Abstract
The following article is based on a speech delivered by Justice Powell on 3 May 2023 on the challenges of applying the Marine and Coastal Area (Takutai Moana) Act 2011. Justice Powell discusses the background and history of the current legislation. He then considers the challenges of applying tikanga under the statutory tests for customary marine title and protected customary rights.
 Keywords: tikanga; customary rights; High Court of New Zealand.
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