Boyce has claimed that the April 1828 "Proclamation Separating the Aborigines from the White Inhabitants" sanctioned force against Aboriginal people "for no other reason than that they were Aboriginal" and described the decision to remove all Aboriginal Tasmanians after 1832—by which time they had given up their fight against white colonists—as an extreme policy position. He concluded: "The colonial government from 1832 to 1838 ethnically cleansed the western half of Van Diemen's Land and then callously left the exiled people to their fate."[78] As early as 1852 John West's History of Tasmania portrayed the obliteration of Tasmania's Aboriginal people as an example of "systematic massacre"[79] and in the 1979 High Court case of Coe v Commonwealth of Australia, judge Lionel Murphy observed that Aboriginal people did not give up their land peacefully and that they were killed or forcibly removed from their land "in what amounted to attempted (and in Tasmania almost complete) genocide".[80]