right of women to "rise to positions from which they may take part in political speech as [politically persuasive] religious leaders." Any such constitutional protection would depend on a court finding that the anti-discrimination laws, first, effectively burdened political speech (as relevant to the Commonwealth Parliament) and, secondly, disproportionately burdened such speech. Right to vote The Constitution is silent as to many aspects of the democratic process, leaving these details to be provided by Parliament. The Constitution does however require in sections 7 and 24 that the members of Parliament be "directly chosen by the people". In 1975 two judges of the High Court suggested that these requirements may amount to a right to vote, holding "the long established universal adult suffrage may now be recognized as a fact and as a result it is doubtful whether ... anything less than this could be described as a choice by the people." In 1983 the High Court took a limited view of the right to vote in R v Pearson; Ex parte Sipka. The High Court Judge Michael Kirby, writing extrajudicially in 2000, said that "...in Australia, there may be a basic right to vote implied in the text of the constitution itself". Prior to 2006 prisoners were only disenfranchised if they were serving sentences of three years or more. 2006 legislation sought to disenfranchise all prisoners, regardless of the length of their sentence. The validity of the disenfranchisement was challenged by Vickie Roach who was serving a four-year gaol term for negligently causing serious injury in a car accident and her legal team comprised Ron Merkel, QC and Michael Pearce, SC. In 2007 the High Court held in Roach v Electoral Commissioner that the requirement that members be "directly chosen by the people" conferred a limited "right to vote". In principle, these words guaranteed qualified universal franchise, and limited the Federal government's legislative power to limit that franchise. The court held that removing right to vote for serious misconduct was acceptable and that the previous legislation was valid, however imprisonment failed as a method of identifying serious criminal misconduct such that the 2006 amendments were invalid. The 2006 legislation was again considered in Rowe v Electoral Commissioner, where the High Court held that amendments restricting the enrolment of voters once an election has been called were also invalid. * The High Court subsequently held that closing the electoral roles 7