86 Unwanted and ambivalent citizenship Burney became the first indigenous Australian woman elected to the Australian Lower House. The extract from her maiden speech given at the head of this section demonstrates the symbolic as well as legal importance of the referendum and the way in which it related to individuals’ relationships with the Australian State and their experiences of citizenship and noncitizenship. This context helps to locate the words of activist Chicka Dixon in a public speech in 1967, in the lead-up to the vote: There’s a simple reason why I want a huge ‘Yes’ vote on the Aboriginal question at next Saturday’s referendum: I want to be accepted by white Australians as a person. There are scores of other reasons why the vote should be yes. But for most Aborigines it is basically and most importantly a matter of seeing white Australia finally, after 179 years, affirming at last that they believe we are human beings.21 Dixon explains that he is fighting a form of dehumanisation that has played an important role in the ways in which today’s States have developed. It is not essential to theoretical liberalism, but it is certainly part of how it was created and how it has played out in practice. From the Latin, meaning ‘nobody’s land’, ‘terra nullius’ refers to the affirma tion that the land of Australia was empty of people before European settlers arrived.22 There is dispute about whether or not terra nullius was official policy in the early years of the colony in Australia.23 However it happened, though, in Aus tralia the notion of terra nullius took hold. Seen in this context, Chicka Dixon’s statement and that of Linda Burney, for example, take on a yet thicker meaning. Indeed, in the context of this level of dehumanisation, it is clear that an important part of what such activists were seeking in citizenship was impossible without inclusion in the Australian census. They wanted to have a recognised existence 21 Chicka Dixon, in the Sydney Sun-Herald 21 May 1967. This is cited, with the same emphasis, in several places. For example, see Russell McGregor (2011) Indifferent Inclusion: Aboriginal People and the Australian Nation, Aboriginal Studies Press; Attwood and Markus 2007 ibid. 22 For example, see Christabel Chamarette (2000) ‘Terra Nullius Then and Now: Mabo, Native Title, and Reconciliation in 2000’, pp. 167–172 in Australian Psychologist 35(2). The year 1992 marks the end of a ten-year battle by Eddie Mabo and four other members of the Meriam people to prove their traditional claims to land on Murray Island in Northern Queensland. Importantly, the court also found that Australia was not a terra nullius at the point of European settlement, though it explicitly stated that this could not be used to challenge the sovereignty of Australia. Mabo v. Queensland 175 CLR 1 (1992). For a useful discussion of the case and its implications, see for example Gerry Simpson (1993–1994) ‘Mabo, International Law, Terra Nullius and the Stories of Settlement: An Unresolved Jurisprudence’, pp. 195–210 in Melbourne University Law Review 19. 23 For example, see Stuart Banner (2005) ‘Why Terra Nullius? Anthropology and Property Law in Early Australia’, pp. 95–131 in Law and History Review 23 (1); Merete Borch (2001) ‘Rethink ing the Origins of Terra Nullius’, pp. 222–239 in Australian Historical Studies 32.