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Privy Council rules on Samoan citizenship

19 July 1982

Protesting against the Citizenship
Protesting against the Citizenship (Western Samoa) Act 1982 (Alexander Turnbull Library, PADL-000081)

When the Privy Council granted New Zealand citizenship to Western Samoans born since 1924, the government did not accept this decision. It rushed through an act granting New Zealand citizenship only to Western Samoans who were living in New Zealand on 14 September 1982 or subsequently obtained permanent residence.

After Western Samoa achieved independence in 1962, the status of Samoans living in New Zealand was uncertain. In a case taken to the Privy Council, Falema'i Lesa, a Samoan woman living in New Zealand, pressed her claim to be a New Zealand citizen. The Privy Council ruled that all Western Samoans born between 1924 and 1948 were British subjects and that in 1949 they and their descendants had become New Zealand citizens.

Many Samoans felt betrayed by the New Zealand government’s response. The 1982 act remains a concern for Samoans in New Zealand who desire freedom of movement between the two countries. In March 2003, a petition with 90,000 signatures calling for the law’s repeal was presented to Parliament. Outside, about 2000 Samoans protested with speeches, dancing and singing.

How to cite this page

Privy Council rules on Samoan citizenship, URL:, (Manatū Taonga — Ministry for Culture and Heritage), updated