Leonard John Lindon (Len Lindon)

About Leonard Lindon

Leonard John Lindon, known as Len Lindon, is an Australian legal practitioner and the husband of Melbourne family-law barrister Mary Agresta.

Lindon’s legal history is considerably less conventional than the ordinary professional biography. Material supplied to Lawyer Reviews describes him as a qualified legal practitioner admitted to practise in South Australia and on the roll of practitioners of the High Court of Australia, and as an LL.B (Hons) graduate of the University of Adelaide in 1974. Lawyer Reviews has not independently verified those three points against a primary record; see the Verification section below.

During the 1980s he was also known as “Citizen Limbo” and became involved in extensive litigation arising from protests at Pine Gap. His subsequent legal history extended through Australian superior courts and ultimately to a communication against Australia before the United Nations Human Rights Committee. Those proceedings are a matter of public record and are set out below.

Current practising status is a separate question. Neither the Victorian register of lawyers nor the South Australian Register of Practising Certificates lists a current practising certificate for him, checked 13 September 2026. He was nonetheless described as a barrister in legal media as recently as March 2024. Both findings are set out below.

• Citizen Limbo The name he used in the 1980s Pine Gap litigation, recorded in the UN Human Rights Committee’s 1998 decision.
• Pine Gap, 1987 to 1991 Trespass charge, conviction and a $150 fine in April 1988; appeal allowed by the Supreme Court in March 1989; reconvicted in absence at the rehearing in April 1991.
• Federal Court, 1995 Application concerning a bankruptcy notice for $33,424.78 in costs; dismissed 7 February 1995.
• United Nations, 1995 to 1998 Communication No. 646/1995 against Australia; declared inadmissible.
• Arabunna and genocide work, 2000 to 2024 Described as the barrister for Arabunna traditional owners c. 2000, and as “barrister Len Lindon” in a March 2024 interview with Uncle Robbie Thorpe.

Leonard Lindon and Mary Agresta

Lindon is the husband of Melbourne barrister Mary Agresta, according to information provided to and confirmed by Lawyer Reviews.

Mary Agresta practises separately as a barrister. Nothing in this profile suggests that she participated in Lindon’s historical litigation or is responsible for his conduct, arguments, costs orders or litigation strategy.

Lawyer Reviews has not independently located a public record confirming the marriage. The relationship is therefore identified as information confirmed directly to Lawyer Reviews rather than independently verified public-record information.

View Mary Agresta’s profile →

From Leonard Lindon to “Citizen Limbo”

Lindon’s recorded legal history is decidedly unconventional.

During the 1980s he used the name Citizen Limbo in connection with litigation arising from protests at the Joint Defence Space Research Facility at Pine Gap, near Alice Springs. The United Nations Human Rights Committee’s decision records that he “was then known as ‘Citizen Limbo’”.

On 19 October 1987, Lindon participated in a demonstration at Pine Gap and was charged the same day with trespass.

On 14 April 1988 he was convicted of that offence by the Court of Summary Jurisdiction sitting at Alice Springs and fined $150.

Lindon appealed.

In March 1989, the Supreme Court of the Northern Territory allowed his appeal on the ground that he had not received a fair hearing, and remitted the matter for rehearing. The rehearing was listed for August 1989, and in the lead-up he sought to raise several matters on interlocutory applications to the Magistrates’ Court and the Supreme Court. The Full Court’s decision of 27 November 1989 is reported as Limbo v Little in the International Law Reports.

What followed was not simply the conclusion of an ordinary trespass matter.

The dispute developed into extensive litigation involving matters including Pine Gap, nuclear weapons, international law, constitutional questions, judicial impartiality, evidence, witnesses and governmental conduct.

A remarkably persistent litigant

Lindon’s legal history is notable not simply for the subjects he pursued, but for how persistently he pursued them.

What began with a relatively modest trespass prosecution developed into years of litigation involving numerous applications and proceedings, constitutional and international-law arguments, disputes over evidence and judicial process, Federal Court proceedings, applications in the High Court of Australia in 1995 and 1996 (Lindon v Commonwealth of Australia, M80/1995 and M82/1995), and, eventually, a communication against Australia before the United Nations Human Rights Committee.

The record also shows that persistence did not necessarily translate into success.

In 1995, Lindon sought Federal Court relief preventing Commonwealth respondents from proceeding on a bankruptcy notice associated with costs arising from his earlier litigation.

The application was dismissed.

The costs figure on that notice was $33,424.78, arising from previous proceedings.

His subsequent communication to the United Nations Human Rights Committee was also declared inadmissible.

The resulting picture is of a legally qualified litigant prepared to pursue arguments through multiple forums and over an extended period, including after earlier proceedings had generated significant adverse costs.

That history may strike some readers as extraordinary persistence; others may regard it as litigation pursued well beyond the point at which conventional cost-benefit considerations would ordinarily bring a dispute to an end.

Lawyer Reviews leaves that judgment to the reader.

Did Len Lindon have any success?

Twice, on procedure, and early. Never on substance.

The record set out in the United Nations Human Rights Committee’s decision allows a straightforward tally of every step in the Pine Gap litigation and its aftermath.

The wins. In March 1989 the Supreme Court of the Northern Territory allowed Lindon’s appeal against his April 1988 trespass conviction, on the ground that he had not received a fair hearing, and sent the charge back for rehearing. That is a genuine result: a conviction set aside. A later application to defer the rehearing also succeeded. Both were wins on process. Neither court accepted any argument about Pine Gap, nuclear weapons or international law; the appeal court remitted the charge rather than dismissing it.

Everything after that. The interlocutory applications he pressed in the lead-up to the rehearing were taken to the Full Court, which on 27 November 1989 rejected each of them and awarded the Territory its costs. When the rehearing finally took place, on 15 April 1991, he was convicted in his absence, fined a total of $450 and ordered to pay $3,856.44 in costs. He sought special leave to appeal to the High Court of Australia and was refused. A bankruptcy notice for $33,424.78 in accumulated costs followed in June 1993; his Federal Court application to restrain it was dismissed with costs on 7 February 1995. His communication to the United Nations Human Rights Committee was declared inadmissible in 1998 on five separate grounds, including that he could not represent other protesters without their authority, that several claims were insufficiently substantiated, that he had not shown himself to be a victim of any threat to his right to life, and that the bankruptcy complaint had not exhausted domestic remedies because proceedings were never actually commenced.

What was never won. No Australian court and no international body accepted the substantive argument that ran through the whole campaign: that Pine Gap’s role in nuclear war-fighting made the trespass prosecution unfair or unlawful. The Committee said it “cannot reverse decisions made by domestic courts under domestic law” and found that Lindon had “failed to substantiate that his trial was unfair” on that theory.

A fair reading. An inadmissibility decision is not a ruling that the claims were wrong; it is a decision not to examine them. The Committee did not decide whether Australia’s defence arrangements breached the Covenant. The High Court, for its part, heard his argument about judicial bias in November 1997 and answered it. Lindon was heard, repeatedly, at every level. He was not vindicated at any of them.

Every row is taken from the Committee’s decision, UN Doc CCPR/C/64/D/646/1995, which summarises the domestic proceedings as part of its admissibility analysis. Source links are in the Sources card below.

Federal Court proceedings

In 1995 Lindon applied to the Federal Court of Australia. The citation supplied to Lawyer Reviews is:

Lindon L J v Hon Kerr J D C MP [1995] FCA 22, heard in Melbourne before Ryan J.

Lindon sought to restrain Commonwealth respondents from proceeding against him in bankruptcy in connection with unpaid costs arising from earlier litigation.

The United Nations Human Rights Committee’s decision independently records the sequence: a bankruptcy notice served on 15 June 1993 for $33,424.78 in costs, and an application that was dismissed on 7 February 1995.

United Nations Human Rights Committee

Lindon’s litigation ultimately extended beyond Australian courts.

On 11 February 1995, Leonard John Lindon submitted Communication No. 646/1995, Lindon v Australia, to the United Nations Human Rights Committee.

Lindon advanced claims under the International Covenant on Civil and Political Rights, invoking article 6 (the right to life) and article 14, paragraphs 1 and 7 (fair-hearing rights and the rule against double jeopardy), in connection with his litigation and Australia’s defence and nuclear policies. He also sought to act on behalf of others who had attended protests at Pine Gap.

The Committee did not uphold the claims. The communication was declared inadmissible.

Full text: University of Minnesota Human Rights Library · OHCHR Jurisprudence Database.

Later work: Arabunna, genocide prosecutions and the 2024 interview

Lindon did not stop appearing in legal contexts after the Pine Gap litigation ended.

Campaign material from around 2000 concerning the Arabunna people’s litigation against Western Mining Corporation (High Court matter A20 of 2000) describes “Len Lindon” as the barrister acting for Arabunna traditional owners in the South Australian Supreme Court and the High Court.

More than two decades later he was still being described the same way. On 8 March 2024, Sydney Criminal Lawyers published an interview headed “Prosecuting Australian Genocide: A Chat With Uncle Robbie Thorpe and Barrister Len Lindon”, which refers to him throughout as “Aboriginal genocide barrister Len Lindon”. In it he discusses division 268 of the Criminal Code, the Attorney-General’s fiat and international criminal law, alongside Gunnai and Gunditjmara activist Uncle Robbie Thorpe.

That 2024 article is the most recent published description of Lindon in legal terms that Lawyer Reviews has located. It is a legal-media description, not a regulatory record, and it does not state where he is admitted or whether he holds a practising certificate.

Lawyer Reviews has not located a published correction or retraction saying that these descriptions of Lindon as a barrister or legal adviser were erroneous.

Not to be confused with Sir Leonard Lindon, the Adelaide surgeon

Searches for “Leonard Lindon” return a different and better-documented person: Sir Leonard Charles Edward Lindon (1896–1978), the Adelaide neurosurgeon who led the Royal Adelaide Hospital’s neurosurgical service from 1931, performed pioneering spinal and intracranial surgery, and served as President of the Royal Australasian College of Surgeons from 1959 to 1961.

The two are not the same person and are not known to be related. The surgeon was a doctor, not a lawyer, and died in 1978. This profile concerns Leonard John Lindon, the legal practitioner known as Len Lindon, whose recorded litigation begins in 1987.

The confusion is easy to make: both men are associated with Adelaide and the University of Adelaide. If you are looking for the surgeon, the Royal Australasian College of Surgeons and the South Australian Medical Heritage Society hold biographies of him.

Qualifications and admission

Material supplied to Lawyer Reviews states:

• DegreeBachelor of Laws (Honours), University of Adelaide, 1974
• AdmissionAdmitted to practise in South Australia
• High CourtOn the roll of practitioners of the High Court of Australia

Lawyer Reviews has not been able to check these three points against the University of Adelaide’s graduate records or the South Australian roll of admissions, and the High Court Register of Practitioners is not publicly searchable, so all three are presented as supplied. His historical status as a legal practitioner is in any case distinct from the question of his present entitlement to practise.

Is Leonard Lindon still a practising lawyer?

What this does and does not mean. A person may remain admitted to the legal profession, and remain on a Supreme Court roll for life, without holding a current practising certificate. Many people with law degrees and admissions work without one, entirely properly. The absence of a Victorian or South Australian certificate is therefore not evidence of wrongdoing, and Lawyer Reviews has not established that Lindon was struck off, suspended or disciplined. Those are materially different propositions from simply not appearing on a current-certificate register.

It is also worth stating plainly that Sydney Criminal Lawyers described him as a barrister as recently as March 2024, and Lawyer Reviews has not reconciled that description with the register searches above.

Accordingly, Lawyer Reviews describes him as: Australian legal practitioner (historical record) — current practising status not established.

If Lindon presently holds a practising certificate in any Australian jurisdiction, Lawyer Reviews welcomes the registration details and will correct this section promptly.

Family connection

For readers arriving at this page through Lawyer Reviews’ coverage of the Victorian family-law profession, Leonard Lindon’s connection to Mary Agresta is personal rather than professional: Lawyer Reviews has been informed, and has received confirmation, that they are married. No public record of the marriage has been located.

Mary Agresta’s work as a barrister should be assessed on its own record.

Likewise, Lindon’s unusual historical litigation should not be attributed to Mary Agresta merely because they are spouses.

Read the Mary Agresta profile →

Reviews

Corrections and right of response

Lawyer Reviews welcomes corrections from Leonard Lindon, Mary Agresta, or anyone able to provide reliable primary-source information relevant to this profile.

Where information has been independently established through judicial or institutional records, the profile identifies it accordingly. Where information has instead been supplied directly to Lawyer Reviews, that distinction is disclosed.

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Verification

Last checked: 13 September 2026.