of a contravention of the Act to the Australian Human Rights Commission. If the complaint cannot be resolved, then an application alleging "unlawful discrimination" may be made to the Federal Court of Australia or to the Federal Circuit Court. When such allegations are upheld, the court may make orders, including for compensation. Analysis Constitutionality The source of the federal parliament's power to pass the Act is the external affairs power contained in section 51(xxix) of the Australian Constitution. Under that power, the federal parliament implemented international obligations arising under the 1965 International Convention on the Elimination of All Forms of Racial Discrimination, which Australia ratified in September 1975. The High Court of Australia confirmed that the external affairs power was a valid source of power for the Act in Koowarta v. Bjelke-Petersen (1982), and again in Mabo v Queensland (No 1) (1988). While the AHRC maintains that the Act provides an appropriate balance between freedom of speech and freedom from racial vilification, legal academics Forrester, Finlay and Zimmermann have suggested that section 18C of the Act, enacted in 1995, may be unconstitutional on the basis that it is inconsistent with the constitutional implied freedom of political communication. Law reform proposals Section 18C of the Act has been a topic of debate, especially in recent years. While some conservative politicians have claimed the bar for breaching 18C is too low, courts have consistently shown that this is not the case, and to fall within 18C the speech must have "... profound and serious effects, not to be likened to mere slights." In 1995, left-wing ABC journalist Phillip Adams argued against the provision, saying that a better response to expressions of racial hatred was "public debate, not legal censure". In 2011, the Federal Court ruled that commentator Andrew Bolt had contravened section 18C of the Act as he could not rely on the exemptions under Section 18D. Bolt said that the verdict was "a restriction on the freedom of all Australians to discuss multiculturalism and how people identify themselves". The political allegiance of the presiding judge to the Australian Labor Party has also been raised as an issue (Justice Bromberg had once stood for Labor pre-selection). In 2013, members of the Abbott Government proposed significant changes to section 18C in a draft bill put on public exhibition, which would have substantially limited the scope of the prohibition. The Attorney-General, George Brandis, defended