
133 Molesworth Street
PO Box 5013
Wellington 6140
New Zealand
T+64 4 496 2000
2 October 2025
Nadine Connock
By email: [FYI request #32351 email]
Ref:
H2025073095
Tēnā koe Nadine
Response to your request for official information
Thank you for your request under the Official Information Act 1982 (the Act) transferred to the
Ministry of Health – Manatū Hauora (the Ministry) on 23 September 2025. You requested:
“In a document dated 19 May 2021, legal advice LPA 01 01 24, addressed to Hon David
Parker Attorney-General, your Ministry stated the following:
6. Several medicines have been approved under section 23 including the Pfizer COVID-19
vaccine. An issue has risen as to whether these consents have been validly issued.
Please provide an explanation as to what this issue was, and why it was believed
consents were not validly issued.
7. The Bil amends the Principal Act to:
a) remove the requirement that provisional consent under section 23 be on a restricted
basis for the treatment of a limited number of persons; and
b) retrospectively validate certain existing provisional consents that have been granted
under section 23 of the Medicines Act; including consent for the Pfizer vaccine.
Please provide the legal counsel that confirmed the requirement for these amendments
and the reasons why they were recommended.”
Please refer to the following court decision from May 2021 which sets out the background and
provides the rationale for the amendment(s):
www.justice.govt.nz/jdo_documents/workspace___SpacesStore_8636ad33_e799_4df7_a0dd_6
47ca8ff7814.pdf.
Therefore, section 18(d) of the Act applies to your request, that the information is publicly
available.
I trust this information fulfils your request. If you wish to discuss any aspect of your request with
us, including this decision, please feel free to contact the OIA Services Team on:
[email address].
Under section 28(3) of the Act, you have the right to ask the Ombudsman to review any
decisions made under this request. The Ombudsman may be contacted by email at:
[email address] or by calling 0800 802 602.
Please note that this response, with your personal details removed, may be published on the
Ministry website at:
www.health.govt.nz/about-ministry/information-releases/responses-official-
information-act-requests.
Nāku noa, nā
Phil Knipe
Chief Legal Advisor
Corporate Services | Te Pou Tiaki
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