In particular, they were within the scope of the "provision of. Benefits to students" within the meaning of s 51(xxiiiA) of the Constitution.[1]:para 441Following the High Court's decision, the Commonwealth Parliament enacted the Financial Framework Legislation Amendment Act (No 3) (Cth)[2] in an attempt to validate contracts and payments made under the National School Chaplaincy Programme as well as hundreds of other Commonwealth spending programs. Mr Williams challenged the validity and effectiveness of that legislation in Williams v Commonwealth (No 2).

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