necessary implication, criticising it as an "inflexible rule". According to the joint judgment, the relevant question was whether Parliament intended for the statute to bind the Crown. The intention of Parliament could be ascertained by reference to the content and objectives of the statute. Justice Brennan Justice Brennan concurred with the joint judgment, noting his view that employees and agents of the Crown should not be exempt from criminal laws. Subsequent action Bropho's successful appeal did not prevent the redevelopment of the Swan Brewery. Later in 1990, Minister Carmen Lawrence gave her consent to the redevelopment, overriding the prohibition in Section 17 of the Aboriginal Heritage Act 1972. Bropho successfully challenged Lawrence's decision in the Supreme Court of Western Australia, but the Western Australian government won on appeal to the Court of Appeal. References Footnotes Cited texts (case note). High Court of Australia cases 1990 in Australian law 1990 in case law Sovereign immunity