Dear Health New Zealand,
I am requesting the following information held by the Ministry of Health relating to the Government’s COVID‑19 border restrictions and their impact on the right of New Zealand citizens to enter New Zealand.

1. Medical and scientific justification documents
All medical, scientific, epidemiological, modelling, risk‑assessment, or public‑health documents (including internal advice, external advice, briefings, memos, emails, reports, and assessments) that were used, relied upon, referenced, or considered by the Ministry of Health to justify restricting or preventing New Zealand citizens from entering New Zealand during the COVID‑19 response.

This includes (but is not limited to):

the assessed risk posed by returning citizens

the necessity of restricting entry

the medical justification for requiring MIQ as a precondition for entry

the medical justification for limiting MIQ availability

any advice on whether preventing citizens from boarding flights was medically justified

2. NZ Bill of Rights Act 1990 – s18(2) and s5 analysis
All documents that assess, discuss, or reference the New Zealand Bill of Rights Act 1990, specifically:

s18(2) — the right of every New Zealand citizen to enter New Zealand

s5 — justified limitations on rights

This includes all proportionality assessments, rights‑impact assessments, legal‑medical interface documents, and any analysis of whether restricting citizen entry was:

prescribed by law

demonstrably justified

proportionate

the least rights‑restrictive means available

3. Consideration of less‑restrictive alternatives
All documents that consider, evaluate, or model less‑restrictive alternatives to limiting citizen entry, including:

home isolation

rapid testing

risk‑stratified entry

medically‑supervised entry

alternative quarantine models

4. MIQ availability and functional denial of entry
All documents that record, analyse, or discuss whether MIQ availability constraints constituted a functional denial of entry for New Zealand citizens who were unable to secure a voucher.

5. Consideration of the diplomatic request printed in the NZ passport (forced yes/no)
Please provide all documents, legal advice, internal correspondence, or policy papers that show whether the Ministry of Health considered, analysed, or discussed the legal meaning or implications of the diplomatic request printed inside the New Zealand passport:

“…to allow the bearer to pass freely without let or hindrance, and to afford the bearer such assistance and protection as may be necessary.”

This includes any assessment of whether COVID‑19 border restrictions, MIQ availability limits, or flight‑boarding restrictions were consistent with or contrary to that statement.

If no such documents exist, please confirm this explicitly.

6. Withheld documents list
A list of all documents withheld in full, including the specific OIA grounds relied upon for each withholding.

7. Search methodology (if refusing under s18(e) or s18(f))
If any part of this request is refused under s18(e) or s18(f), please provide:

the specific searches undertaken

the specific databases, repositories, or systems searched

the date ranges searched

the job titles (not names) of staff who conducted the searches

8. Assistance under s18B
If any part of this request is considered too broad, I request that you identify the specific part(s) causing difficulty and provide reasonable assistance to refine them.

I am happy to receive the information in electronic form.

Yours faithfully,

Nigel Gray