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It strikes me that this article should be renamed to “Warrigal Creek Massacre”, as the creek is otherwise not noteworthy and would not merit a Wikipedia article.
Support. It seems like a reasonable idea to me, although WP:NCE is not entirely clear on this. It gives one example (Babi Yar) where only the place is used as the name of the article. I think it's a judgement call – but looking at the others in the List of massacres of Indigenous Australians article, most seem to have "massacre" appended, and it would be in sync with. e.g. Waterloo Plains massacre and others in the Australian context. Laterthanyouthink (talk) 03:26, 9 February 2021 (UTC)[reply]
Oops, I forgot to mention, "massacre" should begin with a small letter... Might only be possible via a request on the Technical moves page - but give it a whirl and see, Ollee? Or perhaps you can undo the move and do it again? Laterthanyouthink (talk) 06:35, 9 February 2021 (UTC)[reply]