to tum such 'emotive' political issues into technical and legalistic questions of formal equality and definition. We sought and obtained statements of support for the law reform from both legal professional bodies in Victoria, the Victorian Law Institute and the very conservative Victorian Bar Council. The Bar Council Human Rights Committee publicly supported the reform after considerable internal politicking. In language that was music to conservative ears (and that gay activists must sometimes be prepared to put up with), it said the reform was acceptable because it 'promotes the equal treatment of people under the law', 'does not create any form of special rights' and 'does not endorse or promote same sex couples'. We were also able to obtain at short notice pro bono opinions from highly regarded Queen's Counsel at the Victorian Bar in respect of the legal technicalities. We provided these opinions to all politicians and they were important in defusing both genuine and specious concerns about the technical effect of the law.
The other way in which the difficult politics of the last two months of the campaign were overcome was through direct action by the lesbian and gay community. With the encouragement of the VGLRL and other community organisations, people wrote to their MPs, told their stories to the media and generally 'came out' in vociferous support for reform. Time and again, parliamentary speeches referred to the personal stories of constituents, frequently quoting at length from letters that told the story of the relationship or family life of a lesbian or gay man. Many speeches also criticised the letters they received opposing the reform, frequently from people outside their constituency, as counterproductive and 'unchristian'.
The unsettled internal politics of the Liberal Party in 2001 provided a window of opportunity for bipartisan support for the law reform.
Are we merely bringing ourselves into law? That which was outside is now within the governable.
In 1999, Gary Dowsett challenged the VGLRL to think about its reformist approach to gay and lesbian rights. He asked, 'how much are we renovating the family, opening it up to variety and flexibility, and how much we are rendering ourselves into a barely reconstructed corner of the same old edifice?'
Does the relationship reform 'open up' the family to recognise diverse lesbian and gay lives? The answer is clearly yes. A lesbian, gay or transgendered 'domestic partner' in a 'domestic relationship' is now entitled to benefit from state accident compensation if their partner has an accident, is covered by the property division regime on relationship breakdown, need not pay stamp duty on a transfer of property to their partner, can make decisions about organ donation and guardianship concerning their partner, and can inherit as next of kin in most cases. Further, the law symbolically recognises that lesbian, gay and transgender couples can and do commit to an 'intimate personal relationship and shared life', a major step forward in legal and social recognition of our lives.
However, the law that was finally enacted is both narrower and more complex than this description suggests. In fact, it inserted two new definitions of 'domestic relationship' in Victorian law, commonly refenred to as the broad and narrow definitions. At the same time, it restricted the definition of 'spouse' to married couples. The narrow definition of 'domestic partner' applies in laws that relate to property and financial matters, including laws on taxation; accident and work compensation; insurance; superannuation; inheritance; and property division on relationship breakdown. It also applies in respect of 'relationship status' discrimination under the Equal Opportunity Act. For example, s 3 of the Duties Act 2000 (Vic) defines a 'domestic partner' as a person in a 'domestic relationship', which is:
the relationship between two people who, although not married to each other, are hving together as a couple on a genuine domestic basis (irrespective of gender)
The broad definition is included in statutes concerning 'personal' rights, including laws relating to medical records, consumer rights, guardianship and organ donation. For example, s 3(1) of the Coroner's Act 1985 (Vic) provides that:
'domestic partner' of a person means an adult person, to whom the person IS not married but with whom the person is in a relationship as a couple where one or each of them provides personal or financial commitment and support of a domestic nature for the material benefit of the other, irrespective of their genders and whether or not they are living under the same roof.
The key difference between the narrow and broad definitions is the lack of a requirement for cohabitation in the latter. In respect of both definitions, Independent Susan Davies MP obtained the inclusion of a list of matters in s 275(2) of the Property Law Act 1958 (Vic) to be considered in determining whether a domestic relationship exists, insofar as they are relevant in a particular case. These include the duration of the relationship; common residence; whether or not a sexual relationship exists; the degree of financial interdependence and financial support; ownership and use of property; mutual commitment to a shared life; care and support of children; and reputation and public aspects of the relationship.
The details of this rather complex legal outcome reveal the many compromises that were made in the law reform process. Although the VGLRL initially sought a broad notion of domestic partner that would encompass a diversity of caring relationships, we did not achieve this. The narrow definition, and the list of matters to be considered, essentially replicate the definition of de facto spouse for unmarried heterosexual couples that previously existed and incorporates case law on the meaning of de facto spouse in which courts have sought to decide if a relationship is 'marriage-like'. The broad definition is convoluted and difficult to understand. It achieves limited legal recognition of relationships where partners do not live together, but the insertion of the words 'as a couple' by the Liberals late in the legislative process restricts its scope. This is reinforced by the statement in s 1 of the Statute Law Amendment (Relationships) Act 2001 (Vic), inserted to satisfy the Liberals, which emphasises 'a commitment to a long term relationship and the security of children'.
In sum, equal opportunity discourse constrained our ability to recognise diverse relationships in entirely new ways: it worked best at 'bringing us in' to existing legal categories which do not always fit our lives.
Jeffrey Weeks has written that the lesbian and gay movement since the 1970s has oscillated between a 'moment of transgression' and a 'moment of citizenship'. Superficially tracing gay and lesbian activism over the last 30 years, we can discern a shift from 'gay liberation' and resistance to the state, to engagement with the state to obtain services to deal with needs during the HIV/AIDS crisis in the 1980s, to a 'queer' counter-discourse that rejected the state, to a new engagement with the state in the equal opportunity discourse of the late 1990s.
The most striking feature of the recent Victorian gay and lesbian law reforms has been the combination of equal opportunity discourse with direct and continuing close engagement with government bodies and political parties, particularly through governmental committee structures. As Cooper observes, working with the state has been described as 'a process of containment that diffuses rather than achieves fundamental change' and she documents this tendency in gay and lesbian committee activism in the 1980s in UK local government. Law reform has been achieved in Victoria through this process, and it may have assisted us in obtaining funding for educational community outreach about the reforms. But some of the legal and political compromises we made were cemented in these committee forums.
Close engagement with a political party in government may not produce all the legal and social change that the lesbian and gay community wants. In Victoria, , we failed to alter the Labor Government's political stance that excluded the Adoption Act 1984 (Vic) and the Infertility Treatment Act 1995 (Vic) from the relationship law reform, despite significant lobbying and the clear discriminatory impact of those laws. The VGLRL acquiesced publicly in this approach because we felt that the reform would not pass if these laws were included. I still think this was probably right. But it came with a high cost. It failed to acknowledge the very significant caring for children that takes place in our community, in particular by lesbians, and the high levels of discrimination around parenting experienced by lesbians and gay men. Like the continuing exclusion from anti-discrimination laws of certain children-related occupations, the legal implication that lesbians and gay men do not care for and, indeed, may harm children is extremely prejudicial and damaging. After re-election
In 2002, the Government referred these issues to the newly established Law Reform Commission, where they are currently under consideration.
It may also be impossible in some contexts to achieve this level of engagement with government This is currently the case with the federal Liberal/National Government under Prime Minister john Howard. In spite of the optimism of Willett, Australian lesbian and gay lobby groups have not achieved federal legal change, including anti-discrimination laws, equal access to marriage and the Family Court, or an end to discrimination in access to superannuation, welfare benefits, immigration and other areas. The Howard Government has even sought (so far unsuccessfully) to wind back some anti-discrimination protections that would affect lesbian access to fertility treatment . The Australian Democrats, historically our strongest supporter at the federal level, last year walked away from same sex rights in superannuation legislation in a compromise with the' Liberal/National Government. And the federal Labor Party, in marked contrast to its state counterparts, has been extremely reluctant to support equal rights for lesbians and gays.
What should lesbian and gay activists be doing now? Cont1nued activism at the state level, working with governments, all political parties and educating the community, is essential to end legal discrimination in respect of access to adoption and fertility treatment Funding and serious attention is also needed to address continuing violence and homophobia. At the federal level, gay and lesbian rights lobbies around the country have established an Equal Rights Network to lobby federal political parties, especially the Labor Party in opposition, to build support for future legislative reform. I also want to suggest two other ways that gay and lesbian activists need to act creatively.
First, we need to bring the matters that were effectively declared off the agenda in the Victorian law reform process back into the debate. I want to discuss just one example: marriage. While we must keep thinking about new ways to recognise relationships in law, I now think it is important for us to begin the debate about gay marriage. As VGLRL co-convenor, I received several calls a week from lesbians or gay men asking about marriage. I sense, albeit with no statistical support, that a significant number of lesbians and gay men would support marriage, and I wonder if it is really an 'impossible dream', as the NSWGLRL recently stated. There is no doubt that the federal Liberal Party (and Prime Minister Howard in particular) oppose gay marriage. But as more Australian lesbian and gay couples are legally married in Canada, or Belgium, or . The Netherlands, what is seen as possible in our law reform discourse may change. Of course, we still have the very important question, do we really want to be part of that 'old edifice' of marriage? Are we in danger of equating equality with sameness? But gay and lesbian activists have not really taken this issue to our community or to the general public, nor have we tried all avenues of change in this regard: not just legislation, but litigation; not just political parties, but the polity.
Second, gay and lesbian activists need to work on building (or rebuilding) coalitions with other groups seeking human rights in the community: feminists, immigrant groups, even environmental groups. We need to work on the particular difficulties of lesbians and gay men in rural, indigenous and immigrant communities.
But we also need to link the reality of our human rights issues - social exclusion, discrimination, violence, hatred - to a wider agenda of social justice. The Victorian relationship reform was possible because of an existing, broad equal opportunity agenda that was originally established to address sex, race and disability discrimination. Altman and Woolcock observe that past Australian governmental policies of 'multiculturalism', which stressed cultural diversity, have benefited lesbians and gay men. The federal government, the general community and political culture in Australia at present is fearful of diversity. Lesbian and gay activists need to work together with other groups for legal and social change that will enable all people to have a place in an Australia that embraces diversity, equality and social justice.
[*] MIRANDA STEWART teaches law at the University of Melbourne.
© 2004 Miranda Stewart
Thanks to Janet Jukes and Kristen Walker for their significant contributions to this article.
 Website addresses below were accessible at 5 March 2004.
Graham Willett, Living Out Loud A History of Gay and Lesbian Activism in Australia (2000) 264-5.
 In NSW, the GLRL obtained a much improved relationship recognition law in 1999 and the equalisation of the age of consent <www.girl.org.au>. In Western Australia, the Labor Government released Lesbian and Gay Law Reform Report of the Ministerial Committee Lesbian (2001) after lobbying by Gay and Lesbian Equality (WA) and has now enacted the most progressive law ref01m 1n the country <www galewaasn. au>. In Tasmania, the last state to repeal
Its sodomy laws years after the celebrated Toonen case, anti-discrimination laws have been enacted and, in 2003, gay and lesbian relationships were recognised, follow1ng the long-stand1ng efforts of the Tasmanian Gay and Lesbian Rights Lobby <www.tased.edu.aultasonline/tasqueerftasqueer.html>. Even the new Northern Territory Government has passed the Law Reform (Gender Sexuality and De Facto Relationships) Act 2003. While there have been some minor reforms in Queensland, both it and South Australia are now lagging behind.
 Ian Parsons, Cripples, Coons, Fags and Fems. A Look at How Four Human Rights Movements Have Fought Prejudice (1999) 57.
 Janet Jukes and Kenton Miller, 'Victoria on the Move? Yeah, Right", Melbourne Star Observer (Melbourne), 19 June 1999
 VGLRL, Annual Report 1999-2000<home.vicnet net.au/-vgirl/>
 VGLRL, Enough is Enough (2000) <home.vicnet.net.au/-vgirl/>.
 VGLRL, Making Love Legal (2001) 1< home.vicnet.net.au/-vgirl//>
 EOC, Discussion Paper on Same Sex Relationships and the Law (1997) 3
 EOC, Same Sex Relationships and the Law (1998), 6 <www.eoc.vic.gov.au>
 Ibid 5.
 Davina Cooper, Sexing the City Lesbian and Gay Politics within the Activist State (1987)
 Ibid 21.
 Victoria, Parliamentary Debates, Legislative Assembly, 1 May 2001, 800 (Richard Wynne)
 Victoria, Parliamentary Debates, Legislative Assembly, Tuesday 1 May 2001,806 (Andrea McCall).
 Fax copy of this letter, dated 18 December 2000, on file with the author
 Victoria, Parliamentary Debates, Legislative Assembly, Tuesday 1 May 2001, (see eg, Victor Perton MP (Lib 819); John Lenders MP (ALP 821))
 Gary Dowsett, 'Gay and Lesbian Rights· Whatever Happened to Liberation?' (1999) 8 VGLRL Newsletter <home vicnet.net.au/-vgirl/>
 Section 1 of the Statute Law Amendment (Relationships) Act 2001 (Vic) which, together with the Statute Law Further Amendment (Relaaonships) Act 2001 (V1c), ended multiple pieces of legislation
 Jeffrey Weeks, Brian Heaphy and Catherine Donovan, Same Sex Intimacies Families of Choice and Other Life Experiments (2001) 14.
 For a much fuller discussion of these h1stoncal sh1fts, see Geoffrey Woolcock and Dennis Altman, 'The Largest Street Party in the World· The Gay and Lesbian Movement in Australia' in Barry D Adam, Jan Willem Duyvendak and Andre Krouwei, 'The Global Emergence of Gay and Lesbian Politics (1999) 326, Margaret Cruikshank, The Gay andLesbian Liberation Movement (1992)
 Cooper, above n 14, 1
 The VGLRL and the Victorian Government recently launched a joint report and website, Over the Rainbow
<http://over-the-rainbow.org> at 5 March 2004
 <www lawreform.vic.gov.au>
 Sex Discrimination Amendment Bill 2002 (Cth).
 This enabled passage of the Superannuation (Co-contribution for low income earners) Act 2003 (Cth)
 GLRL, 'GLRL Position on Same-Sex Marriage' (Press Release, 28 August 2003)<www girl org au/publications/press_releases/2003/01Sep2003_Mamage htm>
 Parsons, above n 3, 114.
 Woolcock and Altman, above n 25, 328
 Parsons, above n 3, 84