After looking at Nationwide News and ACTV the Court agreed in Theophanous that there is an implied freedom of communication in the Commonwealth Constitution. The Court stated (at 716) "in those cases the Court distilled from the provisions and structure of the Constitution, particularly from the concept of representative government which is enshrined in the Constitution, an implication of freedom of communication."
"Freedom to speak of members of parliament,"
The National Legal Eagle: Vol. 3
, Article 6.
Available at: https://epublications.bond.edu.au/nle/vol3/iss1/6