Abstract
Two main approaches have been used to manage the relationship between state laws of different countries: harmonisation; and the conflict of laws. The article maps these approaches onto the existing jurisprudence on the relationship between state law and tikanga, while bearing in mind the unique constitutional parameters of this relationship and the status of tikanga as the first law of Aotearoa New Zealand. The article concludes that there are parallels between the application of tikanga “as values” and harmonisation, and between the application of tikanga “as law” and the conflict of laws. It shows that there is a need to grapple with the choice between two functions: the harmonisation of state law to move state law closer to tikanga, and the application of an unadulterated tikanga to preserve material differences between state law and tikanga.