Opposition spokesperson for Indigenous Australians, Jacinta Nampijinpa Price, has criticised the Labor government for voting against a motion to establish an inquiry into Native Title bodies, calling Prime Anthony Albanese "two-faced".

The Senator's comments come as the Native Title Council urged Senators to reject calls for the establishment of a Select Committee on First Nations Representative Bodies, arguing it would cause "further politicisation and division".

The motion was introduced by Arrernte woman and Liberal Senator, Kerrynne Liddle, on behalf of herself, along with Senator's Lidia Thorpe and Jacqui Lambie.

Senator Price, who has been vocal in her criticism of some land councils - regularly calling for an audit - was critical of the inquiry being voted down on Tuesday, with Labor teaming up with Australian Greens and Independent senators Fatima Payman, David Pocock and Tammy Tyrrell to defeat the motion.

Senator Price argued that "we know that these bodies are not functioning the way they could be, and the Albanese government is shutting down any attempt to get them back on course".

"The Albanese government's suggestion that this would simply be a duplication of the existing Law Reform Commission Review into Native Title is ill-conceived," the Warlpiri/Celtic Senator said.

Senator Price argued the inquiry would "examine the statutory bodies that have been given responsibility for the management of land and funding," which is not under the remit of the ongoing review being undertaken by the Australian Law Reform Commission.

"By voting against this motion, Anthony Albanese and his government are refusing to listen to the widespread frustration and desperation of Indigenous Australians who are living with the realities of a painfully broken native title system," Senator Price said.

Last month, the Human Rights Commission said First Nations women have been let down by the Native Title system, with a new report calling for significant reform.

However, it is not clear if these reforms would form part of the inquiry called for by the Coalition.

During his speech at Garma, Prime Minister Anthony Albanese championed economic independence of First Nations people, but Senator Price said this pledge was meaningless when he "won't support a motion that would give them the best chance of that happening".

"His opposition to this motion should be proof to all Australians that this is a Prime Minister and a government that is so obviously two-faced and cannot be trusted," she said.

On Tuesday afternoon, the National Native Title Council (NNTC) rejected the calls for an inquiry, with chair Kado Muir saying in the wake of the Voice referendum defeat, "it's upsetting that some politicians would continue to use Aboriginal and Torres Strait Islander communities as a political football".

"[I]t is a sad day when native title holders who have spent decades fighting for their rights get dragged into politics for no good reason," Mr Muir said.

NNTC chief executive, Jamie Lowe, stated: "Allies of First Nations Australians in the Senate will do our people no favours by indulging in further politicisation and division."

"Calls for yet another review of Native Title corporations are nothing more than a distraction from the real issues and practical solutions — the chronic lack of sustainable funding," the Gundjitmara Djabwurrung man said.

NNTC said Prescribed Bodies Corporate's (PBCs) operate on a median income of less than $7,000 per year, resulting in a struggle in meeting basic corporate functions and relying on regional bodies - such as Land Councils - to provide critical support to achieve strong governance.

"Instead of wasting resources on another costly review, the focus should be on providing the support needed for PBCs to continue their essential work," Mr Lowe said.

During his speech at Garma, the Prime Minister said many of the more than 270 Native Title bodies don't have the "resources to engage in commercial negotiations".

He argued that "some of the changes we need to make are not political, they are practical".

Mr Lowe stated: "PBCs need adequate and ongoing support to create intergenerational wealth and other opportunities. Without that, our communities cannot close the gap."

"Instead of rushing into yet another costly review, the NNTC calls on Senators to instead take practical steps to fund PBCs so they can create a better future for their communities," he said.