Just Cases | Season 3 | Episode 4 | Now free speech has been killed as well

How does the law balance the rights of women to access safe and legal abortions with the right to free speech and protest?

For over twenty years anti-abortion protesters have picketed abortion clinics around Australia. To combat this targeted harassment of women seeking safe and legal abortions, state governments have passed ‘safe access zone’ laws which create an exclusion zone around abortion clinics which protestors cannot enter.

Anti-abortionists argue these laws limit their free speech. Supporters of safe access zones argue these laws are vital to ensure the safety of women seeking health care.

When this law was challenged by anti-abortion protesters who had breached the exclusion zones, the High Court was faced with a major balancing act.

Storytellers:
- Dr Tania Penovic, Faculty of Law, Monash University
- Dr Caroline Henckels, Faculty of Law, Monash University

Hosts - Dr Melissa Castan & James Pattison

Further reading:
- Explainer: what are abortion clinic safe-access zones and where do they exist in Australia? (https://theconversation.com/explainer-what-are-abortion-clinic-safe-access-zones-and-where-do-they-exist-in-australia-98175)
- High Court delivers landmark ruling validating abortion clinic ‘safe access zones’ (https://theconversation.com/high-court-delivers-landmark-ruling-validating-abortion-clinic-safe-access-zones-115062)

Music in this episode:
- Lee Rosevere - ‘Start the Day’
- Lee Rosevere - ‘Waiting For the Moment That Never Comes’

Explore more Monash Law podcasts

Transcript | Just Cases | Season 3 | Episode 4 | Now free speech has been killed as well

[00:00:00] Joe O'Brien: A high court case that's being heard today. It's a challenge to the so-called safe zones that have been delineated around abortion clinics. A Melbourne woman was fined $5,000 for a. Approaching a couple going into an East Melbourne clinic back in 2016,

[00:00:21] Dr Tanya Panovich: no woman should be the target of abuse for seeing her doctor yet this is what anti-abortionists have done for decades.

[00:00:29] They have harassed, intimidated, and abused patients and staff seeking access to healthcare. Safe access zones work because they send a powerful message that our society will not condone the abuse of women. We will not. Tolerate gender-based harassment and will take steps to prevent violence against women.

[00:00:53] Professor Melissa Castan: That's Dr. Tanya Panovich from Monash Law. Speaking outside the high court in October, 2018, this high court case was pitted as a major constitutional battle. How do we balance the rights of women to access healthcare, namely safe and legal abortions with the right to free speech and protest. This is just cases.

[00:01:11] I'm Melissa Caton. And James Patterson is here with me. Hi James.

[00:01:15] James Pattison: Hi Melissa. This is a really fascinating question. So how far do your freedoms extend before they encroach on the rights of others? We heard a bit from that press conference just before from Dr. Tanya Panovich outside the high court as the case.

[00:01:29] Began and we're gonna learn about what this case is today in a moment. And we're thrilled that Dr. Panovich joins us today on just Cases. Hi Tanya.

[00:01:38] Dr Tanya Panovich: Hi guys.

[00:01:39] James Pattison: And Dr. Caroline Henkel, who was also involved with this case. Hi Caroline.

[00:01:44] Dr Caroline Henkel: Hi.

[00:01:45] James Pattison: Now you both, along with, um, your colleague, Dr. Ronley SRIs from Monash Law, made a submission to the high court in this case.

[00:01:51] And we're gonna get to that. But first of all, um, let's take it just ba back to basics. So abortion, is it lawful. In the states that this court case referred to, which is Victoria and Tasmania, Tanya,

[00:02:04] Dr Tanya Panovich: so. Abortion law is largely regulated at the state and territory level, and certain issues such as funding and approval of pharmaceuticals are regulated at the federal level.

[00:02:16] And so every state and territory has slightly different laws. So it's not a black and white issue. It is, um, it is somewhat confusing and unclear, but, um, what is not unclear is that abortion is lawful. Um, in Victoria and Tasmania, um, and after a particular gestational period, which in Victoria is 24 weeks and Tassie is 16, it is still lawful, but requires the approval of two doctors.

[00:02:43] Professor Melissa Castan: Tanya, can you paint us a picture about. These anti-abortion protests that occur outside these clinics?

[00:02:49] Dr Tanya Panovich: Yes, I can. So, so James mentioned Ronley Ferous before, and Ronley and I have been doing empirical research for two and a half years now into this type of conduct and its impact and the way it's been addressed under the law or.

[00:03:07] Hasn't been addressed under the law, which is still the case in a couple of jurisdictions. So, uh, what does this behavior include? Well, we, we've found that by positioning themselves outside clinics, individuals such as the appellants in the case we're about to talk about, have been able to target a captive audience in their efforts to discourage and dissuade and indeed prevent.

[00:03:33] Women from obtaining abortions and staff from performing them. So I'll talk about some of the things that they, um, have done. So the handing out of leaflets has been commonplace, and these leaflets have contained frightening misinformation, for example, that abortion results in infertility, relationship failure, mental illness, and cancer, and some very graphic images as well.

[00:03:56] Very graphic images. Both in pamphlets and in, um, posters and sandwich boards that are also part of this conduct. Um, we also have the handing out of plastic fetal dolls, um, by these individuals and other activities have included obstructing clinic entrances, obstructing footpaths, outside clinics, blocking patients from getting out of cars, uh, chasing, heckling, threatening, and, and verbally abusing patients and staff and typically calling them murderers and also.

[00:04:28] Taking photographs and video recordings of persons entering and leaving clinics. And these have sometimes been used in the public shaming of women who have had abortions, either online or in in local, regional communities. And we've spoken with a number of clinic staff who have told us that they have been recorded and they've felt very unsettled about.

[00:04:49] What might become of that recording, whether it might be released online and what might occur. Finally, some of these picketers would engage in bizarre conduct, such as pushing a blood splattered doll in a pram or carrying pigs organs around in prams or around their necks. Um, so,

[00:05:07] James Pattison: so Tony, if I can jump in, this sounds like the kind of conduct that would be dealt with by the law already, right?

[00:05:13] Like this sort of sounds like assault. Am I? Am I correct?

[00:05:15] Dr Tanya Panovich: Yes. Yeah, you are. You're absolutely

[00:05:17] Professor Melissa Castan: correct. Tanya. If this is already behavior that seems already covered by the law, why is this particular conduct being restricted by additional laws?

[00:05:26] Dr Tanya Panovich: Because there was a real problem with enforcement. So a lot of this conduct falls within the law of tort, private nuisance, public nuisance, for example, and the criminal law.

[00:05:37] There have been great difficulties in the enforcement of these laws because of the nature and effect of the conduct. So, um, also until safe access zones were introduced, the law didn't operate to prevent this conduct. Um, so it responded to conduct that had occurred, and, and I might just elaborate on that a little bit.

[00:05:56] So in order to address that, the chronic disruption of anti-abortion activity, clinics have needed to call the police on a regular basis. So when the police arrive. Picketers will often have disappeared, or they may even have accused the individuals that they have targeted of assaulting them. And indeed, sometimes that, uh, will have occurred because of the, the tension that arises in these circumstances and the fact that these picketers won't exist from their intrusions even when it's made clear that they're unwelcome.

[00:06:31] Sometimes patients, but more often the people who accompany them will, um. Engage in altercations with these picketers. The other, the other issue here is that for women seeking abortions efforts to enforce the law inevitably generate further incursions into their privacy. So women don't want to report the conduct to police.

[00:06:55] They don't want to help in a prosecution because of the ongoing stress and publicity. So we were told by a social worker that we interviewed. That abortion is the one medical procedure for which women are the least likely to feel energized to complain. She said that they're dealing with a crisis at that time in their lives, and they just need to get through it and move on rather than revisiting this experience over and over again through the course of the legal proceeding, which, which will further undermine their privacy.

[00:07:26] So in this regard, the, the former health minister now, state Attorney General, Jill Hennessy, has said that. The intensely private nature of the decision that these picketers seek to denounce effectively has operated to protect them from prosecution. So it's, it's largely enabled them to act with impunity and.

[00:07:48] This is really, uh, the, the gap that Safe Access Zone laws have filled.

[00:07:54] James Pattison: Can you tell us what exactly are safe access zones and how did they operate?

[00:07:59] Dr Tanya Panovich: So, safe access zones are sometimes some referred to as buffer zones or a. Bubble zones. They, they basically create a barrier around an abortion clinic in order to protect, uh, patients seeking healthcare and staff and others from certain forms of conduct.

[00:08:18] The, the forms of conduct I've just described to you, so. Certain specified behavior is prohibited within the radius of those zones, which in the case of Victoria and Tasmania, um, these were, the laws under challenge is 150 meters.

[00:08:33] James Pattison: So that's about. Is that about a, a block, two blocks, something like that.

[00:08:38] It's quite big, is what I mean. You're asking these law experts about

[00:08:40] Professor Melissa Castan: geography questions? That's right. I'm sorry. We not, I I want numbers. I have no sense of direction whatsoever.

[00:08:46] Dr Tanya Panovich: James, you've asked the wrong person. Okay, well,

[00:08:48] James Pattison: we'll say, we'll say a block or a block or two roughly, but it's quite a big exclusion zone and that particular.

[00:08:54] Um, exclusion zone was what was going to be challenged in this particular high court case. Yes. So, so enter, um, Kathleen Club. She's a protester, an anti-abortion protester. Can you tell me a little bit about her and how this case began? So.

[00:09:10] Dr Tanya Panovich: Kathleen Club is a Melbourne woman in her fifties, and she has been an active member of a group known as Helpers of God's Precious Infants, which was founded in the United States.

[00:09:23] And members of this particular group have been extremely active in a number of locations across Australia, including the area surrounding Melbourne's fertility control clinic, which. They have actively picketed six days a week for more than two decades until safe access zones were put in place in May, 2016, and it is in the safe access zone surrounding that clinic, the fertility control clinic that Mrs.

[00:09:52] Club engaged in what was found to be a calculated breach of Victoria's Public Health and Wellbeing Act. So she was convicted of engaging in prohibited behavior. In a safe access zone, so specifically communicating about abortion in a manner reasonably likely to cause distress or anxiety. When she approached a couple, entering the clinic, spoke to them and attempted to hand them anti-abortion pamphlets and John Preston in Tasmania, was that a similar situation?

[00:10:24] Um, a different, different form of picketing. Um, I, I'm reluctant to call this conduct protest. The more I become familiar with it, it's not public protest in the sense of, um, expressing disapproval of a law or policy, you know, which, which these people do as well. This is a, this is a targeted form of conduct that.

[00:10:45] Uh, clinic staff tend to refer to as vilification harassment, chronic abuse. So, um, protest is generally the term that is used and in fact, protest is a term enshrined in the Tasmanian legislation, um, that applied to Mr. Preston. So, um, so the appellant who challenged the Tasmanian legislation was John Graham Preston, and Mr.

[00:11:07] Preston is a resident of Queensland and he falls within the typical demographic of anti-abortion picketers, most of whom have been described to us as older men. So. Preston, Mr. Preston was convicted on three counts of engaging in prohibited behavior under the Tasmanian reproductive health access to terminations act for engaging in a protest, and that is a term in the legislation, a protest about abortion that was able to be seen and heard by a person accessing a clinic.

[00:11:41] So his behavior included the display of placards, one of which included a representation of a fetus.

[00:11:48] James Pattison: So Kathleen Club in Victoria?

[00:11:50] Dr Tanya Panovich: Yes.

[00:11:51] James Pattison: And uh, John Preston in Tasmania. Yes. They have both knowingly, they know these laws are in force. Yes. And they knowingly entered that exclusion zone. Yes. Or that safe access zone and continue their picketing.

[00:12:04] Dr Tanya Panovich: Indeed.

[00:12:05] James Pattison: As a result of this, they're both charged.

[00:12:08] Dr Tanya Panovich: Yes.

[00:12:09] James Pattison: They're both fined.

[00:12:10] Dr Tanya Panovich: They're both convicted and fined. Yes. So $5,000 for Kathleen Club. And three for Mr. Preston.

[00:12:17] James Pattison: And they both appeal their conviction all the way to the high court.

[00:12:22] Dr Tanya Panovich: Yes. Now

[00:12:22] James Pattison: what, what exactly were they appealing and, and why is it that the high court can.

[00:12:26] Decide this particular matter. This might, this might also be a, a Caroline question perhaps. Yeah. So

[00:12:31] Dr Tanya Panovich: I'll just maybe comment briefly and then pass over to, to Caroline. So in fact, both, both of these individuals appealed to the Supreme Court. So Kathleen Club appealed to the Supreme Court of the. Victoria and Mr.

[00:12:44] Preston appealed to the Supreme Court of Tasmania. Now, they appealed on a number of grounds, and one of those grounds was the constitutional grounds, so, so the argument that the laws under which they were convicted were constitutionally invalid, and it's the question of constitutional validity that was removed to the high court, and then these two cases were heard together.

[00:13:08] James Pattison: And the high court for our listeners who might be new to law and to Australia's legal system, um, why is it that the high court can decide a matter that involves the constitution and, and not a another court?

[00:13:19] Speaker 5: So the high court is Australia's highest court, and, um, as such, it, it has, um, you know, the final say over constitutional issues.

[00:13:27] Professor Melissa Castan: What is the constitutional issue in this case is, is there a right to protest or a right to save healthcare?

[00:13:32] Dr Caroline Henkel: Right. That's a really good question. So, unlike most other countries, Australia's constitution does not contain what we would call a bill of rights or a charter of rights. Rather, there is something in the Constitution called the implied freedom of political communication, which is not exactly a right to free speech, but you might say that at, at a.

[00:13:55] Fairly abstract level. It serves the same purpose,

[00:13:58] James Pattison: so it's our version. Of free speech or is it a sort of limited version of what is otherwise understood as free speech? Yeah, so

[00:14:07] Dr Caroline Henkel: if we call it a right to free speech, that would be sort of grossly oversimplifying it. I'll tell you what the difference is between a right to free speech and the implied freedom of political communication.

[00:14:18] First of all, um, freedom of political communication is not something that's written down in the Constitution. It's something that the high court found was implied. When reading certain sections of the Constitution that in order for people to be able to be fully informed and exercise, um, their right to vote in the Constitution, they needed to be able to communicate about political matters.

[00:14:42] And political matters is something that's construed quite broadly, not only just about elections and voting for, for, for certain people in elections, but a number of matters that kind of, I suppose you could say broadly. I discussed and debated in the political sphere. And, you know, something like abortion law is clearly

[00:15:03] Professor Melissa Castan: so, so discussion or protest or ex um, expressing yourself on whether a law is a good law or a bad law, or whether it's an appropriate restriction or a, a appropriate arrangement.

[00:15:14] Is that the kind of political speech that's covered by this, this implied Right,

[00:15:18] Dr Caroline Henkel: right. It, it plainly falls within, within the, the freedom of political communication. And there's just one other difference between the freedom and then the right to free speech is that our constitution only protects the freedom of.

[00:15:29] Political communication, not communication in general. So it's a lot narrower than what, you know, we see in the, the United States, for example, where the right to free speech has been held to encompass things like commercial speech. So advertisements, um, pornography and, and the like, our, our writers or our freedom, sorry, is, is much narrower than that.

[00:15:50] Professor Melissa Castan: So, Caroline, what was the constitutional question that the court had to decide in this case? So

[00:15:56] Dr Caroline Henkel: the. Court had to decide whether or not the Tasmanian and the Victorian laws unjustifiably limited the freedom of political communication, so laws can restrict political communication. But they must not do so unjustifiably, which I realize is a rather vague and nebulous term.

[00:16:16] So I can, I can talk about that a bit more if you want.

[00:16:18] James Pattison: Let's take a quick step backwards. Mm-hmm. And look at the involvement of you, Tanya, Caroline, and Ronley in this particular high court case. You were speaking outside the high court, Tanya, why was that and what was your involvement?

[00:16:32] Dr Tanya Panovich: Caroline Ronley and I put submissions in and on the basis of those submissions, we were granted leave to appear as amicus Qi.

[00:16:40] Uh, also it's Latin for friend of the court and there were two other friends of the court in the club proceeding. They were the fertility control clinic and the Human Rights Law Center. And there was, uh, there was one amicus in the, uh, Preston proceeding as well. Is it usual for, um, outside parties to be able to put written submissions into a court case in that way?

[00:17:01] In our system, it's actually very unusual, so it's very common in the United States, but less common in Australia. So it was a real honor to actually be granted. That leave and be involved in the proceeding. But we, we felt that with, with Caroline's constitutional expertise and with the empirical research that we had undertaken that, that we had a contribution to make and, uh, we, we would make it,

[00:17:27] Professor Melissa Castan: it was really unusual that, that you were able to get that specials written submissions in.

[00:17:32] Um, there are a lot of different parties involved in this case.

[00:17:35] Dr Tanya Panovich: Yes. Um, a lot of, a lot of, um, different amicus parties you meet. So, so that press conference that we, we went to at the beginning of this podcast, um, the speakers there were, were representatives from the three Amichi, the three amigos in the club proceeding.

[00:17:51] And it was a real privilege to be able to work with the women from Morris. Blackburn, who represented the fertility control clinic and the Human Rights Law Center and the wonderful Dr. Susie Allenson, who worked at the fertility control Clinic as a clinical psychologist for 26 years and has represented a longstanding voice of reasoned advocacy for safe access zones.

[00:18:15] Susie has done more than any other person to achieve safe, safe access zone legislation in Victoria. And her generosity and compassion and her professionalism really are an inspiration to us all. So it was such an honor to be able to appear at that media conference alongside her.

[00:18:34] Professor Melissa Castan: You are listening to Just Cases, a short break for a couple of important messages for law enthusiasts and nerds.

[00:18:41] Monash Open Day is coming up on Sunday, the 4th of August at the Clayton campus. If you are in Melbourne and thinking a law degree might be your next move, come along to open day. Monash University's Australia's biggest university and this is our biggest day of the year. The campus is always pumping.

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[00:19:10] James Pattison: I actually thought that, um, Harvey Specter is a poor man's Don Draper, but that's a whole other conversation.

[00:19:15] Professor Melissa Castan: For more info and plan your visit to open day, head to Monash, do edu forward slash open day

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[00:19:54] But we really appreciate any answers that you do decide to share. You'll be helping to make just cases even better than it is. Just head to just Cases podcast.com/survey. That's just cases podcast.com/survey. And now back to Tanya Panovich and Caroline Henkel, who are discussing how the high court decides to balance freedom of political communication with the right to access safe and legal abortions.

[00:20:26] Professor Melissa Castan: So with all that information that you provided to the court and with the, the two sides obviously argue their case. What did the high court actually decide in this case?

[00:20:34] Dr Caroline Henkel: What it decided, first of all, was that club had not been engaging in. Political communication, but that Preston had. But nevertheless, they decided to look at both the Victorian and the Tasmanian laws in order to determine whether or not, um, what is, what they call the burden on political communication was justifiable.

[00:20:54] And this is rather a complicated form of judicial reasoning, so I'll try and explain it. Basically, the court needed to determine whether or not the law served a legitimate objective, and then secondly, whether or not the law. Itself was proportionate to its objective, and the method of judicial reasoning that they use in this kind of case is called proportionality analysis, which has been developing in the high courts cases over a number of years, but recently has become.

[00:21:28] Uh, uh, there's, there's more consensus among the judges that this is the appropriate method of analysis. Six out of seven judges now use this, this methodology when they're deciding these sorts of cases.

[00:21:40] Professor Melissa Castan: So basically it's a, is it's a way of kind of the judges weighing up was the restriction on people's.

[00:21:46] Political communication, a reasonable measure given what that, what was at stake on the other side. That is someone's access to healthcare and someone's free passage through a normal street in Melbourne or in Hobart. And so it's just a weighing up exercise, right?

[00:22:00] Dr Caroline Henkel: I suppose in a nutshell. Yes. Um, although there are more kind of technical steps through that process.

[00:22:05] So first of all, they looked at the purpose of the law and they all agreed that it was. Absolutely beyond doubt that the law served a significant and important objective that women who were seeking an abortion would be, should be entitled to do so safely, privately, and with dignity, and without being, you know, harangued or molested by protesters.

[00:22:24] And then they looked at the law itself and they needed to determine, first of all, whether the way the law was written was connected to that objective, which it clearly was. And then the second step is, is now this is where it gets a little bit. To my mind, interesting whether there's any alternative ways that the law could have been written that would've, um, still achieved that objective of protecting women to the same extent, but would have impacted less on the freedom of political communication.

[00:22:55] And this is an interesting question because you could say, well, if the law's at 150 meter radius away from the abortion clinics, why shouldn't it be 120 meters or 100 meters, for example? Which would. Allow or, or burden less the implied freedom on the, the people who wanted to express those anti-abortionists views.

[00:23:13] But here, the judges said that it wasn't the court's role to make those kind of fine grain distinctions about, you know, 130 or 120 meters rather. This was something that governments and parliaments should be effectively responsible to do because they're closest. To the communities where this is happening, they have a greater understanding and greater expertise in this area.

[00:23:36] And it wouldn't be the role of the court to sort of come in and substitute some of that reasoning or,

[00:23:41] Professor Melissa Castan: so you're saying that the court said, look, it's our job to decide whether there's political communication here and whether it's been burdened in a reasonable way or or a proportionate way or not. But it's not the court's job to decide, oh, it's a hundred meters.

[00:23:53] No, it's 150 meters. 'cause that kind of attention to detail is something that Parliaments and the people that work for Parliament should. A much better place to make those assessments. They're better place to do

[00:24:02] Dr Caroline Henkel: that. Yeah. 'cause they're embedded within the communities. They know what's going on and they've got greater expertise in policy making.

[00:24:08] The court does not wanna be making policy, government policy.

[00:24:11] Professor Melissa Castan: So in the end, did the, did the court find that safe access zones are, are permitted in the way that the Victorian and Tasmanian parliaments had written them? Yes, they did. In both cases, the laws were upheld.

[00:24:22] James Pattison: Kathleen Club spoke to the media after the high court handed down its judgment and here's a little bit of what she had to say.

[00:24:29] Dr Tanya Panovich: I'd just like to say it's not enough that so many babies have been killed, but now free speech has been killed as well.

[00:24:36] James Pattison: Tanya has this judgment killed free speech.

[00:24:38] Dr Tanya Panovich: Absolutely not. So to begin with, as Caroline's just explained, the, the judgment is not about free speech. It's about the implied freedom of political communication, which is narrower.

[00:24:49] It's a right to communicate about political matters and representative government, and the judgment hasn't killed that either. But, um, in any event, it has not killed the right to free speech that the right to free speech is not absolute expressing deeply held views does not carry with it a license to harass.

[00:25:07] And intimidate others.

[00:25:09] James Pattison: So is it that idea that your rights bring with them also? Uh, responsibilities and obligations. So your right to free speech or freedom of political communication is not absolute. So you have that right up until it starts adversely affecting somebody else.

[00:25:26] Dr Tanya Panovich: Well, well, I think that the way to look at it is that the state has an obligation to.

[00:25:30] Affect, protect and fulfill human rights. So it needs to, it needs to avoid breaching the rights of individuals, and it also needs to protect individuals from abuses, perpetrated by private actors, such as anti-abortionists. So safe access zones. Enable the state to protect the rights of others so they, they strike an appropriate balance between the picketers rights to express their views and upholding the rights of patients, staff, and others.

[00:25:59] And I might say that the picketers. Have continued to express their views. So in East Melbourne, um, they've moved down the road and they're still there. Um, they're still there expressing their views to anyone, uh, that cares to hear them, but, but by distancing them that that targeting of individuals has stopped.

[00:26:21] James Pattison: Finally, how, how does it feel for you after so many years of involvement in this particular matter, uh, to see this decision of the high court?

[00:26:30] Dr Tanya Panovich: Well, it's, it's incredibly gratifying because it means that safe access zones are here to stay. The jurisdictions that haven't moved to introduce safe access zone legislation now can, and those jurisdictions are South Australia and Western Australia.

[00:26:46] So it is my hope. That by the end of this year, they might have introduced a bill. They, they certainly are actively considering that now, uh, thanks to the judgment. So it is an absolute victory for women's rights, for respect, for women's choices and women's privacy, safety and dignity. And it's, it's really.

[00:27:08] Heartening to have been involved in the case. Tanya and Caroline, thanks for speaking to Just Cases. Thanks very much. Thank you,

[00:27:16] James Pattison: Dr. Tanya Panovich and Dr. Caroline Henkel from Monash Law. And there's a fascinating backstory to how abortion became legal in Victoria back in the 1960s. It involves a court case from 1969, and if you like just cases, this is right up your alley.

[00:27:32] Uh, this particular court case is all covered in the podcast Gertie's Law. It's being released this coming Monday, Monday the 15th of July, and the episode looks at the concept of judge made law and how judges can make law in matters that are kind of too political for Parliament to deal with competently.

[00:27:50] Subscribe now to Gertie's Law in your podcast app to get notified. When the episode is released and we love hearing your story suggestions, get in touch with us on Twitter. Our handle is at Just Cases show and remember, you can take our one question survey at the Just Cases website. That's just cases podcast.com/survey.

[00:28:12] Professor Melissa Castan: See you next time.