 Australia did not experience native title litigation until the 1970s, when Indigenous Australians (both Aboriginal and Torres Strait Islander people) became more politically active, after being included in the Australian citizenry as a result of the 1967 referendum.In 1971, Blackburn J of the Supreme Court of the Northern Territory rejected the concept in "Milirrpum v Nabalco Pty Ltd" (the "Gove land rights case").The Aboriginal Land Rights Commission was established in 1973 in the wake of "Milirrpum".