being granted to persons of good character. More generally, we might characterise this as a public interest in preventing the abuse or misuse of the privilege of New Zealand citizenship. We thus can expect that factors of this kind will often be weighty considerations (always depending on the precise circumstances of the case). And there may, of course, be other matters of public interest that are not directly reflected in the statutory criteria. The question of what skills and assets the applicant brings with them to New Zealand will naturally be relevant (although not determinative). And there may be unique questions of public interest arising from the circumstances of the particular case. For example, in Roland Kun’s case, a public interest that was clearly at stake concerned New Zealand’s international reputation and standing, and its relationship with other sovereign nations.99 Whether this public interest would be advanced or hindered by a grant of citizenship to Mr Kun was a question for the Minister (as the guardian of the public interest) to decide.100 In short, in deciding whether a grant of citizenship would be in the public interest, it is for the Minister to determine the extent to which each of these various dimensions of the public interest are implicated in the particular case, to weigh them in the balance, and to decide where New Zealand’s overall public interest lies. To repeat, the fact that an applicant’s exceptional humanitarian circumstances give rise to a public interest in averting human suffering is, or ought to be, no more than a starting point. Thus, to use the example of Mr Kun’s case, the documentation put to the Minister on Mr Kun’s behalf detailed at length (and on the basis of numerous supporting references) matters such as: - The impact of the separation on the family unit; The strong connections the family (including Mr Kun) had made with their local community over a short space of time; Various demonstrations of their commitment to settling in New Zealand over the longer term; Mr Kun’s and Dr Le Roy’s outstanding reputations for character and integrity; and The significant contribution both Mr Kun and Dr Le Roy could be expected to make to New Zealand society. The Minister was entitled to take into account all these factors, and not just the humanitarian circumstances, in deciding that a grant of citizenship would be in the public interest. The third and final reason why grants of citizenship under s 9(1)(c) are likely to remain rare is that, for the s 9(1)(c) power to be triggered, it must be, specifically, a grant of citizenship that is in the public interest. This certainly does not amount to a hard and fast requirement that an applicant must have no other option available to them. But it does leave it open to the Minister to refuse to grant citizenship under s 9(1)(c) if the public interest can be satisfied by some other means. As we have seen, New Zealand’s immigration law and policy contain a number of mechanisms to provide humanitarian relief.101 In the ordinary run of cases, it is to these various mechanisms that we would expect a prospective migrant to look; not to a grant of citizenship. If we can, again, draw on the example of the Kun case, it was the somewhat unusual fact that Mr Kun was trapped outside of New 99 See Prasad v Chief Executive of the Department of Labour [2000] NZAR 11 (HC) at 22 (making the analogous suggestion that the public interest would encompass “repercussions such as trade embargoes”). 100 We can assume from the fact that citizenship was granted that the Minister ultimately accepted the submission of Mr Kun’s counsel that New Zealand’s international standing was enhanced, rather than undermined, by New Zealand’s intervention on Mr Kun’s behalf. 101 Above nn 88–90 and associated text. 20 Electronic copy available at: https://ssrn.com/abstract=3094731