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I call my paper 'Social Justice Then Native Title' in order to make a clear distinction between two aspects of Indigenous People's struggle; the ultimate goals we are seeking to achieve and the means by which we seek to achieve them. Distinguishing the means and the ends, the former a servant of the latter, is a fundamental tenet of strategic thinking. And it is clear to me that a strategic approach will identify native title as simply a tool for achieving social justice for Indigenous people.