Abstract: This paper assesses what real gains were made, through the Wotjobaluk Native Title Consent Agreement, 2005, in the context of Indigenous land justice in 21st Century Victoria. It analyses the relationship between the Merkel J. Federal Court determination in the Wotjobaluk case, and the Yorta Yorta Native Title claim (1994-2002), and argues that the Wotjobaluk case may well be another act of dispossession, this time through the native title process.