He received not-guilty verdicts by reason of insanity for both incidents
In a case where the applicant was twice found not guilty by reason of insanity for killing two people as a result of schizophrenic delusions, New Zealand’s Supreme Court removed the impediments against publishing his and his second victim’s names.
A “doctor” who had probably forged her qualifications released the applicant in Parr v R [2026] NZSC 16, who was supposed to be a compulsory inpatient for six months, only nine days after his admission into care.
In 1997, around a year after his release, the applicant killed his then-partner. After his trial, he became a special patient. A coronial inquiry criticised how the mental health system dealt with his case.
By 2012, the applicant’s health had improved. Though still a special patient, he could receive treatment and supervision while living in the community. In 2021, pursuant to a status change, he became a patient subject to a community treatment order.
Following the applicant’s readmission after an altercation with a whānau member, a mental health facility released him on 30 May 2024. He then killed his mother on 4 June 2024.
The applicant applied to suppress his and his mother’s names. The High Court denied his application, while the Court of Appeal dismissed his appeal of the High Court decision.
The appeal court accepted that tikanga might assist in determining whether an applicant or a victim has established the necessary hardship in the event the court declined name suppression.
However, the appeal court found that the hardship in this case did not outweigh the strong public interest in open justice, even if assessing the hardship of the applicant’s whānau through the tikanga lens.
The appeal court then addressed suppression of the mother’s name as a victim under s 202(1)(b) of the Criminal Procedure Act 2011. The appeal court saw a strong public interest in informing the public regarding:
The applicant sought leave to appeal. The applicant asserted the relevance of tikanga, as the first law of Aotearoa New Zealand, in determining:
The applicant stressed the need for suppression to prevent wide‑scale reporting of his and his mother’s names and identifying details.
The applicant alleged that widespread publicity would go against tikanga principles due to the lack of relationality. According to him, the media’s publication of intergenerationally harmful information and permanent searchable storage would not align with tikanga.
The Supreme Court of New Zealand dismissed the application for leave to appeal because the case did not meet the criteria for leave to appeal. The Supreme Court did not find it necessary in the interests of justice to hear and determine the proposed appeal.
To enable the whānau to know about this decision, the Supreme Court lifted the prohibition on identifying the applicant and his second victim after 2 pm on 16 March 2026.
The Supreme Court acknowledged the public interest and the need for public protection. Accepting that tikanga affected the interests of justice, the Supreme Court saw a question of general or public importance in how tikanga principles impacted the public interest in this case.
However, the Supreme Court did not consider this case an appropriate vehicle to answer the question for two reasons.
First, the Supreme Court noted that the evidence was neither extensive nor tested because the applicant did not raise tikanga’s impact until the appeal. Second, the Supreme Court saw no apparent miscarriage of justice and no sufficient prospects of success in the proposed appeal.
