Judicial Independence in the 21st Century

Sir Buri Kidu Lecture Series, Port Moresby

Justice Rangiah1 1 October 2026

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Tenkyu long singautim mi long toktok wantaim yu. Mi hamamas long toktok waintaim yu plas.

I am delighted to have been asked to deliver this lecture, named in honour of Sir Buri Kidu, Chief Justice of the National and Supreme Courts of Papua New Guinea between 1980 and 1993.

It is appropriate that my topic concerns the importance of judicial independence. It was under the leadership of Sir Buri that judicial independence was firmly reasserted in the wake of the so-called “Rooney Affair”, an early flashpoint in relations between the executive and the judiciary in Papua New Guinea. It is appropriate to acknowledge Sir Buri as a towering figure in the development of Papua New Guinea’s legal system. I will return to his legacy later.

Why is judicial independence important? The rule of law is indispensable for the functioning of any democratic society. And an indispensable part of the rule of law is that all people and institutions are treated equally before the law. Equal treatment before the law requires administration of the law by a judiciary that is, and is perceived to be, fair and independent. But when the executive undermines the independence of the judiciary, it undermines the perception of fair, independent and equal treatment before the law and therefore undermines the rule of law.

There are growing threats to judicial independence around the world, and these threats are exemplified by events in the United States of America. The President of the United States has traditionally been described as “the leader of the free world”. Yet President Donald Trump has repeatedly and consistently sought to undermine the independence of courts and judges, and therefore the democracy of the United States.

To give one example, on 30 May 2026, the President unleashed a furious rant against a Federal judge on his “Truth Social” social media platform.2 The President was upset about a ruling made by Judge Cooper concerning the Kennedy Center. The Kennedy Center is a performing arts centre opened in 1971 and located on the eastern bank of the Potomac River in Washington DC. It was created under the National Cultural Center Act of 1958 and is regarded as a “living memorial” to President John F Kennedy.3

In 2025, President Trump sacked the Center’s board of trustees and replaced it with a hand-picked board, which he now chairs.4 The new board promptly voted to change the institution’s name to the “Trump-Kennedy Center”.5

A lawsuit was brought challenging the decision to change the Kennedy Center’s name. Judge Cooper ruled that the change was unlawful, holding that, “Congress gave the Kennedy Center its name, and only Congress can change it”.6 The judge granted a permanent injunction restraining the board from representing that the Center was named for anyone but John F Kennedy.7

That is what we would recognise as an orthodox exercise of judicial independence and operation of the rule of law. However, President Trump issued a barrage of furious insults against the judge. He wrote, amongst other things, “our Court System is RIGGED, no different than our Political System is RIGGED, and the people of our Country know it, and that is why I got overwhelmingly elected President”.8

In 2024, escalating attacks upon the federal judiciary led Chief Justice John Roberts of the United States Supreme Court to identify four categories of threats to judicial independence in his Year End Report. They are violence; intimidation (including through public officials’ statements and calls to impeach federal judges); disinformation; and defiance of lawfully entered judgments.9

President Trump’s vitriol now extends to judges of the Supreme Court on the occasions when they have defied his will. In February 2026, six judges of the Supreme Court struck down the President’s signature tariff policy, ruling that his use of emergency powers to impose tariffs on dozens of countries was unlawful. The President ranted, “They also are, frankly, a disgrace to our nation those justices”. He called the majority judges, “fools and lapdogs”, who are, “very unpatriotic and disloyal to our Constitution”. He accused them of being, “swayed by foreign interests and a political movement”.10

In September 2026, seven Supreme Court judges rejected President Trump’s attempt to restrict “mail-in voting” for the mid-term elections in November.11 The President said, “these are not the people I interviewed to serve on the United States Supreme Court, they are merely a shell of their original selves”.12 He claimed that the Supreme Court is, “costing the United States Trillions of Dollars with shockingly bad rulings”.13

There are many other examples of President Trump using gratuitously insulting and intimidatory language against particular judges, including: “Crooked”; “USA HATING”; “MONSTERS”; a “Radical Left Lunatic of a Judge, a troublemaker and agitator”; a “Low IQ person”; “a disgrace to our nation”; an “embarrassment to their families”; and “Wacky, Nasty, Crooked, and totally Out of Control”.14

The contempt shown by the Trump administration for judicial rulings is not confined to the vicious language used. It is also reflected in the administration’s repeated defiance of lawful court orders. For example, it has been reported that in 2026, the Trump administration violated 52 court orders in New Jersey and nearly 100 in Minnesota.15

President Trump’s behaviour can appropriately be described as a crusade against the independence of the judiciary in the United States. If the leader of the free world shows such disdain for his own country’s legal system, it empowers his millions of supporters to treat the judiciary and the rule of law with the same contempt.

The increasing threat to the judiciary is reflected in data which shows that there was an almost 60% increase in “security incidents of significant concern” in courts in the United States in the 2025 fiscal year.16 In a tactic known as “pizza doxing”, judges have had unsolicited pizzas delivered to them or their children at their home addresses.17 The pizzas are often delivered under the name Daniel Anderl.18 Daniel, the son of United States District Judge Esther Salas, was murdered in 2020 after opening the door of their family home to a disgruntled attorney posing as a delivery driver. Pizza doxing is used as a form of intimidation, designed to show that the sender knows exactly where the judge and their family live.19 Another intimidatory tactic is known as “swatting”, where police receive an anonymous call stating that there is a crime in progress at a judge’s home with the consequence that armed police will then attend.20 Some judges who have ruled against the administration have reported threats to rape and kill them and many judges have been bombarded with hate mail.21

It is clear that what President Trump and his supporters are seeking to do is intimidate the judiciary into ruling in favour of his actions and policies. The President is seeking to have judicial decisions made through fear of the consequences, rather than made according to law. For his own political ends, he is seeking to undermine the independence of the judiciary in the United States and undermine the rule of law.

It is important to emphasise that courts and judicial officers are not immune from legitimate criticism. The right to criticise judicial decisions is as fundamental to democracy as is judicial independence. But what is concerning is the deliberate undermining of judicial independence through misleading and ill-informed commentary, including through personal denigration of judicial officers.

The framers of the United States Constitution fought hard to enshrine the independence of the judiciary, so there is great irony and sadness in the President’s casual dismantling of that independence. Article III Section 1 of the Constitution states that:

The judicial Power of the United States, shall be vested in one supreme Court, and in such inferior Courts as the Congress may from time to time ordain and establish. The Judges, both of the supreme and inferior Courts, shall hold their Offices during good Behaviour, and shall, at stated Times, receive for their Services, a Compensation, which shall not be diminished during their Continuance in Office.

In an article entitled, ‘The Essence of Judicial Independence’, Judge Irving R. Kaufman explains that the framers resolved to vest the judicial power of the United States in an independent branch or department of government.22 He writes:23

Recognizing the dangers inherent in unbounded power, the Founders went beyond the legacy of British and colonial history and adopted a written constitution with an independent judiciary for its guardian. The Framers realized, moreover, that their bold experiment could succeed only if the judicial power were kept absolutely separate and distinct from the executive and legislative branches. If it were not, the Constitution’s promise of a government of limited powers could be broken with utter impunity. The solution was thus to elevate the judiciary to a third, co-equal branch of government, whose authority flowed directly from the same constitutional wellspring as its sister branches. The Founders thus rendered federal judges independent of the political departments not only with respect to their tenure and salary, but more importantly, in their source of judicial authority. It is this additional step, inconceivable in England, that made the American Constitution truly revolutionary.

(Footnote omitted.)

Judge Kaufman continues:24

The essence of judicial independence, therefore, is the preservation of a separate institution of government that can adjudicate cases or controversies with impartiality. This principle is embodied in the doctrine of separation of powers, which elevates the judiciary to the status of a co-equal branch. Cases defining the separation of powers suggest that article III’s protection of judicial independence extends beyond the specific prohibitions of the salary and tenure provisions to embrace all significant intrusions upon the exercise of the judicial power.

The concept embodied in the Constitution of the United States of the judiciary as an independent, equal branch of government was adopted in Chapter III of the Australian Constitution. Section 72 provides protection against removal from office and reduction of remuneration while in office. Similar provisions have been adopted in many Constitutions around the world, even if, in practice, many countries deny the judiciary’s independence.

A constitutional guarantee of judicial independence has been adopted in the Papua New Guinea Constitution. Section 157 of the Papua New Guinea Constitution provides, in effect, that the Executive has no power to give directions to any court or member of any court in respect of the exercise of judicial powers or functions. Section 37 requires an “independent and impartial court” in criminal and civil cases.

The Papua New Guinea Constitution does offer protection against reduction of remuneration while a judge is in office. However, the Constitution does not make any express provision in respect of the length of a judge’s term of office, instead, by s 223(1), reserving this as a subject upon which provision is to be made by an “Organic Law”. During their term of office, a judge may only be removed for inability to perform the functions and duties of office, misbehaviour or misconduct in office.25

Returning to the United States, from 1787 to 1788, 85 essays were published in New York newspapers supporting a federal constitution.26 Alexander Hamilton was one of the writers. In ‘Federalist Paper No. 78’, responding to claims that a powerful judiciary could result in oppression, Hamilton famously characterised the judiciary as the “least dangerous” branch or department of government. Hamilton contrasted the judiciary with the executive and the legislature, writing:

The judiciary, on the contrary, has no influence over either the sword or the purse; no direction either of the strength or of the wealth of the society; and can take no active resolution whatever. It may truly be said to have neither FORCE nor WILL, but merely judgment; and must ultimately depend upon the aid of the executive arm even for the efficacy of its judgments.

Hamilton also pointed out that the factors that make the judiciary the least dangerous branch of government also make the judiciary, “beyond comparison the weakest of the three departments of power”.27

The conception of judicial independence as fundamental to the impartial adjudication of cases is reflected in the oath of office taken by judicial officers. In Australia and Papua New Guinea, judges and magistrates swear to, “do right to all manner of people according to law, without fear or favour, affection or ill will”. Judges are required to determine every case impartially according to law and without fear of the consequences that may ensue from making an unpopular decision. The confidence of the public in our legal systems depends on confidence that judges will act impartially. When political actors seek to make judges fear the consequences of making a decision according to law, they seek to undermine the independence of the judiciary and undermine public confidence in the judiciary and, ultimately, undermine the rule of law.

President Trump’s crusade against an independent judiciary does not just affect Americans. Its ripples flow through to Australia, Papua New Guinea and every other democratic country. If the leader of the free world undermines his own country’s democracy in this way, then it also challenges the foundations of democracy around the world.

We are already seeing these ripples in Australia. To give some recent examples, in a politically charged case, a Minister used parliamentary privilege to engage in a personal attack against a Coroner, accusing the Coroner of seeming to, “lack the humility one might expect from an officer of the court”, and saying she was, “more focused on the reveal rather than the result”.28 In another case, a senior politician described a decision to grant an accused person bail as “an utter disgrace” and criticised the Magistrate for failing to apply “the pub test”.29 The politician apparently failed to realise that judicial officers apply the law, not any “pub test”. It is no wonder that a recently retired judge criticised politicians and the media for cynical “performative outrage” and “political theatre” that is compromising the justice system.30

Threats to the physical safety of judicial officers provide a substantial threat to judicial independence. The peak body representing judges and magistrates in Australia is the Australian Judicial Officers Association (AJOA). Its principal objects are directed to protecting the standing and independence of the judiciary in Australia.31 In 2025, the AJOA published a paper noting that an increase in threatening behaviours towards judicial officers by litigants is the common experience of many judicial officers, particularly those sitting in Local and Magistrates’ Courts.32

The anecdotal experience of judicial officers is borne out by the available data.33 Research concerning New South Wales courts found that 61% of judicial officers had experienced some form of threat and, alarmingly, almost a quarter of judges had received a death threat.34 Threats were predominantly experienced in the courtroom or in person outside of court or via social media.35 Data from Victoria indicates that between 2023 and 2024, the number of judicial officers across Victorian courts who sought support to manage a threat more than doubled, with the largest number being from the Magistrates Court.36 The overall number of reported threats to Victorian judicial officers was projected to increase by another 70% in 2025.37

Anecdotally, it seems that much of the increase in threats in Australia comes from so-called “Sovereign Citizens” who believe that courts and law enforcement authorities have no jurisdiction over them. The Trumpian rhetoric seems particularly attractive to people such as these who reject the rule of law.

The current President of the AJOA, Justice Steven Moore, has commented:38

The increasing prevalence of threats to the safety and security of Australian judicial officers is alarming and unacceptable…

It demands urgent action to ensure judicial officers and court staff may go about their work without unnecessary risks to their psychological and physical health and safety, and to ensure that they may properly discharge their oaths of office.

I interpolate to add that the equivalent body for judicial officers of Papua New Guinea and the Pacific Islands is the Pacific Islands Judicial Officers Association (PIJOA). It was formed in 2024 under the leadership of Deputy Chief Justice Kandakasi.39 Its objects include promoting strong and independent judiciaries in the region.40 The formation of the PIJOA is an important development and it will make an invaluable contribution to the rule of law in Papua New Guinea and the Pacific Islands.

Chief Justice Bell of the New South Wales Supreme Court has observed that the judiciary is more dependent than perhaps any other public institution on the confidence of the public and of the other arms of government.41 The judiciary is particularly vulnerable to the undermining effects of offensive and uninformed comments by politicians and media and social media reports of such comments. Many cases heard before the courts are of great public interest and, understandably, stir up visceral reactions and strong emotions. For example, crimes of violence, sexual predation, offences against children and forced entry into people’s homes naturally cause horror and anger. Other categories of cases like deportation of convicted criminals, illegal corporate behaviour and financial scams also produce strong reactions and opinions.

However, the information that members of the public receive about cases before the courts is filtered by media and social media reporting and reposting. Increasingly, opinion and commentary have become a substitute for news. Selective reporting of the facts results in failure to place the court’s decision in its proper context. In Australia, this is most apparent in the outrage expressed in headlines raging about bail and sentencing decisions but failing to explain the full range of circumstances a judge is required by the law to take into account. This outrage is often taken up and refuelled by political actors for their own political purposes.

Judges and magistrates are poorly equipped to publicly defend themselves from ill-informed and misleading attacks. The Guide to Judicial Conduct published by the Council of Chief Justices of Australia and New Zealand states that a judge must avoid involvement in political controversy, unless the controversy itself directly affects the operation of the courts, the independence of the judiciary, or aspects of the administration of justice.42 The Guide points out the risk of expressing views that give rise to issues of bias or prejudgment.43 The Guide notes that if the matter calls for a response on behalf of the judiciary, the response should come from the head of jurisdiction.44 Often there is no response because the attitude is understandably taken that it is better not to fuel a media fire that would otherwise extinguish itself in a day or two.

But the trouble is that destruction of truth is by a thousand cuts. For example, a half-truth we hear over and over again is that, “The police arrest people but the judges just let them out”. If the same trope is repeated often enough then it comes to be regarded as the truth. The public is vulnerable to the influence of unfounded criticism and misinformation that may be inadvertently or deliberately made or distributed.

Chief Justice Bell has commented:45

Unfounded or inaccurate criticism of courts has important consequences in and of itself: it may lead to a loss of public confidence in courts and judges, which compromises the effectiveness of the courts. However, an arguably more concerning risk is that ill-informed perceptions of the judiciary, in turn, may shape the development of public policy on issues of law and justice – or, in the worst case, may be actively encouraged and eventually invoked to justify a weakening of the administration of justice including judicial independence.

If judges are unable to publicly defend themselves from ill-informed and misleading attacks and the heads of jurisdiction are often reluctant to do so, then who can perform that role? In past eras, it was the role of the Attorney-General as the “first law officer” to defend the judiciary, including from attacks from the government of which they were a part. However, that role had faded away by the end of the 20th century. In an article by the then Attorney-General of Australia, Daryl Williams, in 2002, he made it clear that, “it is up to the judiciary to take the lead in defending themselves and their courts against criticism”.46

I have referred earlier to the AJOA. It was partly in response to the unwillingness of Attorneys-General to defend the judiciary that the AJOA was formed (under its former name, Judicial Conference of Australia). The AJOA has repeatedly spoken out in defence of judicial officers against unfair attacks. It has also published a detailed report into the state of independence of the judiciary in Australia.47 The AJOA serves an important role in correcting misinformation and providing education about the importance of maintaining judicial independence against the growing tide of attacks on that independence.

In the Pacific region, the PIJOA will perform a similar role. The AJOA looks forward to a close relationship with the PIJOA in working towards our common goal of maintaining the rule of law.

The judiciary in Papua New Guinea, like the judiciary in Australia, is vulnerable to attacks on its independence. The judiciary in Papua New Guinea has faced several significant challenges since independence in 1975, but each one seems has seen the judiciary emerge a little stronger.

The first challenge to the independence of the judiciary was what has become known as the “Rooney Affair”.48 It started with a decision in 1979, just four years after independence, by the Minister for Foreign Affairs and Trade to revoke an entry permit held by Dr Ralph Premdas, a lecturer at the University of Papua New Guinea, who was providing political advice and commentary.49 A judge of the National Court granted an interlocutory injunction restraining Dr Premdas’ deportation.50 The Minister for Justice, Nahau Rooney, then wrote to the then Chief Justice, circulating the letter to 45 other recipients, complaining of the judge’s decision and asserting that it was up to the government and no one else to decide what criteria are used to deport foreigners, and asserting that the Court had jeopardised its independence and neutrality by intervening in a matter which was the sole prerogative of the government.51

The Chief Justice replied, indicating his belief that the Minister had engaged in an unconstitutional attempt to interfere with the judiciary and asking the Minister to withdraw her letter and apologise.52 There was further correspondence from the Minister, not apologising, but acknowledging the independence of the judiciary and indicating that she had no intention to directly interfere with any decision of the Court.53 The Minister had also stated in a radio interview that she had no confidence in the Chief Justice and the other judges and told a newspaper that she would not retract what she had said because the judiciary could no longer do justice.54

The Supreme Court gave its final decision in the Premdas matter, holding that his deportation did not infringe the Constitution and allowing his deportation.55 Proceedings for contempt of court were commenced against Mrs Rooney. Mrs Rooney was found guilty of contempt and sentenced to imprisonment for eight months.56

However, the then Prime Minister, Sir Michael Somare, appointed himself Minister for Justice and released Mrs Rooney on licence after she had served one day of her sentence.57 The Chief Justice and four other judges then resigned in protest.58

Following the Rooney Affair, the government of Prime Minister Sir Michael Somare was defeated in a no-confidence motion of Parliament.59 Sir Buri Kidu was appointed as Chief Justice by the government of the new Prime Minister Sir Julius Chan.60

During Sir Buri’s 13-year term of office as Chief Justice, he rigorously maintained the independence of the courts. It is of particular note that he was able to secure a system of funding that sees the Courts’ budget independently administered by the Chief Justice rather than under the control of the Justice Minister.61 Sir Buri’s appointment was not renewed after his term had elapsed, which his widow, Dame Carol Kidu, has attributed to his insistence on the independence of the judiciary.62

Another attack on the independence of the judiciary in Papua New Guinea took place more recently. In the period leading up to the 2012 elections, there was a bitter dispute about whether Sir Michael Somare or Peter O’Neill was the lawful Prime Minister of the country.63 In 2011, the Supreme Court decided that Sir Michael had not been lawfully removed as Prime Minister.64 The Chief Justice, Sir Salamo Injia, was a member of the majority.65

Sustained pressure was then brought to bear upon the judiciary by the Executive and the Parliament.66 Sir Salamo Injia was purportedly suspended from office, although that decision was later rescinded by the National Executive Council.67 He was then arrested on two occasions.68 The charges were wholly misconceived and the proceedings were stayed or dismissed.69

In another attack on judicial independence, legislation was enacted in 2012 which purported to allow Parliament to refer a judge for investigation with the effect that the judge could not continue to exercise their powers as a judge pending the provision of a report.70 However, that legislation was repealed in 2013.71

In 2014, the then Attorney-General and Minister for Justice tendered a formal apology to the Supreme Court for the actions of the executive taken in the period leading up to the 2012 elections.72 The apology was, if I may respectfully say so, a matter of great credit to the government of Papua New Guinea and a recognition of the importance of the independence of the judiciary.

It must be recognised that judicial officers also have a responsibility for maintaining public confidence in the judicial system by discharging their duties impartially, effectively and efficiently. There have been unfortunate examples in recent times of judges in Australia failing to comply with these standards.

An infamous example is the case of State of Queensland v Mr Stradford (A Pseudonym) [2025] HCA 3; 421 ALR 376. In that case, in a family law proceeding, a judge sentenced a litigant to a period of 12 months’ imprisonment for contempt of court, suspended after six months, for failure to comply with an order to make full and frank financial disclosure. The judge’s conduct was described by appellate courts as “devoid of procedural fairness”, “an affront to justice” and providing a “parody” of a court hearing.73

The litigant sued the judge for damages for false imprisonment. At first instance, the litigant succeeded, with the Federal Court holding that the actions of a judge of an inferior court are not protected by judicial immunity from civil suit.74 The High Court ultimately held that all judges of courts described in s 71 of the Constitution are either immune from or have a defence to a civil suit arising out of acts done in the exercise or purported exercise of their judicial function or capacity. 75 As the judge had purported to perform a judicial function in convicting and sentencing the litigant, he was not liable to damages for false imprisonment.

The Stradford case caused a great deal of public controversy in Australia. It raised questions about why a judge should have the benefit of an immunity from civil suit and why judges should be protected from removal from office. The fallout of the case goes to show that challenges to judicial independence can arise as much from conduct within the judiciary as attacks from the outside.

If the judiciary is to maintain the support of the public for its independence, then the judiciary collectively must act in a way that demonstrates it is deserving of that entitlement. It is a two-way street. The public is entitled to expect that judges will conduct themselves in a manner that befits the status of the judiciary as an equal third arm of government.

I want to emphasise that nothing I have said is intended to detract from the right of politicians, the media and the public to make legitimate and informed criticisms of judicial decisions and the conduct of the judiciary. That right is as fundamental as judicial independence itself. My concern is with ill-informed and unfounded criticism, particularly where it is in the form of personal attacks on judicial officers and when it is calculated to undermine the rule of law.

I thank the organisers again for giving me the opportunity to present this lecture on a topic that is important to both Australia and Papua New Guinea.

Justice D C Rangiah


[1] I gratefully acknowledge the research assistance provided by my associate, Grace Dowdle.

[2] Truth Social, post by Donald Trump dated 30 May 2026.

[3] The Kennedy Center, “Our Story”.

[4] The New York Times, “Trump Says He Will Dismiss Kennedy Center Board Members and Install Himself as Chair” (7 February 2025, published online).

[5] The New York Times, “As Trump Puts His Brand on Washington, the Kennedy Center Gets a New Name” (18 December 2025, published online).

[6] Beatty v. Trump. No. 1:25-cv-04480. United States District Court for the District of Columbia. 29 May 2026.

[7] Ibid.

[8] Truth Social, post by Donald Trump dated 31 May 2026.

[9] Chief Justice John G. Roberts, Jr., “2024 Year End Report on the Federal Judiciary” (published on 31 December 2024) at 5.

[10] The Guardian, “Furious Trump signs global 10% duty after supreme court issues tariff blow” (21 February 2026, published online); Global News, “Read the transcript of Trump’s response to U.S. Supreme Court tariff ruling” (20 February 2026, published online).

[11] The Guardian, “Supreme court rejects Trump’s mail ballot restrictions for midterm elections” (15 September 2026, published online).

[12] The Guardian, “What Trump’s attacks on mail-in voting mean for the midterms” (18 September 2026, published online); Truth Social, post by Donald Trump dated 15 September 2026.

[13] Truth Social, post by Donald Trump dated 15 September 2026.

[14] Berkeley Judicial Institute & Rule of Law Lab at NYU Law, “Threats to the Independence of the Federal Judiciary” (report, published 31 August 2026) at 7.

[15] The Guardian, “Trump’s vicious attacks on judges fuel his bid for unchecked power” (25 February 2026, published online).

[16] Politico, “Federal judges say they’re facing intensified threats since start of Trump’s second term” (2 September 2026, published online).

[17] Ibid.

[18] Ibid.

[19] Ibid.

[20] The New York Times, “Judges Fear for Their Safety Amid a Wave of Threats” (21 March 2025, published online).

[21] Ibid.

[22] Irving R. Kaufman (then the Chief Judge of the United States Court of Appeals for the Second Circuit), ‘The Essence of Judicial Independence’ (1980) 80(4) Columbia Law Review 671 at 687.

[23] Ibid.

[24] Ibid at 688.

[25] Papua New Guinea Constitution s 178.

[26] Library of Congress, “Full Text of The Federalist Papers”.

[27] Alexander Hamilton, Federalist Paper No. 78.

[28] ABC News, “Northern Territory domestic violence prevention minister condemned by legal associations for criticism of coroner” (1 August 2025, published online); Australian Judicial Officers Association, “AJOA Condemns Attacks on Coroner” (1 August 2025, published online).

[29] The Canberra Times, “Criticism over ISIS bride bail triggers judges’ rebuke” (23 July 2026, published online); Australian Judicial Officers Association, “Media Release from AJOA President, Justice Steven Moore” (23 July 2026, published online).

[30] The Sydney Morning Herald, “Former top judge sprays politicians and media for attacking judicial independence” (29 June 2026, published online).

[31] Australian Judicial Officers Association, “About Us”.

[32] Australian Judicial Officers Association, “Supporting judicial well-being: rising threats to the safety and security of judicial officers”, published 25 July 2025 at [4].

[33] Ibid.

[34] Ibid at [5].

[35] Ibid.

[36] Ibid at [6].

[37] Ibid.

[38] Australian Judicial Officers Association, “Threats to judges a threat to justice” (25 July 2025).

[39] Pacific Islands Judicial Officers’ Association Inc, “The Origins of PIJOA”.

[40] Pacific Islands Judicial Officers’ Association Inc, “Objectives and Purpose of PIJOA”.

[41] The Hon A S Bell, “Truth Decay and its implications for the judiciary: an Australian perspective”, Fourth Judicial Roundtable at Durham University, 23 to 26 April 2024 at [24].

[42] Guide to Judicial Conduct (fourth edition, 2026), published for The Council of Chief Justices of Australia and New Zealand by The Australasian Institute of Judicial Administration Limited at 20.

[43] Ibid.

[44] Ibid.

[45] The Hon A S Bell, “Truth Decay and its implications for the judiciary: an Australian perspective”, Fourth Judicial Roundtable at Durham University, 23 to 26 April 2024 at [30].

[46] The Hon Daryl Williams, “The Role of the Attorney-General” (2002) 13 Public Law Review 252 at 261.

[47] Dr Jessica Kerr, “Judicial Independence in Australia: A Research Paper prepared for the Australian Judicial Officers Association” (August 2024).

[48] The Hon Justice J A Logan RFD, Selden Society 2025 Lecture Program, Lecture 3: “The origins of contemporary judicial power in Papua New Guinea”, delivered at the Banco Court in Brisbane (16 October 2025).

[49] Ibid.

[50] Ibid.

[51] Australian National University, Department of Pacific Affairs, Discussion Paper 2026/1, “Invoking the Melanesian Way in Resolving Conflict between the Executive and Judiciary in Papua New Guinea: The Rooney and Namah Cases” (10 April 2026).

[52] Ibid.

[53] Ibid.

[54] Ibid.

[55] The Hon Justice J A Logan RFD, Selden Society 2025 Lecture Program, Lecture 3: “The origins of contemporary judicial power in Papua New Guinea”, delivered at the Banco Court in Brisbane (16 October 2025).

[56] Ibid.

[57] Ibid.

[58] Ibid.

[59] Ibid.

[60] Ibid.

[61] The National, “A beacon of light in the Pacific” (15 September 2025, published online).

[62] The Hon Justice J A Logan RFD, Selden Society 2025 Lecture Program, Lecture 3: “The origins of contemporary judicial power in Papua New Guinea”, delivered at the Banco Court in Brisbane (16 October 2025).

[63] Ibid.

[64] Ibid.

[65] Ibid.

[66] Ibid.

[67] Ibid.

[68] Ibid.

[69] Ibid.

[70] Ibid; Judicial Conduct Act 2012 (PNG).

[71] Judicial Conduct (Repeal) Act 2013 (PNG).

[72] The Hon Justice J A Logan RFD, Selden Society 2025 Lecture Program, Lecture 3: “The origins of contemporary judicial power in Papua New Guinea”, delivered at the Banco Court in Brisbane (16 October 2025).

[73] State of Queensland v Mr Stradford (A Pseudonym) [2025] HCA 3; 421 ALR 376 at [5] and [30].

[74] Stradford (a pseudonym) v Judge Vasta [2023] FCA 1020.

[75] State of Queensland v Mr Stradford (A Pseudonym) [2025] HCA 3; 421 ALR 376 at [113].

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