^"History of the Church of England in Western Australia". Anglican Church Diocese of Perth. Anglican Diocese of Perth. 2021. Retrieved 11 December 2021. In 1836, the Reverend Louis Giustiniani arrived in Western Australia; an appointee of the 'Western Australian Missionary Society'. He was tasked with ministering to Aboriginal people and became a vocal opponent of what he witnessed as the unequal application of law in relation to Aboriginal people. This brought him into conflict with many of the settlers, the government and the establishment of the church; he left the colony in 1838.
^Allbrook, Malcolm (August 2008). 'Imperial Family': The Prinseps, Empire and Colonial Government in India and Australia(PDF) (PhD). Griffith University. doi:10.25904/1912/3589. Retrieved 11 December 2021. Guistiniani's subsequent rapid departure from the colony set an unfortunate pattern for the future. Those who spoke out in support of Aboriginal populations became liable to vilification and were often left with no other alternative but to leave.
^Giustiniani, L. (1848). "Formation of the free Catholic Church in Rochester". American Protestant Magazine. 4. New York: American Protestant Society: 175–177.
^Doty, Lockwood R., ed. (1925). History of the Genesee Country(PDF). Vol. II. Chicago: S. J. Clarke Publishing Company. p. 799. Retrieved 11 December 2021.