Keane J 36. to confine its operation to State and local government elections preserve its proscriptive effect, notwithstanding the freedom of political communication within the federation. This second issue will be referred to as the "quarantine question". 114 As to the first of these issues, the decision of this Court in Lange100 established the framework for analysis of whether a law of the Commonwealth, a State or a Territory is invalid as impermissibly trenching upon the freedom of communication derived from ss 7, 24, 64 and 128 of the Constitution. This framework was modified in Coleman v Power 101; but it remains convenient to refer to it as "the Lange test". It was most recently accepted as authoritative in the decisions of this Court in Hogan v Hinch 102, Wotton v Queensland 103 and Monis 104. In the present case, no party or intervener sought to call into question the authority of the Lange test. A law will be invalid under the Lange test if: 115 116 (a) the law effectively burdens freedom of communication about government or political matters either in its terms, operation or effect, and (b) it is not reasonably appropriate and adapted to serve a legitimate end the fulfilment of which is compatible with the maintenance of the constitutionally prescribed system of representative and responsible government and the procedure prescribed by s 128 for submitting a proposed amendment of the Constitution to the informed decision of the people. The arguments of the parties in relation to each limb may conveniently be summarised and considered in turn. An effective burden? 117 The plaintiffs submitted that s 96D effectively burdens political communication by limiting the sources of funds otherwise available to political 100 (1997) 189 CLR 520 at 567-568. 101 (2004) 220 CLR 1 at 51 [95]-[96], 78 [196], 82 [211]; [2004] HCA 39. 102 (2011) 243 CLR 506 at 542-543 [47], 554 [92]; [2011] HCA 4. 103 (2012) 246 CLR 1 at 15 [25]; [2012] HCA 2. 104 (2013) 87 ALJR 340 at 360 [61], 366-367 [102]-[106], 387-388 [236], 396 [276]; 295 ALR 259 at 279, 288-289, 318, 329.

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