evidence I have heard, Tuhoe tikanga in its current form, has not adapted to accommodate a personal right on the part of an individual of Tuhoe descent, living outside tribal life, to make decisions for him or herself, or for their immediate family to make decisions on their own behalf, as to where his or her body is to be buried. This is not to say that Tuhoe tikanga may not adapt in that direction in the future. That, however, is a matter for Tuhoe and not a matter for this court. Court of Appeal The Takamore whānau appealed against the ruling. The Court of Appeal ruled for Clarke and the police were prepared to enforce an exhumation order. Supreme Court The Supreme Court heard the case on the grounds of: "whether the Court of Appeal was correct to hold that New Zealand law entitled the executrix to determine disposal of the body of the deceased and whether it was correct to hold that the executrix is entitled to take possession of the body of the deceased not withstanding its burial." The result was a split decision confirming Clarke's rights to determine disposal of the body. Confrontation An August 2014 attempt to enforce the Supreme Count decision was halted when police refused to use force to overcome considerable local resistance to the exhumation. Mediation Multi-party mediation in June 2015 led to a resolution and settlement that has not been released. The case led to new research on Māori customary burial practises, which had been dismissed by the Supreme Court with a 79-page judgement which acknowledged "significant cross-cultural misunderstanding" but upheld the common law rule. Opinion Opinion about the case is mixed, with a number siding with the Takamore whānau citing the United Nations Declaration on the Rights of Indigenous Peoples which gives indigenous people's traditional practices legal weight. The court decision explicitly considered the declaration. Similar cases A previous similar case involved Ngāpuhi descendant whose whānau tried to have his body returned from Otago to the Far North. There was also tension over the burial place of comedian Billy T. James. Disputes over the disposition of bodies is not uncommon in cases of alleged domestic violence. Further reading CA 525/2009 Takamore v Clark decision from the Court of Appeal Takamore v Clark decision from the Supreme Court of New Zealand Ownership of tupapaku. Tomas, VC. New Zealand Law Journal 233-236