The most significant s 92 case since Cole v Whitfield (1988). Clive Palmer challenged Western Australia's hard border closure during the COVID-19 pandemic. The Court upheld the closure, holding that s 92 does not guarantee absolute freedom but rather freedom from discriminatory or protectionist burdens. The Court reunified the 'trade and commerce' and 'intercourse' limbs of s 92 and applied structured proportionality analysis for the first time.