In New Zealand there is a way for citizens to kickstart a referendum themselves and it may complicate the already charged debate over Indigenous rights in the country.
Like in Australia, the government can decide to put an idea or policy to the country via a referendum.
But across the ditch, any New Zealander can bring any issue to parliament and petition for what's called a citizens-initiated referendum.
New Zealand regularly performs among the best in the world on global report cards for political and civil liberties.
And in the early 1990s it joined countries such as Switzerland and Italy by passing legislation to allow this type of national, citizen-led vote.
At the moment, New Zealand is currently debating the future of its founding document, The Treaty of Waitangi.
The treaty has been used to inform policies on Maori rights and recognition, and over the course of 50 years a set of treaty principles has been developed to guide that process.
Minor party leader and cabinet minister David Seymour has tabled a bill that would rewrite the principles, set them out in legislation and then put the act itself to a referendum.
The Treaty Principles Bill was something Mr Seymour won in coalition negotiations a year ago when the new centre-right government was formed.
Recently, Prime Minister Christopher Luxon admitted race relations in New Zealand were now "probably worse" than when he came to power.
"I think there's more division," he said.
"It's a challenging time at the moment … there's strong feeling on all sides of that debate."
Mr Seymour and supporters of the Treaty Principles Bill argue all New Zealanders should have the same rights and privileges and everyone deserves to have a say on the role the Treaty of Waitangi plays in the nation's future.
The bill's critics argue there is a danger in putting the rights of a minority in the hands of the majority.
Mr Luxon has only promised to support the bill until it reaches its second reading, where it will very likely be voted down and killed, but there are multiple paths to a referendum in New Zealand.
A referendum brought by the government would be binding; a citizens-led referendum would not be, but political and legal experts say the politics of a Yes result would make things very complicated either way.
What is a citizen's initiated referendum?
Direct democracy initiatives such as citizens-led referenda and citizens assemblies are ways for ordinary people to ask parliament and the nation to consider an issue.
Switzerland is seen as having a very robust direct democracy, with the nation voting three times on government powers during the COVID-19 pandemic.
"Citizen-led initiatives allow people to be empowered," Nyla Grace Prieto from democracy research centre International IDEA said.
"It gives them a more active role in decision-making. It allows them to put forward and vote directly on issues and policies that are important to them."
Since 1993, New Zealanders have been able to force the government to fund a national vote on a particular question.
But as well as the catch that the result will not be binding, there are a few hurdles to clear before a citizens-initiated referendum can get off the ground at all.
The first step is pretty easy. New Zealanders apply to the clerk of parliament, pay a fee and have their referendum question considered.
It takes about three months for the final wording to be decided on and then the organiser has 12 months to gather enough signatures to force the vote.
A citizens-initiated referendum petition must attract signatures of at least 10 per cent of the voting public, which at the moment in New Zealand is about 360,000 people.
Organisers cannot rely on electronic signatures. Hitting the 10 per cent threshold requires pounding the pavement to secure signatures on a piece of paper that will then be delivered to parliament and verified as individual voters.
There have been five citizen-initiated referendums so far in New Zealand, including one that was dubbed the "anti-smacking" referendum.
After then-prime minister Helen Clark's government made corporal punishment a crime, citizens rallied, forced a referendum and were asked: "Should a smack as part of good parental correction be a criminal offence in New Zealand?"
Of the 1.6 million people who turned out for the referendum, 87.4 per cent voted No, but it did not change the government's position and in the Crime Act of today, nothing justifies a parent's "use of force for the purposes of correction".
Waikato University professor of law Alexander Gillespie said while the result of a non-binding citizens-led referendum did not have to be considered by government, "it's a bad look in a democracy" when the result was ignored.
"If they are avoided, it can create large-scale political problems for the parties that act against them," he said.
"And so the way I see it, sometimes it's not even about the topic of the referendum or the merits of the debate, it's about the larger political games that are going on."
There are currently two petitions for a citizens-initiated referendum open in New Zealand; one is about banning the sale of fireworks, the other is about the country's relationship with the World Health Organization.
Collecting more than 300,000 signatures in support of an obscure issue is not easy, but of course some issues that lead to a referendum are more mainstream.
"A lot of people who have a particular campaigning concern or issue … will start the process and realise that getting 10 per cent of the voting public to sign a petition is no mean feat and will fall short quite substantially," said New Zealand-based barrister and constitutional law expert Graeme Edgeler.
"But for something as big and high profile as the treaty principles process and the treaty principles legislation, I could imagine this would be something where there would be a campaigning organisation which might be able to make a good go at getting the large, large numbers of voters to sign their petition.
"It's certainly something that a lot of members of the public are aware exists."
New Zealand has many more referendums than Australia, but Dr Gillespie warns there are some risks.
"Always, referendums are to be welcomed because democracy is a wonderful thing, but you need to be cautious because in a country like New Zealand … we don't have a written constitution like you guys have, and we don't have a second chamber like a senate," he said.
"And so our legislation is made just by parliament in a one-stop shop and it's fast. Everything … can just happen with such speed.
"Things that should be fundamental could be changed quickly. It's one thing to have a referendum on [the legalisation] of cannabis, on a different design of the flag, it's a different thing to have a referendum on the rights of the minority."
Those who want a referendum
Former National Party opposition leader and now lobbyist Don Brash has previously pushed for a referendum on the treaty principles.
He said if Mr Luxon did not allow one, his group Hobson's Pledge would "work with similar groups to demand a citizens-initiated referendum".
"Well, it's certainly in our mind, there's no doubt about that," told the ABC.
"We haven't made any decision on this."
Brash said it depended on whether the political advantage would be affected.
"I've said that I'd be up for helping to organise such a referendum if [the Treaty Principles Bill] is killed at the second reading, but it depends a bit on what Seymour does," he said.
"Because if he says, 'Look, this is what I go into the next election on and I will have a referendum on it the following month. It may not be appropriate."
Mr Seymour has said he wants New Zealanders to go to a referendum on the Treaty Principles Bill that is binding, and he will not organise a citizens-initiated referendum himself.
Asked about it by the ABC's Pacific Beat program last month, he said: "I've ruled that out. Others may do that, but I don't think that's practical."
"The problem is they are not actually binding, so generally they get people's hopes up and then they disappoint people so no, I don't favour that approach."
New Zealand's national government terms are three years, so the next election is due in 2026.
Also part of the coalition agreement was that Mr Seymour would take over as deputy prime minister halfway through the term. That kicks in mid-2025.
His Treaty Principles Bill is open for written submissions for another month, with the select committee process expected to take about six months.
"That select committee will probably recommend that the bill not pass, but it will also say if you were to take this bill forward, here are some changes we would make to it," Mr Edgeler said.
"At that point, there will probably be an updated version of the bill.
"The treaty principles that might be rewritten from that bill could be used as part of the question that someone might decide to put to a petition process."
New Zealand will still be in the midst of this debate when Waitangi Day — the national day marking the signing of the treaty — happens on February 6.
This year's Waitangi Day saw huge crowds and a hikoi, or march, to the hallowed Waitangi Grounds, where those gathered demanded the treaty be honoured.
When the Treaty Principles Bill was tabled in parliament, young Maori Party MP Hana-Rawhiti Maipi Clarke made global headlines by tearing the legislation up and starting a haka inside the chamber.
Another hikoi protesting against the legislation arrived in Wellington just days later, with police estimating more than 42,000 people took part.
Polling on the issue of the Treaty Principles Bill and the government itself has been shifting.
Numbers out this week showed approval for Mr Luxon and Mr Seymour has fallen since they came to power a year ago. However, a different survey taken in early October found support for the bill was sitting at 46 per cent nationwide.
Dr Gillespie said it was "quite possible" New Zealand would eventually have a national vote of some kind on the issue.
"Mr Seymour realises that he's got a topic which is, although very divisive, one which will be very popular for the section of the populous that he appeals to and so he will continue to pursue it … or it will come from people like Mr Brash or other interested citizens," he said.
"I think it'll be a citizens-initiated referendum or else it will be part of a coalition deal. When there's the next election, they would say, 'We will give you our support if we get this referendum,' and that's quite possible."
