The Minister for Local Government has launched the final Destination 2036 action plan, dated June 2012 (the “Action Plan”). Initiative 12 of the Action Plan is to recognise Local Government as a legitimate and important sphere of government. As a result of the High Court of Australia’s recent judgments such as Williams a referendum is intended to be put by the Commonwealth Government to the Australian people by 2013 on the recognition of Local Government in the Australian Constitution. The success of such a proposal must be questioned as a referendum on this issue has failed on 2 previous occasions. A change to the Australian Constitution to recognise Local Government may however be the only way to ensure that the Commonwealth Government can lawfully fund Local Government and funding programs.
 See also Pape v Federal Commissioner of Taxation  HCA 23 (7 July 2009)