Trust in policing: Western Sydney Western Sydney, an area with a high percentage of migrants and a high degree of socioeconomic disadvantage, had disproportionate rates of COVID-19 deaths.71 Sections of Western Sydney were given strict curfews and other restrictions, and experienced a heavy police and military presence.72 The NSW Bureau of Crime Statistics and Research (BOCSAR) found that while the majority of Sydney residents ‘strictly complied’ with public health orders, police acted on 36,597 breaches of public health orders in the twomonth period between July and August 2021.73 About 13,292 breaches occurred in the Local Government Areas of concern (primarily in Western Sydney).74 BOCSAR concluded that: there is no evidence that people in areas of concern or young people are engaging in more noncompliant activities. Overall, our results suggest that breaches are largely enforcement-driven rather than reflecting underlying patterns of non-compliance.75 In Western Sydney suburbs of Liverpool and Mount Druitt there were $2.5 million in COVID-19 fines handed out since June 2021.76 The different rules and stricter police enforcement applying to Western Sydney led to a breakdown of trust, with community leaders pointing out these discrepancies, and residents stating that they felt ‘scapegoated’.77 This paralleled the treatment of people high-rise public housing towers in inner north Melbourne, discussed in the COVID-19 case study in section 1.5. Associate Professor Stuart Ralph and Mark Stoové made the following observations on the decision to use the military in Western Sydney: It’s incongruous that this same military is simultaneously being used to deliver public health messages that rely on engagement, trust and transparency. 78 South Western Sydney is rich in culturally and linguistically diverse communities … . Many of these people have good reason to regard armed forces as unreliable sources of public assistance. In these communities the use of the army in enforcing lockdowns will inevitably undermine its dual role as a source for trusted healthcare messages. This may also resonate poorly with migrants from countries where authoritarian governments use the military and police to control and intimidate communities.78 NSW does not have a Human Rights Act, and this example illustrates why a human rights approach is needed to ensure that individuals and communities can trust that government decisions are made and applied fairly. A human rights-based approach would have required the government and the police to transparently justify why stricter measures were being utilised in certain areas, and how human rights affects would be mitigated. Stricter measures in Western Sydney may well have been justified from a public health perspective in accordance with human rights principles – but it would have been necessary for government and police to show that the chosen response was proportionate and appropriately tailored to the public health risk; and to change tack if unnecessary or potentially discriminatory outcomes occurred. A human rights-based approach would also have required a recognition of cultural differences in the affected communities, and pointed to a need to directly engage with those communities, beyond an enforcement-focused approach. The absence of this human rights-based process may have led to suspicion of government decisions that were ultimately intended to be in the public good, with potential negative implications for police legitimacy and social cohesion in Western Sydney.