Fraser government continued to implement many of the previous government's initiatives, under the description "self-management" rather than self-determination. 1979 – Paul Coe case In 1979, Paul Coe, a Wiradjuri man from Cowra, New South Wales, commenced, as plaintiff, an action in the High Court of Australia arguing that at the time white people came to Australia, Aborigines were there and therefore the Court had to recognise their rights. Coe's claim was never heard due to serious deficiencies with his statement of claim. Justice Gibbs said, at paragraph 21, 'The question what rights the aboriginal people of this country have, or ought to have, in the lands of Australia is one which has become a matter of heated controversy. If there are serious legal questions to be decided as to the existence or nature of such rights, no doubt the sooner they are decided the better, but the resolution of such questions by the courts will not be assisted by imprecise, emotional or intemperate claims. In this, as in any other litigation, the claimants will be best served if their claims are put before the court dispassionately, lucidly and in proper form'. 1981 – Pitjantjatjara Yankunytjatjara Land Rights Act The South Australian Anangu Pitjantjatjara Yankunytjatjara Land Rights Act 1981 was introduced by Premier Don Dunstan in November 1978, several months prior to his resignation from Parliament. An amended bill, following extensive consultation, was passed by the Tonkin Liberal Government in March 1981. This legislation gave significant rights well in advance of any other to date in Australia. In 1981, SA Premier Tonkin returned of land (10.2% of the state's land area) to the Pitjantjara and Yankunytjatjara people. However, it did not give the people the power of veto over mining activities; any disputes would need to be resolved by an independent arbitrator. In 1984 Premier John Bannon's Labor Government passed legislation to return lands to the Maralinga Tjarutja people. The legislation was proclaimed in January 1985 and was followed by a ceremony in the desert attended by Maralinga Tjarutja leader Archie Barton, John Bannon and Aboriginal Affairs Minister Greg Crafter. This granted rights over of land in the Great Victoria Desert, including the land contaminated by the British nuclear weapons testing at Maralinga. Mabo and the Native Title Act 1988–1992 – Mabo Mabo v Queensland (No 2) (1992) was the foundational case for native title in Australia. In 1992 the doctrine