freedom of speech and of the press in the First Amendment to the United States Constitution. But it remains to be seen whether a suitable expansion of the notion of "political communication" may not lead, in time, to a similar result. In the migration-bias case, some of the Justices, while being careful to quarantine "commercial speech without political content", seemed to imply that the scope of "political speech" may nevertheless be very broad indeed. Mitchell Landrigan goes as far as arguing that the exception to the "Anti-Discrimination Act 1977" (NSW) permitting the exclusion of women from ordination as priests infringes the right of women to "rise to positions from which they may take part in political speech as persuasive religious leaders." Any such constitutional protection would depend on a court finding that the anti-discrimination laws, first, effectively burdened political speech (as relevant to the Commonwealth Parliament) and, secondly, disproportionately burdened such speech.