due to his reputation at the bar. During his service, he was appointed as a Royal Commissioner in the National Hotel Royal Commission following allegations that the hotel was the centre of a network of vice including a call girl ring with support of senior members of the Queensland Police Force. Gibbs found that the allegations were not correct. Critics such as Evan Whitton and Richard Ackland claim that Gibbs inappropriately followed the hearsay rules, excluding a great deal of evidence despite the fact that Royal Commissioners are not bound to follow such rules. He also chaired a committee of inquiry into the expansion of the Australian sugar industry. High Court Justice (1970–1981) In 1970, Gibbs joined the High Court of Australia replacing Sir Frank Kitto. During his early years on the Court, there was high turnover of judges, with Sir Victor Windeyer retiring in 1972, Sir William Owen dying in 1972, Sir Cyril Walsh dying in 1973 and Sir Douglas Menzies dying in 1974. As a result of this high turnover, Gibbs rapidly became second in seniority behind Sir Garfield Barwick. Gibbs' first significant case was Strickland v Rocla Concrete Pipes Ltd in 1971, a landmark trade practices case which significantly expanded the powers of the Commonwealth under section 51(xx) of the Constitution, the corporations power. He was in the minority. In the Curran case decided in 1974, Gibbs was part of the majority ruling in favour of the legality of a tax minimisation scheme. As a result of the proliferation of similar schemes, John Howard as Treasurer introduced retrospective legislation which was subsequently passed by the parliament. The AAP Case in 1975, examined the nature of the appropriations power in section 81 of the Constitution and the incidental power in section 51(xxxix) of the Constitution. The Appropriation Act (Number 1) provided for certain sums to be appropriated to the Australian Assistance Plan to enable grants to be made to Regional Councils for Social Development. The Victorian Government disputed the powers of the Commonwealth to legislate for such purposes. In his dissenting judgement, Justice Gibbs held that the words of Section 61 "make it clear that the Executive cannot act in respect of a matter which falls entirely outside the legislative competence of the Commonwealth". Gibbs was part of a 6:1 majority in the DOGS Case in 1981, which found that the Commonwealth could provide financial assistance to non-Government