her, the court did not need to decide about the nature of section 41, whether it was a guarantee or a transitional provision. However, some of the judges did address the issue in obiter dicta. Justice Menzies said: "The character of s. 41 is that of a permanent constitutional provision. It is not a provision to make temporary arrangements for the period between the establishment of the Constitution and the making of Commonwealth laws. It applies to a person, who, in 1901, had or who, in the future, acquires particular voting rights by the laws of a State." Justice Gibbs was more reserved, saying: "The view of Quick and Garran, that s.41 assures the right to vote at Commonwealth elections only to persons whose right to vote at State elections was acquired before the framing of a franchise by the Commonwealth Parliament... is far from clearly correct, but I find it unnecessary to express a final opinion upon it." Although the court did not reach a conclusion about the nature of section 41, since it was unnecessary to decide that question, the various judgments did indicate that the section was not a temporary or transitional provision, but was rather a guarantee of the right to vote for all who could vote in their state. Consequences At the 1972 federal election, later in the year, the Whitlam Labor government was elected, with Lionel Murphy becoming the new Attorney-General. The Whitlam government lowered the voting age at federal elections to 18 in 1973. The states of Victoria, Tasmania and Queensland, which still had a voting age of 21, soon lowered their voting ages to 18 also. The issue of the nature of section 41, which had not been decided in this case, was considered again in 1983 in the case of R v Pearson; Ex parte Sipka. By that time, Lionel Murphy had been appointed to the High Court, and was able to advocate his interpretation of the section. However, Murphy was in lone dissent, since the six other justices took the narrower view of the section. References High Court of Australia cases Australian constitutional law 1972 in Australian law 1972 in case law