The common law rejects ‘Aboriginal sovereignty’ as being inconsistent with Crown sovereignty. Yet the common law defines ‘Aboriginal sovereignty’ as a single, homogenous sovereignty adverse to the Crown. The position at common law differs from the literature by First Australians which maintains that their sovereignties are a spiritual notion, have not been ceded, and are heterogeneous. In the same way that the Uluru Statement from the Heart conceives of its authors’ sovereignty as ‘shining through’ legal and political institutions, this article contends that the recognition of additional rights at common law would be an implicit recognition of sovereignty. This article puts forward three interconnected and alternate sources for such rights: as additional land-related rights as presupposed by native title, via the ‘preferable rule’ in Mabo, or via the connection to land as identified in Love.