This article examines the override provision under the Victorian Charter. Relevantly, Parliament has used the override on two occasions regarding laws enacted to prevent parole being granted to prisoners except in extremely limited circumstances. Conversely, Parliament responded to the COVID-19 threat without resorting to temporarily suspending the Charter via an override. This article analyses the parole-setting uses of the override within the international context of the temporary suspension of rights, against the Charter mechanisms that allow for restrictions on rights, and against the principles underlying the Charter – the retention of parliamentary sovereignty and the creation of an inter-institutional dialogue about rights. These uses test the transparency of and accountability for rights-limiting decision-making, and the culture of justification the dialogue is supposed to engender. By way of contrast and conclusion, the article highlights the curiosity between the use of the override with parole legislation and the non-use of the override with COVID-19 legislation, and revisits the case to repeal the override.
{"title":"Of Parole and Public Emergencies: Why the Victorian Charter Override Provision Should Be Repealed","authors":"J. Debeljak","doi":"10.53637/tmsv9345","DOIUrl":"https://doi.org/10.53637/tmsv9345","url":null,"abstract":"This article examines the override provision under the Victorian Charter. Relevantly, Parliament has used the override on two occasions regarding laws enacted to prevent parole being granted to prisoners except in extremely limited circumstances. Conversely, Parliament responded to the COVID-19 threat without resorting to temporarily suspending the Charter via an override. This article analyses the parole-setting uses of the override within the international context of the temporary suspension of rights, against the Charter mechanisms that allow for restrictions on rights, and against the principles underlying the Charter – the retention of parliamentary sovereignty and the creation of an inter-institutional dialogue about rights. These uses test the transparency of and accountability for rights-limiting decision-making, and the culture of justification the dialogue is supposed to engender. By way of contrast and conclusion, the article highlights the curiosity between the use of the override with parole legislation and the non-use of the override with COVID-19 legislation, and revisits the case to repeal the override.","PeriodicalId":45951,"journal":{"name":"UNIVERSITY OF NEW SOUTH WALES LAW JOURNAL","volume":null,"pages":null},"PeriodicalIF":1.3,"publicationDate":"2022-07-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"48456718","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
In all its different manifestations modern slavery involves the abuse of power and the violation of human rights. In this article, we examine whether Australia is meeting its international obligations to provide access to effective remedies to survivors of modern slavery. We argue that Australia must squarely confront the violations of human rights suffered by survivors of modern slavery by improving access to remedies, including compensation. We recommend establishing a national compensation scheme, providing survivors with greater assistance to apply for reparation orders, and improving access to support and protection. These reforms are necessary to give effect to Australia’s commitment to prevent, address and remedy the human rights abuses and enable survivors to access effective remedies.
{"title":"Modern Slavery and Material Justicce: The Case for Remedy and Reparation","authors":"Frances Simmons, J. Burn, Fiona Mcleod","doi":"10.53637/llwj9285","DOIUrl":"https://doi.org/10.53637/llwj9285","url":null,"abstract":"In all its different manifestations modern slavery involves the abuse of power and the violation of human rights. In this article, we examine whether Australia is meeting its international obligations to provide access to effective remedies to survivors of modern slavery. We argue that Australia must squarely confront the violations of human rights suffered by survivors of modern slavery by improving access to remedies, including compensation. We recommend establishing a national compensation scheme, providing survivors with greater assistance to apply for reparation orders, and improving access to support and protection. These reforms are necessary to give effect to Australia’s commitment to prevent, address and remedy the human rights abuses and enable survivors to access effective remedies.","PeriodicalId":45951,"journal":{"name":"UNIVERSITY OF NEW SOUTH WALES LAW JOURNAL","volume":null,"pages":null},"PeriodicalIF":1.3,"publicationDate":"2022-04-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"42375233","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Royal commissions are a tool for the executive government to inquire into matters of public importance. A new type of royal commission has emerged at the federal level as a result of the Royal Commission into Institutional Responses to Child Sexual Abuse – the truth-telling inquiry. Several more royal commissions have been established with an explicit truth-telling function. Recent legislative changes to the Royal Commissions Act 1902 (Cth) allowed for private sessions, cementing a truth-telling function in the legislative framework. The function of a truth-telling royal commission is to aid people who have suffered damage or injury in a process of reconciliation or restorative justice. In this article, I analyse the historical development of the powers and functions of Commonwealth royal commissions in statute and at common law in light of a truth-telling function. If this trend continues, truth-telling royal commissions may develop into an important symbol of reconciliation and justice.
{"title":"From Fact Finding to Truth Telling: An Analysis of the Changing Functions of Commonwealth Royal Commissions","authors":"Jonathan Tjandra","doi":"10.53637/blep2018","DOIUrl":"https://doi.org/10.53637/blep2018","url":null,"abstract":"Royal commissions are a tool for the executive government to inquire into matters of public importance. A new type of royal commission has emerged at the federal level as a result of the Royal Commission into Institutional Responses to Child Sexual Abuse – the truth-telling inquiry. Several more royal commissions have been established with an explicit truth-telling function. Recent legislative changes to the Royal Commissions Act 1902 (Cth) allowed for private sessions, cementing a truth-telling function in the legislative framework. The function of a truth-telling royal commission is to aid people who have suffered damage or injury in a process of reconciliation or restorative justice. In this article, I analyse the historical development of the powers and functions of Commonwealth royal commissions in statute and at common law in light of a truth-telling function. If this trend continues, truth-telling royal commissions may develop into an important symbol of reconciliation and justice.","PeriodicalId":45951,"journal":{"name":"UNIVERSITY OF NEW SOUTH WALES LAW JOURNAL","volume":null,"pages":null},"PeriodicalIF":1.3,"publicationDate":"2022-04-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"48059940","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Late in 2020 in California, two giant rideshare operators, Uber and Lyft, spearheaded a USD200 million campaign to overturn state legislation providing employment entitlements to their workers. This article exposes the way these enterprises employ legal drafting to disguise the reality of their relationships with workers; and we consider the rhetorical arguments they use to justify these strategies. We conclude that it is time for Australian regulators to adopt an alternative approach to ensuring basic protections for workers which focusses on the nature of the work being undertaken, rather than on the legal form of the contract between enterprise and worker. We focus on the Australian road transport industry, and particularly on rideshare and food delivery workers, because despite assertions that their labour is part of a shiny new ‘digital economy’, this kind of work has been important in societies since medieval times, or earlier.
{"title":"Constraining the Uber-Powerful Digital Platforms: A Proposal for a New Form of Regulation of On-Demand Road Transport Work","authors":"M. Rawling, Joellen Riley Munton","doi":"10.53637/dpei2001","DOIUrl":"https://doi.org/10.53637/dpei2001","url":null,"abstract":"Late in 2020 in California, two giant rideshare operators, Uber and Lyft, spearheaded a USD200 million campaign to overturn state legislation providing employment entitlements to their workers. This article exposes the way these enterprises employ legal drafting to disguise the reality of their relationships with workers; and we consider the rhetorical arguments they use to justify these strategies. We conclude that it is time for Australian regulators to adopt an alternative approach to ensuring basic protections for workers which focusses on the nature of the work being undertaken, rather than on the legal form of the contract between enterprise and worker. We focus on the Australian road transport industry, and particularly on rideshare and food delivery workers, because despite assertions that their labour is part of a shiny new ‘digital economy’, this kind of work has been important in societies since medieval times, or earlier.","PeriodicalId":45951,"journal":{"name":"UNIVERSITY OF NEW SOUTH WALES LAW JOURNAL","volume":null,"pages":null},"PeriodicalIF":1.3,"publicationDate":"2022-04-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"44106392","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article analyses the emerging evidence of labour exploitation of refugees and asylum seekers on temporary visas in Australia. Over the last decade, Australia’s temporary protection regime has been marked by profound uncertainty in relation to visa status, unfettered Ministerial discretion, and the punitive exercise of governmental power. We argue that this framework amounts to abuse of governmental power, confining refugees and asylum seekers who arrived by boat to a situation of radical temporariness in Australia. This results not only in the denial of permanent protection and social inclusion to these refugees and asylum seekers, but also provides conditions for greater abuse of power by employers in the realm of workplaces across Australia. We outline six factors related to temporary immigration status and other punitive, unpredictable and arbitrary elements in this regulatory regime that currently increase the vulnerability of refugees and asylum seekers to labour exploitation.
{"title":"Refugees and Asylum Seekers as Workers: Radical Temporariness and Labour Exploitation in Australia","authors":"Laurie Berg, S. Dehm, A. Vogl","doi":"10.53637/vvzr2705","DOIUrl":"https://doi.org/10.53637/vvzr2705","url":null,"abstract":"This article analyses the emerging evidence of labour exploitation of refugees and asylum seekers on temporary visas in Australia. Over the last decade, Australia’s temporary protection regime has been marked by profound uncertainty in relation to visa status, unfettered Ministerial discretion, and the punitive exercise of governmental power. We argue that this framework amounts to abuse of governmental power, confining refugees and asylum seekers who arrived by boat to a situation of radical temporariness in Australia. This results not only in the denial of permanent protection and social inclusion to these refugees and asylum seekers, but also provides conditions for greater abuse of power by employers in the realm of workplaces across Australia. We outline six factors related to temporary immigration status and other punitive, unpredictable and arbitrary elements in this regulatory regime that currently increase the vulnerability of refugees and asylum seekers to labour exploitation.","PeriodicalId":45951,"journal":{"name":"UNIVERSITY OF NEW SOUTH WALES LAW JOURNAL","volume":null,"pages":null},"PeriodicalIF":1.3,"publicationDate":"2022-04-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"46941606","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Noting the ‘deep concern’ of taxpayers and stakeholders with how the assessment power is sometimes used, this article demonstrates that notwithstanding the statutory process for overturning an assessment in part IVC of the Taxation Administration Act 1953 (Cth) and recent judicial comments constraining the scope of judicial review for jurisdictional error, judicial review is nevertheless available to invalidate a default assessment or one made at any time where the Commissioner merely suspects the taxpayer engaged in fraud or evasion without any probative evidence to this effect. As will appear, in either instance the assessment-making process may be challenged in judicial review proceedings for legal unreasonableness, which markedly differs, and is otherwise excluded, from a part IVC challenge but which fundamentally bears on whether there has been abuse of the assessment-making power and thus whether the ensuing assessment satisfies the statutory description of assessment.
{"title":"Judicial Review and the Tax-Assessment Making Process","authors":"J. Azzi","doi":"10.53637/dlcb5923","DOIUrl":"https://doi.org/10.53637/dlcb5923","url":null,"abstract":"Noting the ‘deep concern’ of taxpayers and stakeholders with how the assessment power is sometimes used, this article demonstrates that notwithstanding the statutory process for overturning an assessment in part IVC of the Taxation Administration Act 1953 (Cth) and recent judicial comments constraining the scope of judicial review for jurisdictional error, judicial review is nevertheless available to invalidate a default assessment or one made at any time where the Commissioner merely suspects the taxpayer engaged in fraud or evasion without any probative evidence to this effect. As will appear, in either instance the assessment-making process may be challenged in judicial review proceedings for legal unreasonableness, which markedly differs, and is otherwise excluded, from a part IVC challenge but which fundamentally bears on whether there has been abuse of the assessment-making power and thus whether the ensuing assessment satisfies the statutory description of assessment.","PeriodicalId":45951,"journal":{"name":"UNIVERSITY OF NEW SOUTH WALES LAW JOURNAL","volume":null,"pages":null},"PeriodicalIF":1.3,"publicationDate":"2022-04-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"44412877","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
B. White, L. Willmott, Katrine Del Villar, Jayne Hewitt, Eliana Close, Laura Ley Greaves, J. Kevin Cameron, R. Meehan, J. Downie
Eligibility criteria in voluntary assisted dying legislation determine access to assistance to die. This article undertakes the practical exercise of analysing whether each of the following nine medical conditions can provide an individual with access to voluntary assisted dying: cancer, motor neurone disease, chronic obstructive pulmonary disease, chronic kidney disease, Alzheimer’s disease, anorexia, frailty, spinal cord injury and Huntington’s disease. This analysis occurs across five legal frameworks: Victoria, Western Australia, a model Bill in Australia, Oregon and Canada. The article argues that it is critical to evaluate voluntary assisted dying legislation in relation to key medical conditions to determine the law’s boundaries and operation. A key finding is that some frameworks tended to grant the same access to voluntary assisted dying, despite having different eligibility criteria. The article concludes with broader regulatory insights for designing voluntary assisted dying frameworks both for jurisdictions considering reform and those reviewing existing legislation.
{"title":"Who is Eligible for Voluntary Assisted Dying: Nine Medical Conditions Assessed against Five Legal Frameworks","authors":"B. White, L. Willmott, Katrine Del Villar, Jayne Hewitt, Eliana Close, Laura Ley Greaves, J. Kevin Cameron, R. Meehan, J. Downie","doi":"10.53637/fyid9182","DOIUrl":"https://doi.org/10.53637/fyid9182","url":null,"abstract":"Eligibility criteria in voluntary assisted dying legislation determine access to assistance to die. This article undertakes the practical exercise of analysing whether each of the following nine medical conditions can provide an individual with access to voluntary assisted dying: cancer, motor neurone disease, chronic obstructive pulmonary disease, chronic kidney disease, Alzheimer’s disease, anorexia, frailty, spinal cord injury and Huntington’s disease. This analysis occurs across five legal frameworks: Victoria, Western Australia, a model Bill in Australia, Oregon and Canada. The article argues that it is critical to evaluate voluntary assisted dying legislation in relation to key medical conditions to determine the law’s boundaries and operation. A key finding is that some frameworks tended to grant the same access to voluntary assisted dying, despite having different eligibility criteria. The article concludes with broader regulatory insights for designing voluntary assisted dying frameworks both for jurisdictions considering reform and those reviewing existing legislation.","PeriodicalId":45951,"journal":{"name":"UNIVERSITY OF NEW SOUTH WALES LAW JOURNAL","volume":null,"pages":null},"PeriodicalIF":1.3,"publicationDate":"2022-04-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"42701107","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Consumer Affairs Australia and New Zealand conducted a wholesale review of the Australian Consumer Law in 2017. Despite calls for the introduction of an ‘unfair conduct’ prohibition, the review found that a change to the current prohibition on ‘unconscionable conduct’ was unnecessary in light of the statutory prohibition evolving from its equitable origins. The recent High Court decision in Australian Securities and Investments Commission v Kobelt (2019) 267 CLR 1 has stifled this development and realigned statutory unconscionability with the restrictive equitable doctrine. In light of curial and extra- curial comments from senior members of the judiciary, regulators and commentators, it is appropriate to reconsider the merits of a prohibition on unfair conduct. This article argues that this reform will better promote community understanding, lead to greater certainty in commerce and fulfil the role of a ‘safety net’ provision in the Australian Consumer Law.
{"title":"Beyond Unconscionability Exploring the Case for a New Prohibition on Unfair Conduct","authors":"Nicholas J. Felstead","doi":"10.53637/ibyx4580","DOIUrl":"https://doi.org/10.53637/ibyx4580","url":null,"abstract":"Consumer Affairs Australia and New Zealand conducted a wholesale review of the Australian Consumer Law in 2017. Despite calls for the introduction of an ‘unfair conduct’ prohibition, the review found that a change to the current prohibition on ‘unconscionable conduct’ was unnecessary in light of the statutory prohibition evolving from its equitable origins. The recent High Court decision in Australian Securities and Investments Commission v Kobelt (2019) 267 CLR 1 has stifled this development and realigned statutory unconscionability with the restrictive equitable doctrine. In light of curial and extra- curial comments from senior members of the judiciary, regulators and commentators, it is appropriate to reconsider the merits of a prohibition on unfair conduct. This article argues that this reform will better promote community understanding, lead to greater certainty in commerce and fulfil the role of a ‘safety net’ provision in the Australian Consumer Law.","PeriodicalId":45951,"journal":{"name":"UNIVERSITY OF NEW SOUTH WALES LAW JOURNAL","volume":null,"pages":null},"PeriodicalIF":1.3,"publicationDate":"2022-04-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"47552867","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
J. Kotzmann, M. Bagaric, Gabrielle C. Wolf, Morgan Stonebridge
Awareness of the incidence and impact of domestic violence has increased in recent decades, along with community and legal recognition of the interests of animals. However, streams of jurisprudence addressing these issues have only partially influenced one another. While in most Australian jurisdictions, animal cruelty can constitute domestic violence, abused companion animals have not been accorded the legal status of victims. This article proposes introducing laws that recognise such animals as sentient victims of domestic violence. This would enable courts to make orders protecting these animals, which would safeguard their welfare and ensure that people with whom they live who are also experiencing domestic violence can escape without worrying about the fate of their animals. Further, it would convey the seriousness of animal cruelty, and might increase support for and awareness of programs for re-homing abused animals, and training of people involved with animals to identify and report animal abuse.
{"title":"Addressing the Impact of Animal Abuse: The Need for Legal Recognition of Abused Pets as Sentient Victims of Domestic Violence in Australia","authors":"J. Kotzmann, M. Bagaric, Gabrielle C. Wolf, Morgan Stonebridge","doi":"10.53637/wgyr1275","DOIUrl":"https://doi.org/10.53637/wgyr1275","url":null,"abstract":"Awareness of the incidence and impact of domestic violence has increased in recent decades, along with community and legal recognition of the interests of animals. However, streams of jurisprudence addressing these issues have only partially influenced one another. While in most Australian jurisdictions, animal cruelty can constitute domestic violence, abused companion animals have not been accorded the legal status of victims. This article proposes introducing laws that recognise such animals as sentient victims of domestic violence. This would enable courts to make orders protecting these animals, which would safeguard their welfare and ensure that people with whom they live who are also experiencing domestic violence can escape without worrying about the fate of their animals. Further, it would convey the seriousness of animal cruelty, and might increase support for and awareness of programs for re-homing abused animals, and training of people involved with animals to identify and report animal abuse.","PeriodicalId":45951,"journal":{"name":"UNIVERSITY OF NEW SOUTH WALES LAW JOURNAL","volume":null,"pages":null},"PeriodicalIF":1.3,"publicationDate":"2022-04-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"43974428","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Debate on the need for new anti-discrimination laws to address religious discrimination continues in Australia. Claims for greater protection for freedom of religious expression present particular challenges for employers who bear responsibilities to maintain psychologically safe and healthy workplaces for all their employees. The present ‘general protections’ against discriminatory treatment in the Fair Work Act 2009 (Cth) do not adequately deal with complaints of discrimination, largely because of the ease with which employers can excuse adverse action on the basis of their own workplace policies. However, the proposals in the Religious Discrimination Bill 2019 (Cth) go too far in seeking to address that weakness. We propose that an alternative model for balancing the respective interests in workplace disputes of this kind would be expanding the workplace bullying and unfair dismissal jurisdictions of the Fair Work Commission, to enable these kinds of conflicts to be managed in a proportionate and balanced manner.
{"title":"Religious Freedom and Job Security","authors":"Joellen Riley Munton, T. MacDermot","doi":"10.53637/fnzf5790","DOIUrl":"https://doi.org/10.53637/fnzf5790","url":null,"abstract":"Debate on the need for new anti-discrimination laws to address religious discrimination continues in Australia. Claims for greater protection for freedom of religious expression present particular challenges for employers who bear responsibilities to maintain psychologically safe and healthy workplaces for all their employees. The present ‘general protections’ against discriminatory treatment in the Fair Work Act 2009 (Cth) do not adequately deal with complaints of discrimination, largely because of the ease with which employers can excuse adverse action on the basis of their own workplace policies. However, the proposals in the Religious Discrimination Bill 2019 (Cth) go too far in seeking to address that weakness. We propose that an alternative model for balancing the respective interests in workplace disputes of this kind would be expanding the workplace bullying and unfair dismissal jurisdictions of the Fair Work Commission, to enable these kinds of conflicts to be managed in a proportionate and balanced manner.","PeriodicalId":45951,"journal":{"name":"UNIVERSITY OF NEW SOUTH WALES LAW JOURNAL","volume":null,"pages":null},"PeriodicalIF":1.3,"publicationDate":"2022-04-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"42255500","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}