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It was later suggested that the external affairs power and the power to regulate the relations of the Commonwealth and the Pacific islands be combined, for example "external affairs, including the relations of the Commonwealth with the islands of the Pacific", (a case which dealt with the High Court of Australia's ability to hear appeals from the Supreme Court of Nauru) and was held obiter as being "conferred for reasons entirely unrelated to judicial power".

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In his speech, Edmund Barton summarised the situation as follows: It has been suggested that this sub-section is embraced in the preceding one-"External affairs and treaties." That is arguable; it is quite possible that it may be true; but there are a very large number of people who look forward with interest to the Commonwealth undertaking, as far as it can as part of the British Empire, the regulation of the Pacific Islands...

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Photographed from the Southbank Promenade along the Yarra River.

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