conditions. The emphasis on the need for a dispute has been said to have resulted in the prevention limb of the Federal parliaments power going largely unused. There were no federal common rule awards until Victoria referred powers to the Commonwealth, in 2003 to provide for the Australian Industrial Relations Commission to make common rule awards for Victoria. The constitutional basis for the regulation of terms and conditions of employment changed as a result of the Workplace Relations Amendment (Work Choices) Act 2005 (Cth), which did not rely on the Australian parliament's conciliation and arbitration power instead being primarily founded on the corporations power. WorkChoices was replaced by the Fair Work Act 2009, which was similarly founded on the corporations power and not the conciliation and arbitration power. In addition the Fair Work Act relied on a referral of power from most States. The Fair Work Act established common rule awards called "Modern Awards" that are of general application and set out minimum terms and conditions for particular industries and occupations. there were 122 modern awards of general application. References Further reading Australian constitutional law High Court of Australia cases 1910 in case law 1910 in Australian law Australian labour case law Labour disputes in Australia Inconsistency in the Australian Constitution cases