Yarmirr v Northern Territory was an Australian court case, decided in 2001.

The application was made by Mary Yarmirr and others on behalf of a number of different clan groups of Aboriginal people to an area of seas and sea-beds surrounding Croker Island in the Northern Territory of Australia.

[1][2] The case established that traditional owners do have native title of the sea and sea-bed; however, common law rights of fishing and navigation mean that only non-exclusive native title can exist over the sea.

[1] The case aimed to determine, under Territorial application of the Native Title Act 1993 (Cth):[1] The trial judge, Olney J, determined members of the Croker Island community have a non-exclusive native title right to have free access to the sea and sea-bed of the claimed area for all or any of the following purposes:[1] The claimed area was defined by maps attached to the application for determination.

The determination was thus amended so as to be restricted to and apply to the internal waters of the Northern Territory, including the inter-tidal zone both of the mainland and of the islands within the claimed area.