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 .
 None
Given options, please tell me the categories of all the listed entity words.Output format is "type1: word1; type2: word2". 
Option: location, person, organization 
Text: {0} 
 Entities:  
Answer:
 None