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On 28 July 1982, following a stiff tightening of Pacific Island immigration by the Muldoon government, in its interpretation of the 1923 and 1928 British Nationality and Status of Aliens Acts, the Privy Council ruled that all Samoans born between 1924 and 1948, and their children, were British subjects and hence, on 1 January 1949, had become New Zealand citizens.

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