Western Australia is set to mark a major milestone in Indigenous land recognition, with the state’s 150th native title determination to be made over land approximately 180 kilometres north of Laverton in the goldfields, west of Lake Wells. The determination follows the long-running Payarri native title claim, first lodged in 1994 and spearheaded by Ngalia man Kado Muir and his family, including senior elders.
The determination area covers largely untouched country of spinifex plains, sandhills, clay pans and granite breakaways. Through the Payarri people’s recognition of native title, their ancestors – and their descendants today – are acknowledged as part of Western Desert society, which continues to exist as a cohesive body united by the acknowledgement and observance of traditional laws and customs.
Separately, in late 2025, the Federal Court recognised the Marlinyu Ghoorlie claimants as traditional owners of an area spanning more than 89,000 square kilometres of the goldfields. The determination covers Kalgoorlie-Boulder, Kambalda and Coolgardie, extending west to Southern Cross in the wheatbelt.
The Marlinyu Ghoorlie native title claim was first filed in 2017. In delivering judgment, Federal Court Justice O’Bryan cited the “rapid and overwhelming effects” of European settlement on Aboriginal people in the goldfields as a key consideration in determining the composition of native title groups. At the same time, the court dismissed the Karratjibbin people’s native title claim over areas overlapping the Marlinyu Ghoorlie claim area.
Kado Muir said native title determinations remain an important cultural recognition of traditional Aboriginal society. He used his own painting of ancestral walking tracks as part of the evidence supporting the Payarri claim and spoke to the vital place both his people and the Marlinyu Ghoorlie hold within Aboriginal society.
“Contextualised into the actual society under which Marlinyu Ghoorlie sits, it forms a long arc – from the Mirning on the south coast and Nullarbor, to Ngadju in the southern woodlands, to Kalamia in the central woodlands, and then Badimia and Widi in the north,” Mr Muir said.
“These groups act as a buffer between Noongar society in the southwest and desert societies to the east and northeast, as well as Pilbara societies to the north. That’s the key to Marlinyu Ghoorlie – it’s a triumph of historical data that demonstrates deep-time connections that were later obscured by the desert diaspora.”
