It's just my recollection was that animals had to be caged, not that a permit was needed. I haven't looked at that reg for years and haven't needed to, my flashbacks to turtles, goannas and baby crocs in the back of the aircraft are from a long while ago....
Furthermore what if the animal is a half dead? i.e. Arnhem Land turtle with flippers tied with fencing wire as carry on baggage?