legislative amendment or judicial decision.10 New administrative interpretations can sometimes be slow to feed through into publicly available policy documentation. Even once they do, policy guidelines do not adhere to the same conventions of reason-giving as judicial decisions, and the true significance of the change that has occurred may well not be obvious on the face of the documentation. In the case in point, the Department of Internal Affairs’ revised interpretation of s 9(1)(c) was only finally reflected in a publicly promulgated policy document some 14 months after Mr Kun’s case was determined (and just as this article was being finalised).11 And while that new policy document clearly signals a change of approach, its relevance to the resolution of humanitarian predicaments such as Mr Kun’s is perhaps not completely evident from the face of the document.12 The purpose of this article is thus to record, and to analyse, an important shift in official interpretations of the law of New Zealand regarding citizenship in exceptional circumstances. In the course of doing so, the article reflects on the reasons that, in my view, justified (indeed required) the relevant change, and on its potential significance – as well as the limits of its significance – for future applicants. The article is in seven substantive parts, followed by a brief conclusion. Part 1 provides a short summary of the background to Roland Kun’s citizenship application. Part 2 examines s 8 of the Citizenship Act, which contains the standard criteria for a grant of New Zealand citizenship. These standard criteria are an important part of the legislative context in which s 9(1)(c) of the Act (provision for the grant of citizenship in exceptional circumstances) must be understood. In Part 3, I turn to consider the application of s 9(1)(c) itself, and its implications for Mr Kun’s case. I explore a tension inherent in the two key legislative concepts deployed in s 9(1)(c) – “exceptional circumstances of a humanitarian or other nature” and “public interest” – and suggest that this tension is particularly acute in cases such as Mr Kun’s that rely primarily on humanitarian circumstances to ground the application. At the conclusion of this Part, I pose a legal conundrum: when, if ever, can humanitarian circumstances relating to a particular applicant give rise to a positive public interest in the grant of citizenship? Parts 4 and 5 identify two potential answers to that question. The first (discussed in Part 4) reflects the settled view of the Department of Internal Affairs prior to the determination of Mr Kun’s case: that a public interest requires a positive benefit or advantage to New Zealand. This narrow conception of public interest is extremely unreceptive to applications grounded in humanitarian circumstances. It is therefore not surprising that, on the basis of this view, the Department proposed initially to recommend against a grant of citizenship to Mr Kun. The legal significance of Mr Kun’s case lies in the fact that, in the course of finalising its advice to the Minister on Mr Kun’s application, the Department of Internal Affairs revised its approach. Its new approach (which is discussed in Part 5) is derived from a recent Supreme Court decision on the meaning of public interest in the immigration context: Helu v Immigration and 10 See generally Harlow and Rawlings, above n 5, at 192–196; Lorne Sossin “How Judicial Decisions Influence Bureaucracy in Canada” in Marc Hertogh and Simon Halliday (eds) Judicial Review and Bureaucratic Impact: International and Interdisciplinary Perspectives (Cambridge University Press, Cambridge, 2004) 129 at 140. To be clear, the opposite can sometimes also be true: that “soft law” interpretations may be more transparent and accessible. 11 “New Zealand Citizenship – Operational Policy” (August 2017) The Department of Internal Affairs <www.dia.govt.nz>. 12 For further discussion, see below n 73 and associated text. 3 Electroniccopy copy available available at: Electronic at: https://ssrn.com/abstract=3094731 https://ssrn.com/abstract=3094731