Abstract
The Crown has no property interest in customary land and is not the source of title to it. (Ngati Apa v Attorney-General [2003] 3 NZLR 643 at [47], per Elias CJ.)
… the king is the universal lord and original proprietor of all the lands in his kingdom; and no man doth or can possess any part of it, but what has mediately or immediately been derived as a gift from him … (William Blackstone1)
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