 The High Court of Australia, which had appellate jurisdiction before 1975, recognized aboriginal title in Papua New Guinea—decades before it did so in Australia—in "Geita Sebea v Territory of Papua" (1941), "Administration of Papua and New Guinea v Daera Guba" (1973) (the "Newtown case"), and other cases.The Supreme Court of Papua New Guinea followed suit.Schedule 2 of the Constitution of Papua New Guinea recognizes customary land tenure, and 97% of the land in the country remains unalienated.