The Gama Foundation v Controller and Auditor-General of New Zealand - [2024] 3 NZLR 767

Judicial review — Parliamentary privilege — COVID-19 wage subsidy scheme — Auditor-General’s reports and recommendations on management of scheme — Recommendations to executive government and House of Representatives — Whether parliamentary privilege attaching to reports and recommendations — Whether recommendations by public bodies capable of review — History of parliamentary privilege — Auditor-General’s duty of independence — Audit standards — Whether recommendations unlawful as failing to comply with statutory duty of independence — Whether Auditor-General acting unreasonably — Failing to recommend Ministry write to all wage subsidy payment recipients — Whether unreasonable delay — Public Audit Act 2001 ss 9, 16 and 20.

Parliament — Auditor-General — Parliamentary privilege — Whether Auditor-General’s recommendations to parliament subject to privilege — History of parliamentary privilege — Auditor-General’s duty of independence — Audit standards — Public Audit Act 2001 ss 9, 16 and 20.