264696
Before and after the Engineers ' case Prior to 1920 , the High Court of Australia tended to employ the US jurisprudence governing intergovernmental immunity , expressing it as an implied immunity of instrumentalities , where neither the Commonwealth nor State governments could be affected by the laws of the other .
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Please list all entity words in the text that fit the category. Output format is "word1, word2". 
Option: location, person, organization 
Text: {0} 
Answer:
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