November 14, 2025
When whakapapa does not mean Citizenship
New Zealand actress Keisha Castle-Hughes-best known internationally for her breakout role in Whale Rider-has become a prominent advocate in a deeply personal and broader-systemic citizenship debate in Aotearoa. Born in Australia to a Māori mother, she holds New Zealand citizenship by descent. Her recent struggle to secure NZ citizenship for her U.S.-born daughter has exposed issues in the country’s citizenship law, especially as they affect Māori born overseas.
Castle-Hughes holds New Zealand citizenship by descent due to her Māori mother and her upbringing in NZ. In 2021 her daughter was born in the United States. When she applied for a New Zealand passport/citizenship on her daughter’s behalf, officials denied that the child had an automatic claim. The reason given: Castle-Hughes herself was a citizen by descent, not by birth in New Zealand.
Castle-Hughes described the subsequent process as “arduous”, “invasive” and “at times incredibly racist”, pointing out how she was asked to supply detailed documentation about her marae involvement, iwi affiliation, time spent participating in Māori cultural practices etc. Eventually, her daughter’s citizenship was granted; but only after intervention from government ministers and political actors. Castle-Hughes emphasises that while this individual outcome is positive, it doesn’t resolve the structural issue she highlights.
Castle-Hughes’ experience is part of a larger inquiry. The Waitangi Tribunal has recently examined whether the current citizenship regime under the Citizenship Act 1977 aligns with the principles of the Treaty of Waitangi, particularly for Māori born overseas. Key findings from the Tribunal include:
- The Act limits “citizenship by descent” to one generation. That means if a parent is a New Zealand citizen by descent (rather than by birth or grant), their child born overseas does not automatically get citizenship by descent.
- The Act makes no express acknowledgement of Māori as tangata whenua (people of the land) or of the Treaty.
- The Tribunal concluded that the Crown has breached Treaty-principles (such as partnership, active protection, rangatiratanga, good government, equal treatment, and options) in the way the citizenship regime is currently structured.
The Tribunal recommended:
- Amend the Act to recognise Māori status as tangata whenua and to give effect to the Treaty of Waitangi.
- Establish a “tikanga pathway” to citizenship for Māori born overseas, where hapū and iwi can assess whakapapa-evidence.
- Extend citizenship by descent to two generations for Māori (i.e., children of citizens by descent born overseas should automatically have it).
Castle-Hughes has used her platform to articulate the emotional, cultural and bureaucratic impact of these laws on Māori families overseas. Her key observations include: The demand for documentation about “participation in Māori culture” (e.g., marae time, kapa haka) doesn’t align with how Māori identity and belonging are understood within Māori communities. “We don’t have binary systems that quantify what being Māori is,” she said. Even though her daughter ultimately got citizenship, she emphasises: “The grant of citizenship for our daughter does not resolve our issues… she is in the exact same boat unless she has her future tamariki in Aotearoa.”
The New Zealand government has so far rejected creating a whakapapa-based automatic citizenship pathway specifically for Māori, with the minister saying the rules should apply equally to everyone. Criticism has come from various quarters: supporters of reform argue the law is outdated and fails to reflect modern Māori realities; opponents argue that extending citizenship rights based on ancestry could lead to two standards of citizenship.
The case is significant for several reasons: Identity & belonging: For Māori born overseas or whose children are born overseas, the inability to automatically gain NZ citizenship can feel like exclusion from the tribal, cultural and national connection to Aotearoa. Legal & constitutional: It raises questions about how New Zealand’s citizenship laws interact with the Treaty of Waitangi, and whether an Act from 1977 adequately reflects 21st-century realities of Māori diaspora and global mobility.
Practical consequences: Without citizenship, children may face barriers in accessing certain rights/residency/permanent status, despite strong whakapapa and cultural connection. Precedent for other Indigenous rights regimes: The discussions may influence how other countries treat Indigenous diaspora, dual generation descent, and citizenship connected to ancestral land/tūrangawaewae.





