schools. Chief Justice of the High Court (1981–1987) In 1981, Gibbs was appointed Chief Justice after the retirement of Sir Garfield Barwick. The first notable case to come before his court was Koowarta v Bjelke-Petersen, decided in 1982. This case upheld the Racial Discrimination Act 1975 with a majority of the Court finding that the external affairs power allowed the Commonwealth to pass such legislation as a consequence of Australia's obligations under the Convention on the Elimination of All Forms of Racial Discrimination. Gibbs dissented, finding that the Commonwealth might have such powers only in relationships with other nations and only if the treaty arranged with other nations was "international in character". The external affairs power was expanded further in the case of Commonwealth v Tasmania in 1983 known as the Tasmanian Dams case. The High Court upheld the World Heritage Properties Conservation Act 1983 passed by the Commonwealth Parliament to stop the Government of Tasmania from building a dam on the Franklin River which had been nominated for World Heritage Site status. The majority of the court found that the external affairs power enabled the Commonwealth Parliament to pass such legislation under the Convention Concerning the Protection of the World Cultural and Natural Heritage. Gibbs again dissented, finding that the use of the external affairs power should be limited by the status of Australia as a federation and if the Commonwealth was granted too much power under section 51 of the Australian Constitution, it would upset the "Federal balance". The latter part of Gibbs' tenure as Chief Justice was dominated by allegations of impropriety against Lionel Murphy, a fellow justice of the High Court. The Age newspaper published transcriptions of conversations between Murphy and NSW solicitor Morgan Ryan, alleging an improper relationship between the two men in February 1984. Two Senate Committees were established to look into the matter along with the Stewart Royal Commission in NSW to look into the tapes. A lengthy court case ensued resulting in Murphy's acquittal. When the Stewart Royal Commission published a secret volume of conversations between Murphy and Ryan, Gibbs insisted on reading the Royal Commission Report and advised Lionel Bowen, the Commonwealth Attorney-General, that some justices intended making public their reluctance to sit with Murphy in 1986. Lionel Bowen set up a Parliamentary Commission of Inquiry consisting of three retired judges in 1986 to inquire into the claims. However, this commission