recognition. In particular, the content of aboriginal title may be tied to the traditions and customs of the indigenous peoples, and only accommodate growth and change to a limited extent. Extinguishment Aboriginal title can be extinguished by the general government, but again, the requirement to do this varies by country. Some require the legislature to be explicit when it does this, others hold that extinguishment can be inferred from the government's treatment of the land. In Canada, the Crown cannot extinguish aboriginal title without the explicit prior informed consent of the proper aboriginal title holders. New Zealand formerly required consent, but today requires only a justification, akin to a public purpose requirement. Jurisdictions differ on whether the state is required to pay compensation upon extinguishing aboriginal title. Theories for the payment of compensation include the right to property, as protected by constitutional or common law, and the breach of a fiduciary duty. Percentage of land Native title in Australia - (16% of the country's land area) Indian reserves in Canada - (0.2804% of the country's land area) Native Community Lands in Bolivia - (15% of the country's land area) Indigenous territories in Brazil - (13% of the country's land area) Indigenous territories in Colombia - (31.5% of the country's land area) Indian reservations in the United States - (2.308% of the country's land area) History by jurisdiction Australia Australia did not experience native title litigation until the 1970s, when Indigenous Australians (both Aboriginal and Torres Strait Islander people) became more politically active, after being included in the Australian citizenry as a result of the 1967 referendum. In 1971, Blackburn J of the Supreme Court of the Northern Territory rejected the concept in Milirrpum v Nabalco Pty Ltd (the "Gove land rights case"). The Aboriginal Land Rights Commission was established in 1973 in the wake of Milirrpum. Paul Coe, in Coe v Commonwealth (1979), attempted (unsuccessfully) to bring a class action on behalf of all Aborigines claiming all of Australia. The Aboriginal Land Rights Act 1976, established a statutory procedure that returned approximately 40% of the Northern Territory to Aboriginal ownership; the Anangu Pitjantjatjara Yankunytjatjara Land Rights Act 1981, had a similar effect in South Australia. The High Court of Australia, after paving the way in Mabo No 1 by striking down a State statute under the Racial Discrimination Act 1975, overruled Milirrpum in Mabo v Queensland (No 2) (1992). Mabo