"10 Point Plan", was introduced by the Howard Government. The amendments substantially restricted Native Title by narrowing the right to negotiate and extinguishing Native Title on most pastoral and mining leases granted before 1994. Cases after the 1998 amendment 1998–2002 – Yorta Yorta Yorta Yorta v Victoria, was a native title claim by the Yorta Yorta Aboriginal people of north central Victoria, which was dismissed by Justice Olney of the Federal Court in 1998. Appeals to the Full Bench of the Federal Court in 2001, and the High Court in 2002 were also dismissed. The determination by Justice Olney in 1998 ruled that the 'tide of history' had 'washed away' any real acknowledgement of traditional laws and any real observance of traditional customs by the applicants. The 2002 High Court decision adopted strict requirements of continuity of traditional laws and customs for native title claims to succeed. 1998–2003 – Miriuwung Gajerrong Ward v Western Australia (1998) was an application made on behalf of the Miriuwung and Gajerrong people of the east Kimberly, over land in Western Australia and the Northern Territory. Justice Malcolm Lee of the Federal Court ruled in their favour in recognition of the native title. Western Australia appealed the decision to the Full Court of the Federal Court, then to the High Court. The High Court held in Western Australia v Ward that native title is a bundle of rights, which may be extinguished one by one, for example, by a mining lease. In this case, the lease did not confer 'exclusive possession', because the claimants could pass over the land and do various things. But some parts of native title rights were extinguished, including the rights to control access and make use of the land. The claim was remitted to the Full Court of the Federal Court to determine in accordance with the decision of the High Court. The claimants reached an agreement about the claim area and a determination was made in 2003. "Exclusive possession native title was recognised over Lacrosse Island, Kanggurru Island, Aboriginal reserves within the Kununurra townsite, Glen Hill pastoral lease and Hagan Island. Non-exclusive rights were recognised over a number of areas including islands in Lake Argyle." 2001 – Yarmirr Yarmirr v Northern Territory (2001), was an application made on behalf of a number of clan groups of Aboriginal people to an area of seas and sea-beds surrounding Croker Island in