Rights Act 1990, the presumption of innocence until proven guilty. He argued that section 6 of the Bill of Rights Act required section 6(6) of the Misuse of Drugs Act 1975 to be given a meaning consistent with the presumption of innocence. Hansen contended that consistency with the presumption of innocence would be achieved if section 6(6) of the Misuse of Drugs Act 1975 was construed to impose an evidential burden on him which, if accepted by the jury, might create a reasonable doubt of his possession being for supply. This would impose the legal onus on the Crown to satisfy the jury beyond reasonable doubt that the appellant was in possession of drugs for supply. The majority of the court found that the reverse onus in section 6(6) of the Misuse of Drugs Act 1975 was not rationally connected to the objective or it was not a proportionate response to the problem, and was in breach of section 25(c) of the Bill of Rights Act 1990. However, section 4 of the Bill of Rights Act forced the court to allow the presumption-of-supply clause to prevail, and Hansen's appeal was unsuccessful. Criticism and reform In the Hansen decision, several judges criticised the fact that the courts are constitutionally bound by section 4 of the Bill of Rights Act to uphold legislation they have concluded is inconsistent with the Bill of Rights. The New Zealand Law Commission's 2011 report on controlling and regulating drugs contained several criticisms of the Misuse of Drugs Act 1975. Considering how to best address the problem of proof that the presumption of supply seeks to remedy, while respecting the protection conferred by section 25(c), the commission proposed the removal of the offence of possession for supply in favour of an offence of possession. Responding to the report's recommendations, in September 2011 the government issued a Regulatory Impact Statement. Although several recommendations were implemented, it was found that greater clarity on the impact of costs and resources was required to determine the full effects of a new act and drug-classification system (including the presumption of supply). References External links The New Zealand Bill of Rights Act 1990 The Misuse of Drugs Act 1975 Law Commission Report 2011: Controlling and Regulating Drugs – a review of the Misuse of Drugs Act 1975 Government Response to the Law Commission’s Report “Controlling and Regulating Drugs – a review of the