In 2012, statements in some of Kerr's papers, released by the National Archives, following a request by Professor Jenny Hocking were given publicity in her biography, "Gough Whitlam: His Time". Kerr confirms that in 1975 Mason had advised him on whether the Constitution allows a Governor-General to dismiss a Prime Minister who is unable to obtain supply. Kerr claims that Mason, as well as Chief Justice Sir Garfield Barwick, had advised him that there is such power and that he had followed that advice.