Zealand passport, to hold themselves out to the world as a New Zealander, and to access State protection while overseas.86 Once granted, New Zealand citizenship is extremely difficult to revoke.87 Section 8 of the Citizenship Act (relating to citizenship by grant) sets out in detail New Zealand’s legislative policy as to the circumstances in which an individual who is not born into the status of New Zealand citizen has a sufficiently strong connection to New Zealand for that relationship to arise. One would certainly expect any exception to that policy to be construed narrowly; all the more so as New Zealand’s immigration law and policy contains a number of different avenues to provide humanitarian relief. These include rights to appeal the making of a deportation order on humanitarian grounds to an independent tribunal,88 mechanisms to recognise and protect refugees and “protected persons” (the latter being those to whom New Zealand owes an obligation of non-refoulement under the ICCPR or the United Nations Convention Against Torture),89 and a range of special residence categories in New Zealand immigration policy designed to address particular humanitarian concerns.90 In the ordinary run of cases, it is to these various mechanisms that we would expect a prospective migrant to look for humanitarian relief. In addition to these contextual factors, two aspects of s 9(1)(c) itself distinguish it from the various immigration analogues, and suggest that the threshold for an exercise of power under s 9(1)(c) is high. The first is that s 9(1)(c) requires the Minister to be satisfied that the grant of citizenship would be positively in the public interest; it is not enough (as in the immigration context) to rule out any threats to the public interest. This, as I have already suggested, invites a stringent inquiry.91 The second is that the s 9(1)(c) power is reposed in the Minister and has not been entrusted to an independent tribunal, suggesting that it is regarded as implicating the public interest in its broadest sense. These statutory and contextual indicators all support the conclusion that the threshold for intervention under s 9(1)(c) is a high one and that the courts (if a case were ever to be presented to them) would be slow to interfere in an exercise of power under it. But these considerations cannot justify the Department’s (previous) narrow approach to “pubic interest”. The problem with that approach was not that it imposed a high threshold for intervention under s 9(1)(c) but that it ruled out, categorically, an entire class of qualifying circumstances. Cases grounded in humanitarian predicament effectively missed out on consideration, no matter how exceptional the circumstances or how strong the public interest. The Department’s new approach to public interest thus opens the way for consideration, on the merits, of a neglected class of applications. But there is no reason why it need disrupt the high threshold for intervention inherent in s 9(1)(c). In order to expand on that proposition, I now turn to consider in more detail the significance (and the limits of the significance) of the new approach. 7. Significance of the new approach for prospective applicants It is important not to overstate what the new approach will mean, in practice, for prospective applicants. There are at least three reasons why we should expect that grants of citizenship under s 9(1)(c) – certainly in humanitarian cases – will continue to be rare. 86 Tennent, above 41, at [3.1.2]. For the limited circumstances in which New Zealand citizenship can be deprived, see Citizenship Act 1977, ss 16–17. 88 Immigration Act 2009, ss 154–162. 89 Immigration Act 2009, ss 129–131. 90 Immigration New Zealand, above n 34. In addition to eligibility for residence based on a range of family relationships (F), the operational manual currently recognise special residence classes for victims of people trafficking (S4.15), family reunification of refugees (S4.20), and victims of domestic violence (S4.5). 91 Above n 48 and associated text. 87 18 Electronic copy available at: https://ssrn.com/abstract=3094731