Abstract
This article evaluates the legal history of the dealings between various New Zealand governments and the owners of the SILNA forests (indigenous forests on land originally granted to Southern Maori under the South Island Landless Natives Act 1906). Recent decisions to apply the Resource Management Act's land-use controls to SILNA land, in conjunction with the government's current approach to the SILNA land owners are open to criticism. The problems with this approach have less to do with the conservation of the forests, and everything to do with the government's duties to the landowners under the Treaty of Waitangi