Native Title rights will be extinguished by valid1 legislation2 or acts of the executive3 which are inconsistent with the continuing recognition of those rights under the common law.4 The process to compare Native Title Rights to these 'government acts' and subsequently determine if the rights have been extinguished is outlined below. Extinguishment? 'Extinguishment' refers to the effect of a piece of Legislation or act of the executive that is inconsistent with Native Title rights.5 Once Native Title rights are extinguished, they are no longer enforceable.6 Court's Approach Native Title rights can only be extinguished by legislation that clearly intends to do so.7 The intentions of the members of parliament8 will only be assessed if they assist in determining what statutory rights are granted under the legislation.9 The primary consideration is a comparison of Native Title rights claimed to the statutory rights created by a piece of legislation.10 The full extent of those statutory rights will be examined, not the way in which the rights have previously been exercised.11 If native title rights cannot be exercised in conjunction with statutory rights, they will be extinguished to the extent of the inconsistency.12 Collection of Rights Native Title is a collection of rights,13 capable of being separately identified and extinguished by statutory rights.14 Accordingly, where some, but not all claimed Native Title rights are inconsistent with a piece of legislation, only those inconsistent rights will be extinguished.15 Regulations Yanner v Eaton16 and Akiba v Commonwealth17 showed that Native Title rights to exploit natural resources through hunting and fishing could survive regulations prohibiting the same. The court found that merely regulating these activities is insufficient to extinguish Native Title rights.18 In some cases, regulation of a Native Title right shows that extinguishment was not intended by the legislature.19 However, regulation may be so strong that any exercise of Native Title rights would be 1 Mabo v Queensland (No 2) (1992) 175 CLR 1, 63-4. 2 Native Title Act 1993 (Cth) s 226. 3 Ibid. 4 Mabo v Queensland (No 2) (1992) 175 CLR 1, 64; Native Title Act 1993 (Cth) s 227. 5 Western Australia v Ward (2002) 213 CLR 1, [58]. 6 Native Title Act 1993 (Cth) s 237A; Yanner v Eaton (1999) 201 CLR 351, 395 [107]. 7 Ibid 64. 8 Western Australia v Ward (2002) 213 CLR 1, [78]; Akiba v Commonwealth (2013) 250 CLR 209, [62]. 9 Queensland v Congoo (2015) 256 CLR 239, [27], [116], [139]. 10 Wik Peoples v Queensland (1996) 187 CLR 1, 75-6, 108, 133, 149, 195-6, 243. 11 Western Australia v Ward (2002) 213 CLR 1, [215]. 12 Ibid; Wik Peoples v Queensland (1996) 187 CLR 1, 185; Yanner v Eaton (1999) 201 CLR 351, 395-96 [107]- [108]. 13 Western Australia v Ward (2002) 213 CLR 1, [95]. 14 Yanner v Eaton (1999) 201 CLR 351, 395 [106]; Akiba v Commonwealth (2013) 250 CLR 209, [31]. 15 Western Australia v Ward (2002) 213 CLR 1, [95], [149]-[151]. 16 (1999) 201 CLR 351. 17 (2013) 250