Later Life
Samuels remained active after his governorship, inquiring into activities of the Australian Secret Intelligence Organisation and allegations that "loose talk" by diplomatic staff had led to the exposure of agent Warren Reed. In 2002, Samuels attacked Prime Minister John Howard's response to Senator Bill Heffernan's "vicious attack" on Justice Michael Kirby, using a false document as evidence: "It is incredible that the Prime Minister, if he was indeed opposed to Heffernan's intention, did not ask for the evidence upon which the senator relied. What was in contemplation was an attack of the gravest kind upon the fitness of a High Court judge. Would not the Prime Minister have asked his friend of whom he speaks in affectionate terms to show him the material which justified so serious a course?"
Samuels also resumed his activities in the Law Reform Commission, serving as a Part-time commissioner from 2001 to 2007. He died of a cancer-related illness on 10 December 2007, survived by his wife and two daughters, Deborah and Selina Samuels. Samuels requested not to be given a state funeral.
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