Research Note on Exclusion Zones in Australia
This Research Note provides information on exclusion zones in response to the Public Health and Wellbeing Amendment (Safe Access) Bill 2015, introduced by Australian Sex Party MLC Fiona Patten on 18 August 2015. This includes commentary on zones to protect access to abortion clinics, sometimes known as 'access zones', 'bubble zones' and 'buffer zones'. Specifically, this Research Note:
§ provides a brief background on protests at abortion clinics in Melbourne;
§ analyses the proposed Victorian exclusion zones against other proposals for exclusion zones in Australia, including in Tasmania, New South Wales and the Australian Capital Territory;
§ discusses the human rights and constitutional implications of limiting freedom of expression and political communication; and
§ briefly presents the experiences of abortion clinic exclusion zones in other jurisdictions, including Canada and the United States.
The Fertility Control Clinic was set up in East Melbourne 1972 by abortion campaigner Dr Bertram Wainer, and was the first of its kind in Australia.[footnote 1] It provides abortion services as well as treatment for miscarriages, vasectomies, contraception advice and general sexual health services. Staff at the clinic have frequently complained that protesters endanger their personal comfort and safety.[footnote 2] The number of protesters outside the clinic ranges from three to 12 persons most days, with the group expanding to 50-100 persons once a month.[footnote 3] In 2001, a security guard was murdered at the East Melbourne clinic by a gunman not affiliated with any of the other protesters.[footnote 4]
The Helpers of God's Precious Infants are an international anti-abortion organisation. In Melbourne, they protest six mornings a week outside the Fertility Control Clinic on Wellington Parade, East Melbourne and maintain a presence at clinics in Carlton, Richmond and St Albans at least one day a week.[footnote 5] During parliamentary sitting weeks, they demonstrate at the rear entrance to the Victorian Parliament.[footnote 6] They have maintained a presence outside the East Melbourne clinic for over 20 years.[footnote 7] They have stated that their activities are aimed at 'encouragement and assistance' and that they 'always act within the law and we never incite or instigate violence'.[footnote 8]
Fertility Control Clinic v Melbourne City Council
In March 2014, the Fertility Control Clinic sought a writ of mandamus[footnote 9] against the Melbourne City Council for failing to do anything about the nuisance caused by the protesters. The Supreme Court of Victoria's judgment was handed down on 26 August 2015. The court heard that the actions of the protesters include:
§ approaching women apparently coming to the Clinic, imposing their presence even when clearly unwelcome;
§ harassing women entering or leaving the Clinic, engaging in arguments with the women and passers-by;
§ attempting to block women's entry to the Clinic;
§ blocking the footpath outside the Clinic;
§ entering the laneway that runs along the side of the Clinic to follow patients or stand and pray, sing and shout outside the Clinic's consulting rooms;
§ jostling and striking people passing the area and entering the Clinic;
§ making offensive, frightening and misleading statements to patients and staff;
§ engaging in loud singing, praying and shouting, clearly audible in the Clinic;
§ intimidating and harassing patients of the Clinic, with the effect of deterring patients from attending the Clinic; and
§ causing significant injury to the personal comfort of staff members, patients and others.[footnote 10]
Justice McDonald considered that, 'prima facie, such conduct is a private nuisance by reason of impeding the Clinic's enjoyment of its property and a public nuisance by reason of impeding the Clinic's enjoyment of its property and a public nuisance by reason of the elements of annoyance, inconvenience or hurt to members of the public'.[footnote 11]
Under s 60 of the Public Health and Wellbeing Act 2008(Vic), a Council has 'a duty to remedy as far as is reasonably possible all nuisances existing in its municipal district'. However, under s 58(1) such nuisances must be, or must be liable to be, 'dangerous to health or offensive'. Justice McDonald found that it was within the Council's jurisdiction to 'erroneously conclude that the conduct [footnote of the protesters] was neither offensive nor dangerous to health'.[footnote 12]
Exclusion zones in Australia
Tasmania is the only Australian jurisdiction which has specific exclusion zones around abortion clinics. Similar zones have also been proposed in the ACT, NSW and now Victoria. The provisions in each jurisdiction are described below, with a focus on the definition of prohibited behaviour and the operation of the zone. Some commentary regarding the operation of the right to freedom of expression and the implied freedom of political communication in conjunction with these limitations on certain behaviour is also provided.
Tasmania introduced 'Access Zones' around abortion clinics at the same time it decriminalised abortion, under the Reproductive Health (Access to Terminations) Act 2013 (Tas).[footnote 13] Under s 9 of the Act, access zones are defined as 'an area within a radius of 150 metres from premises at which terminations are provided'. Persons cannot engage in 'prohibited behaviour' in these Access Zones, at the risk of a fine of 75 penalty units[footnote 14] and/or 12 months imprisonment. Prohibited behaviour under s 9 includes:
(a) besetting, harassing, intimidating, interfering with, threatening, hindering, obstructing or impeding a person;
(b) any protests relating to terminations that can be seen or heard by a person attempting to access premises providing terminations;
(c) footpath interference in relation to terminations;
(d) intentionally recording a patient attempting to access the clinic; or
(e) any other prescribed behaviour.[footnote 15]
There is an exception to the prohibited behaviour of intentionally recording a person where that behaviour is reasonable conduct of a law enforcement officer acting in the course of their duties (s 9(3)).
ACT Greens MLA Shane Rattenbury presented an Exposure Draft to the ACT Legislative Assembly on 6 August 2015, outlining amendments to the Health Act 1993 (ACT) to provide for prohibited behaviour within protected areas.[footnote 16] Under proposed s 86, protected areas around approved medical facilities must be declared by the Minister, and the Minister must be satisfied that the area is 'sufficient to ensure the privacy and unimpeded access for anyone entering, trying to enter or leaving an approved medical facility', while also being 'no bigger than reasonably necessary to achieve that outcome'. Civil Liberties Australia have noted that they prefer this approach where the Minister is required to set an exclusion zone, but that the size of the zone is not prescribed in legislation and can be tailored to each clinic, as it is capable of excluding private property from the zone and strengthens arguments that the zone is 'appropriate and adapted to the circumstances'.[footnote 17] Further, these zones only apply during 'protected periods' which include the hours of 8am to 6pm each day of operation, and 'any other period declared by the Minister' (proposed section 85(2)).
Prohibited behaviour within the exposure draft has an intent element whereby 'harassment, hindering, intimidation, interference with, threatening or obstruction of another person' or 'an act that can be seen or heard by a person' in the protected area during the protected period is prohibited where it is intended to stop that person entering the facility, or 'having or providing an abortion' in the facility (proposed s 85(1) definition). Protests in relation to the provision of abortions and visual recording of people entering, trying to enter, or leaving approved facilities are also forms of prohibited behaviour during the protected period. Engaging in prohibited behaviour within a protected area is punishable by 25 penalty units[footnote 18] (proposed s 87(1)). The publication of data captured as part of the prohibited behaviour of recording a person accessing a facility is punishable by a maximum fine of 50 penalty units[footnote 19] (proposed s 87(2)), with an exception for law enforcement officers acting reasonably in the exercise of their functions (proposed s 87(3)).
NSW Greens MLC Dr Mehreen Faruqi sought leave to introduce the Abortion Law Reform (Miscellaneous Acts Amendment) Bill as a Private Member's Bill in May 2015, but the motion has been postponed three times since then and is currently due for consideration on 29 October 2015.[footnote 21] The Bill seeks to decriminalise abortion in NSW, and introduce exclusion zones to 'make it an offence to protest, harass, intimidate or film without consent a person accessing abortion services within a 150 metre radius of an abortion clinic'.[footnote 22] Polling by Essential Research in NSW in July 2015 indicated that 54 per cent of respondents thought it should be illegal to protest outside a medical clinic that provides abortions, while 30 per cent thought it should be legal.[footnote 23]
The Australian Sex Party's Public Health and Wellbeing Amendment (Safe Access) Bill 2015 seeks to insert a new 'Part 9A—Safe access to reproductive health services' into the Public Health and Wellbeing Act 2008.
The new Part introduces two new offences: engaging in prohibited behaviour in a safe access zone and publishing or distributing a recording of a person accessing or attempting to access reproductive health service premises (both punishable by 500 penalty units[footnote 24] or up to 12 months imprisonment) (proposed ss185B and 185C).
According to the explanatory memorandum:
The penalty provisions are designed to reflect the serious, discriminatory nature of such behaviour. The deterrence impact should be viewed in light of previous violent encounters around such clinics ... The penalties reflect the importance of avoiding such escalation, and providing clarity around the rights to safe access to such services, and privacy in so doing.[footnote 25]
New definitions are inserted by s 185A of the proposed Part 9A. 'Safe access zone' is defined as 'an area within a radius of 150 metres from premises at which reproductive health services are provided'. Reproductive health services include services 'relating to advice, medication and treatment in respect of reproductive health, including the prevention and termination of pregnancy'. Prohibited behaviour within these zones includes:
(a) besetting, harassing, intimidating, interfering with, threatening, hindering, obstructing or impeding a person;
(b) communicating in relation to reproductive health services in a way that could be seen or heard by a person accessing (or attempting to access) reproductive health service premises;
(c) interfering with or impeding a footpath; or
(d) intentionally recording a person accessing (or attempting to access) reproductive health service premises without their consent; or
(e) any other prescribed behaviour.
Under proposed s 185B(2), intentionally recording a person accessing reproductive health service premises, without their consent, is prohibited behaviour within a safe access zone, unless the person doing the recording is a police officer performing official duties, is an employee or contractor of the reproductive health service, or another prescribed person. It is a separate offence to then distribute such recordings (proposed s 185C), and a police officer can seize any recordings or material related to either of the new offences if they have reasonable grounds to believe that it 'was used, or is about to be used, in relation to the offence or likely offence' (proposed s 185D).
Victoria has a Charter of Human Rights and Responsibilities Act 2006 which sets out certain rights that legislators must take into account, including the right to freedom of expression (s 15). Further, the High Court has determined that an implied freedom of political communication is provided for in the Australian Constitution, and this can apply to state legislation.[footnote 26] The implications of these two freedoms in relation to exclusion zones are discussed below.
Victorian Charter and freedom of expression
It is noted in the Statement of Compatibility to the Australian Sex Party's Bill that the proposed offence of engaging in prohibited behaviour within a safe access zone may limit the freedom of expression provided for in s 15(2) of the Charter of Human Rights and Responsibilities.[footnote 27] However, this limitation could be considered as falling within s 15(3) of the Charter, which allows for limitations on freedom of expression where they are reasonably necessary to 'respect the rights and reputation of other persons' (such as their right to privacy under s 13) or 'for the protection of national security, public order, public health or public morality'.[footnote 28] Further, under s 7 of the Charter, rights 'may be subject under law only to such reasonable limits as can be demonstrably justified in a free and democratic society based on human dignity, equality and freedom', and taking into account: the nature of the right; importance of the limitation; extent and nature of the limitation; relationship between the limitation and its purpose; and the availability of any less restrictive means reasonably able to achieve the same purpose.
Other exclusion zones in Victoria
It is worth noting that there are many precedents for limitations on public behaviour in Victoria. For example, the Parliamentary Precincts Act 2001(Vic), includes provisions allowing authorised officers to give a person a direction to leave or not enter the parliamentary precincts for up to seven days 'if the authorised officer believes on reasonable grounds that the direction is necessary for the good order and security of the Parliamentary precincts' (s 16). This has the effect of excluding the top steps of the front entrance to Parliament from public protests.[footnote 29]
There are a number of provisions restricting behaviour in State forests. The Sustainable Forests (Timber) and Wildlife Amendment Act 2014 amended the Sustainable Forests (Timber) Act 2004 to provide for 'timber harvesting safety zones' under Part 7A of the Act, which commenced on 28 May 2014. According to the second reading speech, the new zones were introduced in order to: 'deter unlawful protest activities that are unsafe and disrupt timber harvesting operations'.[footnote 30] The safety zones apply to timber harvesting coupes and the state forest within 150 metres of the boundary of that coupe, and are notified at the site and on the VicForests website.[footnote 31] In addition, exclusion orders can be issued by the courts prohibiting an offender from entering a timber harvesting safety zone or an area of state forest for a period of up to 12 months.[footnote 32] In conjunction with these zones, the Secretary of the Department retains the right to declare areas of State forest to be 'public safety zones' under the Safety on Public Land Act 2004, where unauthorised persons cannot carry out any activity in contravention of the public safety zone declaration (punishable by 20 penalty units).
Implied freedom of political communication
The implied freedom of political communication was first set out by the High Court in Lange v Australian Broadcasting Corporation.[footnote 33] Here, it was found that given the system of government set out in the Constitution, there is an implied freedom of political communication 'limited to what is necessary for the effective operation of that system of representative and responsible government'.[footnote 34]
Whether restricting communication in relation to reproductive health services is a violation of the implied freedom to political communication in the Constitution depends on the type of political debate actually protected by that freedom. The High Court has not conclusively decided on this. In Coleman v Power, the majority preferred 'a civil, accessible and rational discourse'[footnote 35] which allowed for restrictions aimed at preventing breaches of the peace or violent behaviour.[footnote 36] In the more recent case of Monis (on which the High Court was split), Chief Justice French accepted 'unreasonable, strident, hurtful and highly offensive communications' as part of the political debate.[footnote 37] Here, Justice Heydon lamented that the inclusions of such 'sadistic, wantonly cruel and deeply wounding blows' within the definition of political communication indicated that the implied freedom may in the future be considered by the Court as a 'noble and idealistic enterprise, which has failed, is failing and will go on failing'.[footnote 38] A challenge to abortion clinic exclusion zones would be required in the High Court 'to mediate these conflicting positions and to shed further light upon the type of debate that the implied freedom of communication serves to protect'.[footnote 39]
Nonetheless, the High Court has ruled that limits can be placed on political communication. If it is determined that access zone laws place a burden on political communication, it could still be found that the purpose of providing safe access to reproductive health services is a legitimate purpose 'compatible with the maintenance of the constitutionally prescribed system of representative and responsible government',[footnote 40] and that limiting restrictions to within a 150 metre radius of such services (as proposed by the Bill) is 'appropriate and adapted to achieving that legitimate object or end'.[footnote 41] Further, a burden on political communication could be justified if access zones are considered as 'necessary for the attainment of some overriding public purpose', such as public order and safe access to health services.[footnote 42] For example, the High Court has previously found Victorian legislation to be valid when it restricted the political communication of duck protesters because the law was targeted at public safety, and only applied to a small geographic area during a specific and limited time (i.e., hunting zones during duck hunting season).[footnote 43]
However, the relatively severe penalties associated with the new offences in the Victorian Bill may lead to a restrictive reading of such provisions.[footnote 44] It has been argued that the general prohibition of protests in the access zones in the Tasmanian legislation could be struck out if interpreted by the High Court.[footnote 45] In the place of this prohibition on protests, the Victorian Bill prohibits 'communication in relation to health services', which could be interpreted even more broadly than the Tasmanian provisions, and carries a significantly more severe penalty than that in the Tasmanian legislation.[footnote 46] Further, the more tailored and limited access zones proposed in the ACT legislation demonstrate that there are 'less restrictive' and 'reasonably practicable' options available, which may also lend weight to the reasoning that the measures in the Victorian Bill are not 'appropriate and adapted'.[footnote 47]
The province of British Columbia in Canada has had exclusion zone laws in place since 1996 under its Access to Abortion Services Act. Under this Act, access zones around specific facilities are determined by the Lieutenant Governor in Council by regulation and encompass the land 50 metres from the boundaries of the parcel of land on which a specified facility is located. Persons must not engage in certain activities in access zones including: engaging in sidewalk interference; protesting, besetting, physically interfering or attempting to interfere with a service provider; and intimidating or attempting to intimidate a service provider. Graphic recording and harassment is also prohibited in the access zone. Local governments such as Calgary, Alberta and Toronto, Ontario have also enacted access zone provisions around specific clinics, while other clinics have sought individual injunctions against protest groups.[footnote 48] The Canadian Charter of Rights and Freedoms has similar provisions protecting freedom of expression as those in Victoria, and it was held as early as 1996 that access zones around abortion clinics were a reasonable impairment on that rights as 'freedom of expression may be impaired geographically, by time and by manner'.[footnote 49]
United States of America
The United States has a violent history of protests against abortion.[footnote 50] Under the Freedom of Access to Clinic Entrances Act[footnote 51]certain activities are prohibited in the USA including intentionally injuring, intimidating or interfering with persons obtaining or providing reproductive health services; intentionally injuring, intimidating or interfering with persons lawfully exercising their right of religious freedom at a place of religious worship; and, intentionally damaging or destroying a property because it provides reproductive health services or is a place of religious worship.[footnote 52] A first offence under this Act is punishable by a fine and/or 12 months imprisonment, and subsequent offences are punishable by a fine and/or three years imprisonment. These offences do not constitute an exclusion zone as there is no specific area that protesters cannot enter, but injunctive relief prohibiting a person from attending a clinic can be sought after a first offence.[footnote 53] A number of States in the US have also enacted 'buffer zone' laws around abortion clinics in addition to the Federal offences, although a 2014 Supreme Court ruling has found such zones to be a violation of the US Constitutional right to free speech.[footnote 54]
Since the early 1990s in France, it has been an offence under the Public Health code to prevent or attempt to prevent a termination of pregnancy or preliminary acts, punishable by two years' imprisonment and a fine of 30,000 euros. This includes by disrupting access to the termination facilities, the free movement of persons within these facilities, or the working conditions of staff; and/or by employing moral or psychological pressure, threats or any act or intimidation on either staff, women accessing the services, or people accompanying them.[footnote 55] In South Africa, it is an offence to prevent the lawful termination of a pregnancy or to obstruct access to a facility for the termination of a pregnancy, but it is not illegal to protest.[footnote 56] Recently, there have also been calls in the UK for buffer zones to restrict the recording of people accessing abortion clinics.[footnote 57]
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[footnote 4] P. Anderson (2014) 'Deluded pro-life crusader Peter James Knight kills guard, but wanted more dead after he brought his gun and hatred to an abortion clinic in Melbourne', Herald Sun, 11 March.
[footnote 5] Helpers of God's Precious Infants (date unknown) 'Prayer sites – Australia', Helpers of God's Precious Infants website; See also A. Cooper & A. Carey (2015) 'East Melbourne abortion clinic lawyers demand end to pro-life "nuisance"', The Age, 3 June.
[footnote 7] J. Vuk (2014) 'Rank and vile, that's the charge of the life brigade', The Age, 17 March.
[footnote 9] A writ of mandamus is a court order that commands an entity to either perform, or refrain from performing, a particular act. Here, the writ was being sought to require the Melbourne City Council to resolve the nuisance.
[footnote 11] ibid., [footnote 31].
[footnote 12] ibid., [footnote 32].
[footnote 13] See R. Sifris (2015) 'Tasmania's Reproductive Health (Access to Terminations) Act 2013: an analysis of conscientious objection to abortion and the "obligation to refer"', Journal of Law & Medicine, 22, pp. 900–914.
[footnote 14] Tasmanian penalty units are indexed annually. In 2015–16, a penalty unit is $154, with the current penalty for engaging in prohibited behaviour within an access zone amounting to $11,550. See, Department of Justice (Tas) (2015) 'Value of Indexed Amounts in Legislation', Tasmanian Department of Justice website.
[footnote 16] S. Rattenbury (Minister for Justice) (2015) 'Health (Patient Privacy) Amendment Bill 2015—exposure draft: Papers and statement by member', Debates, Australian Capital Territory, Legislative Assembly, 6 August, p. 2417.
[footnote 19] Currently $7,500
[footnote 20] See ACT Parliamentary Counsel (2015) 'Consultation Period: 20 July 2015 to 11 September 2015', ACT Legislation website.
[footnote 21] See NSW Legislative Council (2015) Legislative Council Notice Paper No. 20—Tuesday 8 September 2015, Parliament of NSW, p. 1457.
[footnote 22] Greens NSW (2015) Make it Happen: the Greens NSW Plan to Reform Abortion Laws and Stand up for Women's Reproductive Rights, media release, Greens NSW, 8 March.
[footnote 23] Essential Media Communications (2015) 'Right to Protest', Essential Vision website, 7 July; See also, M. Faruqi (2015) Greens MP Reiterates Call for Protest Exclusion Zones Outside Abortion Clinics Following New Polling, media release, NSW Greens, 8 July.
[footnote 24] 500 penalty units currently equals $75,835 (penalty units are indexed for inflation every financial year); See Department of Treasury and Finance (2015) 'Indexation of fees and penalties', DTF website.
[footnote 25] Explanatory Memorandum, Public Health and Wellbeing Amendment (Safe Access) Bill 2015, p. 3.
[footnote 26] See Coleman v Power (2004) 220 CLR 1.
[footnote 27] F. Patten (2015) 'Statement of compatibility: Public Health and Wellbeing Amendment (Safe Access) Bill 2015', Debates, Victoria, Legislative Council, 19 August, p. 2544.
[footnote 28] ibid.; The right to freedom of expression and these associated exceptions are also contained in Article 19 of the International Covenant on Civil and Political Rights (United Nations), to which Australia is a signatory.
[footnote 29] See H. Taylor (2011) Accessing Abortion: improving the safety of access to abortion services in Victoria, Parliamentary Intern Report, June, p. 18.
[footnote 30] P. Walsh (Minister for Agriculture) (2013) '<href="#page=66">Second reading: Sustainable Forests (Timber) and Wildlife Amendment Bill 2013', Debates, Victoria, Legislative Assembly, 31 October, p. 3797.
[footnote 33] Lange v Australian Broadcasting Corporation (1997) 189 CLR 520.
[footnote 34] ibid., p. 561.
[footnote 35] E. Jones (2014) 'Implementing protest-free zones around abortion clinics in Australia', Sydney Law Review, 36, p. 174.
[footnote 36] Coleman v Power (2004) 220 CLR 1, p. 2.
[footnote 37] Monis v The Queen (2013) 249 CLR 92, p. 131 [footnote 67]; See Jones, op. cit., p. 174; In this case, the potential political communication involved letters Mr Monis was sending to relatives of Australian soldiers killed in active service, found to be offensive under s 471.12 of the Criminal Code (Cth).
[footnote 38] Monis v The Queen (2013) 249 CLR 92, pp. 180 [footnote 241], [footnote 251].
[footnote 39] Jones, op. cit., p. 174.
[footnote 40] Lange v Australian Broadcasting Corporation (1997) 189 CLR 520, p. 567; Coleman v Power (2004) 220 CLR 1, p. 51 [footnote 95].
[footnote 41] ibid.
[footnote 42] Levy v Victoria (1997) 189 CLR 579, p. 619; Coleman v Power (2004) 220 CLR 1, p. 102.
[footnote 43] Levy v Victoria (1997) 189 CLR 579, p. 619–620.
[footnote 44] Coleman v Power (2004) 220 CLR 1, pp. 53-4, 56, 66.
[footnote 45] Jones, op. cit., p. 183; M. Stokes (2013) 'Tasmanian ban on abortion clinic protests may not be constitutionally valid', The Conversation, 25 November.
[footnote 46] Prohibiting communication in relation to reproductive health services in the safe access zone may also be problematic as it could apply to communication by the reproductive health service provider.
[footnote 47] See A. Stone (2013) 'Tasmania's abortion protest law is probably constitutionally valid', The Conversation, 29 November.
[footnote 48] For the efficacy of these options see F. Wu & J. Arthur (2010) A Survey of Anti-Choice Protesting Activity at Canadian Abortion Clinics, Abortion Rights Coalition of Canada, October.
[footnote 49] R v Lewis (unreported, Sup Ct, BC, 1996, No CC960120)p. 100; See R. E. Dean & S. Allanson (2004) 'Abortion in Australia: access versus protest', Journal of Law & Medicine, 11, p. 513; The Constitution Act 1982 (Can), Part 1, cl 1 and 2.
[footnote 51] 18 USC § 248 (1994).
[footnote 53] ibid.
[footnote 54] McCullen v Coakley 523 U.S. __ (2014); See L. Bassett (2014) 'Abortion clinic buffer zones crumble around the country', Huffington Post, 7 September.
[footnote 55] See 'Abortion Law France', Women on Waves; United Nations (date unknown) 'Population Policy Data Bank: Abortion Policy: France', United Nations.
[footnote 57] T. McTague (2014) 'Labour calls for US-style 'buffer zones' around abortion clinics to stop protesters hassling patients', Daily Mail, 9 December.