[1] In early 2001, considerable political controversy arose concerning two Cabinet Ministers who were registered as electors in the Wellington Central Electorate, and were also in receipt of parliamentary allowances payable only to Members of Parliament (MP) whose normal place of residence is outside Wellington. That attracted significant public interest and media attention. A number of investigations and inquiries into various aspects of the controversy were undertaken, by several agencies of government. One of these was an investigation by the Registrar of Electors for the Wellington Central Electorate concerning the registration of Ms Phillida Bunkle MP. The outcome of that investigation was the subject of an application for judicial review by the appellant. The proceedings were heard before Wild J who, in a judgment delivered on 25 November 2004, dismissed the application (Edwards v Toime (No 2) [2005] NZAR 228 (HC)). This is an appeal against that decision.

Factual background

[2] Ms Bunkle was registered as an elector in the Otaki Electorate for the 1996 general election, at which she was elected as a list MP. From June 1997, she made a claim for the Wellington accommodation allowance which is payable to MPs who reside outside Wellington, in respect of a property which she owned in Thorndon. On 18 January 1999 she enrolled in the Wellington Central Electorate, giving as her address the Thorndon property. In the 1999 general election she was elected as member for the Wellington Central Electorate, and was appointed a Minister. She was allocated a ministerial residence in Wellington in about March 2000. Such allocation is available only to Ministers who do not normally reside in Wellington. Upon that allocation, payment of the Wellington accommodation allowance was terminated.
[3] The fact that Ms Bunkle was enrolled in, and member for, the Wellington Central Electorate, and at the same time occupying a ministerial residence became the subject of considerable political and public interest in early 2001. On 29 January 2001, Mr Sowry, an opposition MP, wrote to the third respondent, the Registrar for the Wellington Central Electorate, requesting that she investigate the circumstances surrounding the registration as electors in the Wellington Central Electorate of Ms Bunkle and another government MP. He stated the issues to be:

Was Ms Bunkle’s enrolment on the Otaki electoral roll for the 1996 General Election valid if she did not have a permanent dwelling at that time?

If Ms Bunkle was claiming Wellington accommodation allowances from June 1997 through to the General Election in 1999, in effect stating that she considered either Waikanae or Nelson to be her primary place of residence during that period, how could she then truthfully advise the Registrar of Electors that she considered her place of residence to be at 204 Sydney Street West in Wellington for enrolment purposes?

He went on to say:

I am of the view that these circumstances require further investigation as there appears to be the possibility that Ms Bunkle and Ms Hobbs may have breached sections 118 and 119 of the Electoral Act 1993 in making a false statement or declaration.

[4] Mr Prebble, another opposition MP, became aware of the Registrar’s inquiry and wrote to the Registrar on 15 February 2001. In his letter he said:

The Hon Phillida Bunkle enrolled in Wellington Central so she could claim, as she did during the campaign, that she was a Wellington Central resident. The false enrolment was done to mislead voters.

I suggest there is a prima facie case of a deliberate false enrolment that undermines the integrity of the electoral system. The Electoral Act, Section 120 says that if there is any question of a false enrolment you must refer the matter to the Police.

I suggest you find out whether any of them voted in the election. If so, the false enrolment is even more serious.

He requested to be informed of the action that the Registrar was taking.

[5] When the complaints were received, the second respondent, who was the Deputy Chief Registrar of Electors, sought advice from the Solicitor-General. That opinion was made available on discovery. It dealt with a number of issues arising from the controversy. The main points of it, so far as the issue of registration in Wellington Central is concerned, may be briefly summarised:

(a) On the material available, the Solicitor-General thought it unlikely that the Wellington property could properly be said to have been Ms Bunkle’s “home” within the meaning of s 72(3) of the Electoral Act at the relevant time, and that the matter merited further investigation by the Registrar;

(b) An error in relation to residence under the Electoral Act did not necessarily mean that an offence under ss 118 or 119 of the Electoral Act had been committed and that any offences under those sections are subject to the six month limitation period in s 14 of the Summary Proceedings Act 1957; and

(c) Irrespective of the limitation period, it is open to the Registrar to seek the person’s removal from the electoral roll under ss 96 or 98(1) of the Electoral Act.

[6] The more detailed advice from the Crown Law Office which accompanied the Solicitor-General’s opinion proposed a particular course of action. That advice expressed the view that should it appear that either of the two Ministers was incorrectly enrolled, it was open to the Registrar to seek their removal from the electoral roll under ss 96 or 98(1) of the Electoral Act and recommended that the Registrar should commence inquiries by corresponding directly with them, if necessary seeking the assistance of the police under s 122. The opinion was expressed that it is implicit in the responsibilities of the Registrar for the maintenance of electoral rolls that he or she may make inquiries of his or her own accord where it appears necessary to do so. The advice included a draft letter to Ms Bunkle from the Registrar for that purpose.
[7] A letter in the form of the draft was sent by the Registrar to Ms Bunkle on 21 February 2001. It said

... I wish to inquire into the circumstances of your enrolment in Wellington Central to determine whether your enrolment was incorrect and so should be subject to objection or removal from the Wellington Central electoral roll under sections 96 and 98(1)(i) of the Electoral Act or prosecution under sections 118 or 119. I should note that the latter could, in any event, only arise in respect of any actions taken in the last six months due to the limitation period provided by section 14 of the Summary Proceedings Act 1957.

The letter asked a number of questions directed at ascertaining the circumstances of Ms Bunkle’s residence at relevant periods, and where she considered her home to be. That information was sought as at three dates: 18 January 1999, when she had applied to register in Wellington Central; 28 April 2000, when ministerial housing was allocated; and the present time, as the Registrar understood from the Chief Registrar of Electors that Ms Bunkle was in the process of registering as an elector in the Otaki Electorate.

[8] Ms Bunkle replied on 2 March 2001. She supplied the information requested in response to the Registrar’s questions. On 8 March, her solicitors wrote to the Registrar, enclosing an opinion which had been obtained from Mr Rennie QC. Mr Rennie expressed the following opinion, relevant to the matters at issue in this proceeding:

It does not appear to me that the Registrar of Electors has any statutory power to inquire into a registration which is no longer in effect and which is outside the statutory period for any offence action, but there is no reason why Ms Bunkle cannot as a courtesy respond to an inquiry from the Registrar – as she has in fact done.

[9] The Registrar responded on 19 March 2001. She set out her views at some length, in terms which included the following:

I have considered all of this material and have set out my preliminary conclusions below. I should note that I do not agree with Mr Rennie’s conclusion that I lack statutory power to inquire into Ms Bunkle’s previous enrolment in Wellington Central. Under Part V of the Electoral Act, I am responsible for the maintenance of the electoral roll for Wellington Central. Inherent in that responsibility is a concern for the accuracy of the roll and public confidence in the integrity of the enrolment process.

......

On the basis of these provisions, I consider that Ms Bunkle’s Waikanae home was her chosen place of residence within the meaning of the Act, rather than the other places in which she lived when temporarily absent or while working or on parliamentary or ministerial service. I conclude Ms Bunkle’s enrolment in the Wellington Central electorate was, for that reason, incorrect.

......

Moreover, while I could have been obliged to seek to correct Ms Bunkle’s enrolment under section 96 of the Act had she remained in Wellington Central, I understand that Ms Bunkle has recently registered as an elector in the Otaki electorate. There has been no suggestion that Ms Bunkle’s new enrolment is incorrect.

......

In summary, my preliminary conclusions are that –

Ms Bunkle was not qualified to register as an elector of Wellington Central either at the time of her application in 1999 or thereafter; and
In light of Ms Bunkle’s misunderstanding of the Act, her subsequent enrolment in Otaki and the passage of time, no issue now arises under sections 96, 118 or 119 of the Act.

I should be happy to consider any further comments that Ms Bunkle or her advisors may have before reaching final conclusions.

[10] Ms Bunkle’s solicitors replied on 20 March 2001, indicating an intention to respond to the preliminary conclusions, and seeking a meeting. The letter noted that there was a disagreement with Mr Rennie’s advice on jurisdiction, and sought a copy of any legal advice which the Registrar had obtained on point. The Registrar responded on 21 March to the effect that she had received oral advice from the Crown Law Office on the question and the tenor of this advice was as set out in her letter of 19 March. Ms Bunkle wrote to the Registrar on 23 March 2001 expressing concern at her letter of 19 March and her draft preliminary conclusions as she thought the Registrar had misunderstood the position. She said:

As you are aware, the Auditor-General has now released his report on the payment of accommodation allowances to me. In that report he finds that the test for “residence” in the Electoral Act is not entirely objective, and can be a place other than where one regularly lives, at least for the time being. He makes it clear that there may be a difference between allowance entitlements and enrolment, as you noted in your original letter to me. He reached his conclusions after detailed investigations including a lengthy questioning of me.

I believe a meeting with you would have the same value, unless you are content to rely on the Auditor-General’s findings. That is why I have requested a meeting with you and the Chief Registrar. I am concerned that your first draft, if finalised, would have serious consequences and could result in serious injury to my reputation. I would much prefer that we sort this out between us rather than see the matter turn into a legal dispute.

[11] Following a further exchange of correspondence, a meeting was held on 26 March 2001. Present were Ms Bunkle and her partner, with Mr Rennie and Ms Ryder-Lewis (Ms Bunkle’s solicitor), Ms Uren, Mr Wicks, Ms Sim and Mr Peden from the Ministry of Justice, and Messrs Hodgen and Keith from Crown Law Office. The meeting lasted from 3 - 4.30pm and is recorded in a file note made by Mr Keith. The minute noted that the meeting was held on the request of Ms Bunkle through Mr Rennie and Ms Ryder-Lewis. Mr Rennie was asked to indicate what matters were to be discussed. The file note records:

...Mr Rennie said that he saw there to be two levels to the issue. The first was that he disagreed with our view as to the Registrar’s jurisdiction. The second was that both he and Ms Bunkle felt that the Registrar had misunderstood her circumstances.

On the jurisdiction point, Mr Rennie essentially repeated the view that he had expressed in his second opinion. MH [Mr Hodgen] commented that he considered in the scheme of the Act, there was a wider concern for the Registrar to ensure the integrity of the roll, and this included ensuring voters did not act on misconceptions. Mr Rennie said that he thought that the latter was the role of the Electoral Commission.

The minute then records the discussion which took place. After the conclusion of the meeting, after Ms Bunkle and her advisors had left, the file note records the following:

We then had a brief discussion with the Ministry of Justice and electoral officials. Ms Sim indicated that Ms Bunkle’s account was, in her view, consistent with her previous statements and also, whether as a result of careful legal advice or not, met the requirements of the Act. She took the view, with which MH agreed, that provided that the different statements were consistent it was not open to the Registrar to dispute Ms Bunkle’s credibility. Ms Sim agreed that the Ministry would draft responses to Ms Bunkle and to the complaints, Mr Sowry and Mr Prebble. MH said that we looked forward to receiving those on Tuesday.

[12] There is, among the discovered documents, a draft letter from Ms Uren to Ms Bunkle which refers to the meeting of 26 March 2001 and says:

On the basis of the information you provided at our meeting about your family circumstances and your reasons for living in Wellington Central during this period, there appears to me to be no basis to question your qualification to enrol as an elector of Wellington Central during this period.

[13] The provenance of that draft is not clear from the evidence. It was never finalised in that form. Ms Uren does not refer to it. Her evidence on this issue is as follows:

Throughout the meeting, Ms Bunkle referred both to Wellington and Waikanae as her home. The issue in terms of the Act was where Ms Bunkle’s place of residence was at the various relevant times. At the end of the meeting, I was no clearer on Ms Bunkle’s true view of that issue. I did not agree with what is recorded as Ms Sim’s view that Ms Bunkle’s account was consistent with her previous statements and met the requirements of the Act.

....

After the meeting, the Ministry of Justice and the Crown Law Office prepared draft opinions, which were then distributed to Mr Wicks and me for comment. On 30 March 2001, I went to Mr Wicks’ office to consider a final letter to Ms Ryder-Lewis, counsel for Ms Bunkle. Mr Wicks reminded me at this time that I was free to accept or reject the draft letter. After reading and approving the letter, I signed it. The letter to Ms Ryder-Lewis outlined my final decision on this matter.

[14] The letter signed by her, as referred to in her evidence, was dated 30 March. It sets out the background in detail and expresses her conclusions in these terms:

As I have advised previously, I do not believe that Ms Bunkle had the necessary criminal intent to commit any offence under sections 118 or 119 of the Electoral Act, even if those offences were not subject to the limitation period under the Summary Proceedings Act 1957. Nor do I consider that there is anything that approaches the criminal standard of proof to establish that Ms Bunkle’s enrolment was incorrect.

However, I consider that in order to determine the validity of Ms Bunkle’s enrolment in Wellington Central it would be necessary for me to make findings as to subtle, and highly subjective, issues of fact. If Ms Bunkle were still enrolled in Wellington Central, I could have made those findings, at least as they related to her present circumstances, under section 95 or section 96 of the Electoral Act and they would have been open to review by the District Court. Under that procedure, Ms Bunkle would have had the onus of establishing her qualifications as an elector in the Wellington Central electoral district.

Alternatively, had a complainant challenged Ms Bunkle’s enrolment in the course of an electoral petition at the time of the last election, the issue would have been determined by the High Court under section 236 of the Electoral Act. In the absence of any such court procedure, and given the complexity of Ms Bunkle’s circumstances, I do not consider that I can or should reach any conclusion either way except to reiterate that Ms Bunkle’s original explanation of her enrolment was based on a misunderstanding of the Electoral Act.

Finally, I have also considered the complaints made in respect of Dr Lepper and two other members of Ms Bunkle’s family registered at Ms Bunkle’s Sydney St West address. I have established that one of the other family members reregistered in another electoral district shortly before the 1999 General Election and have not, for that reason, had cause to investigate that person’s enrolment further. Once again, I do not believe that there has been any offence against sections 118 or 119 or the Electoral Act. As to the validity of the enrolment of Dr Lepper and the other family member, I consider that the complexity of these circumstances and the fact that neither remains enrolled in Wellington Central similarly prevent me from reaching any conclusion.

I should note that I shall be advising Mr Sowry and Mr Prebble of my conclusions in respect of their complaints. The Electoral Enrolment Centre will also make a brief public statement in respect of my conclusions.

The proceedings

[15] It does not appear that Ms Bunkle took any steps to challenge or contest that outcome of the inquiry. However, the appellant, who feels very strongly that an injustice had been done to Ms Bunkle, commenced these proceedings. He claimed that his right, with others, to be represented in Parliament by Ms Bunkle had been infringed by the consequences of the investigation. No issue has been taken as to his standing.
[16] The statement of claim, prepared without legal assistance, raised a number of matters. These were summarised by Wild J in the following terms:

[36] The applicant filed on 31 July 2003 a further amended statement of claim running to 106 paragraphs and 33 pages. For the Crown, Ms Warburton distilled from this 33 causes of action against the respondents. She suggested that these could usefully be summarised under the following categories:

[a] Jurisdiction:

The Registrar lacked jurisdiction to inquire into Ms Bunkle’s electoral enrolment.

[b] Natural justice:

The Registrar failed to conduct her inquiry in accordance with the principles of natural justice.

[c] Dictation:

The Registrar acted under dictation.

[d] Lack of dictation:

The Registrar was required to act under dictation but did not do so.

[e] Oppressive and negligent inquiry process:

Mr Toime was responsible for the acts and omissions of his subordinates and was in breach of his terms of employment, and Mr Wicks was complicit with the Registrar in an oppressive and negligent process.

[f] Irrelevant/relevant considerations:

In reaching her decision, the Registrar took into account irrelevant, and failed to take into account relevant, considerations.

[17] In his Notice of Appeal, the appellant appeals against the whole of the judgment. Particular grounds of appeal are not stated. In his submission, Mr Edwards raises a wide range of matters. It is convenient, in addressing these, to adopt Wild J’s categorisations of the issues.

The Legislation

[18] Before turning to address those, it is desirable to describe some essential features of the broad scheme of the Electoral Act so far as they are relevant. The most relevant provisions are set out in the appendix to this judgment, for ease of reference. Under s 21, the Chief Executive of New Zealand Post Limited (the First Respondent) is appointed as the Chief Registrar of Electors. The Chief Registrar is charged, under the direction of the Minster of Justice, with the duty of carrying into effect Part 5, which deals with the registration of electors. That duty includes a requirement to take all reasonable steps to ensure the accuracy of information held on the electoral roll. The Chief Registrar may appoint an officer or employee of New Zealand Post Limited to be the Deputy Chief Registrar of Electors. The Second Respondent has been appointed. Under s 22, for each electoral district the Chief Registrar appoints an employee of New Zealand Post Limited as Registrar of Electors. For the Wellington Central Electorate, that was the third respondent. The Registrar is required, under the direction of the Chief Registrar, to compile and keep the roll for that electoral district and to carry out such other functions and duties as are specified in the Act.
[19] Part 5 deals with the registration of electors. Under s 82, every person in New Zealand qualified to be registered as an elector of any electoral district must apply for registration. Qualification is determined in accordance with s 74. The relevant electoral district is based on residence, and is generally that in which the person has last continuously resided for more than one month. The place of residence is to be determined in accordance with the rules set out in s 72. An application for registration must state the particulars set out in s 85, and, under s 87, if the Registrar is satisfied that the applicant is qualified, he or she shall forthwith enter the name of the applicant on the roll.
[20] Objections to registration are provided for in ss 95 - 97. Under s 95, any elector may at any time object to the name of any person being on the roll for any district on the ground that that person is not qualified to be registered as an elector of that district. The objection is to be made in writing to the Registrar setting out sufficient particulars to inform the person objected to of the grounds of the objection and the reasons supporting it. The Registrar may seek further particulars. Under s 95A the Registrar must forthwith serve notice of any such objection on the person concerned. That notice must include the name of the objector and the particulars of the objection, sufficient to inform the person of the ground of and reasons for the objection. It must contain further particulars to which we later refer. Under s 96, a similar notice may be given by the Registrar on the basis of the Registrar’s own objection.
[21] Where a notice is given under ss 95 or 96, the following outcomes are possible, depending upon the response (if any) to the Registrar’s notice:

(a) Under s 95B, if the person objected to fails to provide evidence of eligibility to be on the roll, or notifies the Registrar that he or she consents to removal from the roll, the name is to be removed from the roll.

(b) Under s 95C, if the person objected to provides the Registrar with evidence that satisfies the Registrar that the person objected to is qualified to be on the roll, the name is retained on the roll.

(c) Under s 95D, if neither of those situations applies, the Registrar shall refer the objection to a District Court and notify the parties of the time and place appointed for the hearing. The procedure in the District Court is governed by s 97.

[22] Under s 98, there are provisions for the removal of names from the roll in certain specified circumstances. There are also a number of offence provisions. Section 118 creates an offence of knowingly and wilfully making a false statement in any application. Section 119 creates an offence of wilfully misleading the Registrar. Section 120 imposes on the Registrar a duty to report facts which cause the Registrar to believe that any person has committed an offence against s 119 to the police. Section 122 provides for police to assist the Registrar in certain matters that are specified.

The issues

Jurisdiction

[23] Against that legislative background, it is necessary to consider the various steps which were taken by the Registrar, and how and whether those fit within the statutory procedures. The first relevant step is her letter of 21 February to Ms Bunkle. Wild J said of this letter:

[51] The Registrar was entitled to treat the letter as an elector’s objection under s95 or as the basis for initiating an objection of her own under s96. Her 21 February letter indicates that she took the latter course, since it refers to ss96 and 98(1)(i) of the Act. However, in paragraph [61] following, I hold that the Registrar in fact treated Mr Sowry’s letter as an elector’s objection under s95, which is what it was.

.....

[61] That conveys to me (as it appears to have conveyed to Ms Bunkle and her legal advisers), that the Registrar had decided to inquire – and was inquiring – in response to Mr Sowry’s objection. I do not interpret it as the Registrar conveying to Ms Bunkle that the Registrar was trying to decide whether herself to object under s96. I hold that Mr Sowry’s letter of 29 January was an elector’s objection under s95, and was treated as such by the Registrar.

[24] We do not consider that the letter was, or was intended to be, a notice under either ss 95A or 96. We agree that the Registrar would have been entitled to treat Mr Sowry’s letter as an objection under s 95. While it does not purport to be made under that section, no particular degree of formality, beyond that specified in s 95(2), is required. The letter might have been viewed as meeting those requirements. However, we do not consider that the Registrar was obliged to treat the letter as such an objection. There was no specific request so to do. The letter was specifically directed to the possibility of a breach of ss 118 or 119. The terms of her letter of 21 February are not consistent with her having treated Mr Sowry’s letter as a s 95 objection.
[25] The steps which were taken did not trigger the objection procedure, either by Mr Sowry’s letter being treated as an elector’s objection, under s 95, or (as counsel for the respondent had submitted to Wild J) by the Registrar initiating an objection under s 96. Triggering of those procedures would have required the Registrar to serve notice under ss 95A(1) or 96(2). Such a notice is required to include particulars sufficient to inform the person objected to of the ground for the objection and the reason or reasons supporting the ground for objection. Such a notice is also required to comply with ss 95A(3) or 96(4). These both require that the notice inform the person objected to that: he or she may send a statement to the Registrar explaining why he or she should remain on the roll; that the person’s name will be retained on the roll if he or she provides evidence that satisfies the Registrar that he or she should remain on the roll and that if the person fails to send such a statement within 14 days after the notice is served on the person, the Registrar will remove that person from the roll.
[26] The Registrar’s letter of 21 February did not comply with those provisions. There was no reference to the possibility of retention of the name on the roll or removal. The terms in which reference to s 96 is made in that letter suggest that the possibility of objection under s 96 is a stage which might follow, not that the s 96 process is being triggered by that letter. A degree of non-compliance with formalities does not necessarily lead to a conclusion that the document was not a ss 95A or 96 notice, if the intent is clear. But this is not a case where it is appropriate to treat the letter as a ss 95A or 96 notice despite the non-compliance. The letter was sent in the form in which it had been drafted by Crown Law Office. If it had been intended to be a ss 95A or a 96 notice, it would not have been drafted in those terms. Read in its entirety, we do not consider that the letter can properly be treated as a notice of objection under either ss 95A or 96. As the terms of the letter make clear, the Registrar was making the inquiries for the purpose of determining whether the enrolment was incorrect, and so should be subject to the objection and removal procedures, or to prosecution, not as commencing the formal statutory process.
[27] That necessarily raises the issue whether it is within the scope of the Registrar’s powers, or necessarily incidental to the exercise of her functions, to make inquiries of an elector before deciding whether to issue a notice under ss 95A or 96, or whether the offence provisions should be invoked.
[28] We deal first with the question whether such inquiry is appropriate as a step preliminary to the issue of a notice and under ss 95A or 96. A notice under those provisions must contain such particulars of the objection as are sufficient to inform the person objected to of the ground for the objection and the reason or reasons supporting the ground for objection. Some investigation by the Registrar may be necessary to determine whether there are grounds for objecting, and whether there are reasons to support those grounds. The extent of inquiry which may be seen as reasonably incidental to the function of issuing a notice must be seen in the light of the procedure as a whole. The notice under ss 95A or 96 is the starting point of a process which does not necessarily lead to a decision by the Registrar that the name is retained on, or removed from, the roll. It will do so only in the circumstances set out in ss 95B and 95C. If evidence is provided in response to a notice, but that evidence does not satisfy the Registrar that the person is qualified to be on the roll, the objection must be referred to the District Court under s 95D(1).
[29] That is relevant to the extent of inquiry which may be reasonably incidental to the exercise of the Registrar’s powers to issue a notice under ss 95A or 96. The questions which were posed in the letter of 21 February were clearly directed to the issue of eligibility. The questions were of a type which would have been relevant if an objection under ss 95A or 96 had proceeded to the District Court. They were not relevant to questions on which the Registrar was required to form a view before deciding whether to issue a notice. The letter of 21 February went beyond the proper bounds of the Registrar’s ability to make inquiries as to whether a ss 95A or 96 notice is appropriate.
[30] The second aspect of the 21 February letter was the possibility of prosecution under ss 118 or 119. The Registrar does have power, as reasonably incidental to the duty imposed on the Registrar by s 120 to report suspected offences to the police, to investigate the facts of a matter sufficiently to determine whether the Registrar forms the belief that an offence has been committed under s 119. The extent of inquiry which is appropriate is a matter for the judgment of the Registrar. It must be related to the possibility of an offence. Offences under both ss 118 and 119 are, as the Registrar noted, subject to a six month limitation period. Any inquiry would necessarily be limited to matters occurring within that six month period. The questions in the Registrar’s letters were not limited in that way. The letter went beyond the proper bounds of an inquiry under the s 120 duty.
[31] The third possible basis for a power to make inquiry such as was made in the letter of 21 February is the general function of the Registrar under s 22(4).
[32] Under that section, the Registrar may make such inquiries as are reasonably incidental to the performance of the duty under (a) (that the Registrar shall compile and keep the electoral roll as required by the Electoral Act), and of any other functions and duties under the Act. The relevant aspect of the compilation and keeping of the roll in this case is the subject of the specific provisions in ss 96 to 98, which we have already addressed. The relevant functions in relation to offences under ss 118 to 120 have also been dealt with. There are no other relevant functions or duties on which the letter of 21 February could be based.
[33] For these reasons, we consider that, even if Ms Bunkle’s enrolment in Wellington Central was still effective at 21 February, the making of the inquiries in that letter did not fall within the scope of the Registrar’s functions.
[34] More important, however, is Ms Bunkle’s application for registration in the Otaki Electorate. Acceptance of her application for registration in that electorate must necessarily have involved the removal of her name from the Wellington Central Electorate. It is clear that application for enrolment had been made before the letter of 21 February was written. Wild J refers to it having been made on 14 February. It apparently became effective shortly thereafter. The Registrar’s letter of 19 March indicates that it was complete by then.
[35] Wild J held ss 95 and 96 are dependent upon the person being on the roll at the time of the objection. We agree with that conclusion. However, he rejected a submission that the Registrar’s jurisdiction ended when Ms Bunkle made her application to register in the Otaki Electorate. He said that whilst enrolment in an electorate gives jurisdiction to inquire there is nothing in the Act to the effect that de-enrolment terminates jurisdiction. He accepted that it removes the Registrar’s main sanction of removal from the roll, but expressed the view that there is a point in the Registrar expressing a view as to whether the elector had been qualified to be registered, and that such an inquiry, and expression of view, are consistent with the function of maintaining the integrity of the electoral rolls.
[36] We do not agree with the conclusion that the Registrar’s jurisdiction under the objection continued after de-enrolment. The purpose of the objection process under ss 95 and 96 is to maintain the integrity of the roll by examining the entitlement to registration, and removing the names of persons who are not entitled. The function does not go further than that. Wild J did not accept that an elector could forestall inquiry by “de-enrolling”. But the Act permits that. Section 95B allows the subject of an objection to consent to the removal of their name from the roll. Once that has been achieved, there can be no further point, in the performance of that statutory function, in continuing the inquiry. The maintenance of the integrity of the roll is an aspect of the function of the Registrar to compile and keep the roll for that district under s 22(4). There is also a requirement in s 21(2A) that the Chief Registrar, under whose direction the Registrar must act in performing the function under s 22(4), must take all reasonable steps to ensure the accuracy of information held on the electoral roll. In both cases, the focus is on the current roll. The power to make inquiries directed to those matters ends when the objective, namely the integrity of the roll, is achieved. In this case, that was upon removal from the roll. From that point, the power to make inquiries as to the entitlement for the period when Ms Bunkle was on the roll ended. Jurisdiction to investigate possible offences would not end with de-enrolment, but, for the reasons given at [30] above, that is not relevant here. For this reason, too, the letter of 21 February was not within the scope of the Registrar’s functions.
[37] We also do not agree that there can be a point in the Registrar, after completing her inquiry, expressing a view as to whether the elector had been qualified to be registered. Retention on the roll under s 95C can occur only if there is evidence which satisfies the Registrar. If the evidence leaves the position doubtful, the issue is to be determined by the District Court. It is not, in a doubtful case, a function of the Registrar to express a view one way or the other. Accordingly, once the purposes of ss 95 and 96 have been achieved, by the removal of a name from the roll, it cannot be regarded as reasonably ancillary to the exercise of the powers under ss 95 and 96 that the Registrar may continue the inquiry, and express a view which would not form part of the outcome of the objection process if it had continued. In her letter of 30 March 2001, the Registrar expressed the view that, if ss 95 or 96 applied, she could have made findings as to subtle, and highly subjective issues of fact concerning Ms Bunkle’s eligibility and that these would have been open to review by the District Court. The function of the court on an objection referred by the Registrar under s 95D(1) is an original jurisdiction, not a review of a decision of the Registrar. It is only the function on an objection referred under s 95D(2) which is akin to a review. That function arises, in a case where there is evidence, only where that evidence satisfies the Registrar that the person is qualified. It seems unlikely that the Registrar could properly be satisfied under s 95C if findings as to subtle and highly subjective issues of fact are required. The scheme of the Act suggests that in a case where difficult issues of fact are involved, the Registrar should refer the issue to the court under s 95D(1).
[38] The equivalent provisions in the predecessor legislation, the Electoral Act 1956, were the subject of consideration in Togiatama v Parker [1994] 2 NZLR 347 (HC). Temm J there said (at 352):

It is quite clear that Parliament has decided that if there be an objection to the inclusion of a name of a person on the roll that question is of such importance that it should be decided not by the Registrar, but by the Court. For that reason once the Registrar receives notice of objection he must make that known to the person who is the subject of the objection and, if that person under challenge does not consent to the removal of his or her name within seven days, then the Registrar is required to refer the matter to the District Court for the challenge to be considered judicially and an appropriate judgment delivered.

It is at that stage, when the matter is heard in the District Court, that each side will produce the evidence that is relevant to the question and, the person whose right to be enrolled is challenged, can apply to the District Court Judge for an order for further particulars if there be any aspect of the notice of objection which leaves the person under challenge embarrassed in his or her defence for lack of information if that should be the case.

The present provisions are different from those considered in that case, to the extent that the Act now permits a decision by the Registrar in the circumstances set out in ss 95B and 95C. In other cases, the proposition that the decision is one for the court, not the Registrar, continues to apply. The fact that difficult questions of fact arise, and that the Registrar has jurisdiction to decide definitively only in favour of continued enrolment, not removal, indicates that the District Court procedure under s 95D(1) is more appropriate for dealing with cases at the margin.

[39] By the time the Registrar expressed her preliminary conclusion in her letter of 19 March, she herself recognised that the issue was no longer live. It is not appropriate to take a restrictive view of the Registrar’s powers of inquiry in the exercise of her statutory functions. A broad discretion to determine the nature and extent of her inquiries should be recognised. But the steps taken, by way of inquiries and any conclusions expressed as a result, must fall within the scope of the Registrar’s functions. For the reasons we have given, it would not have been part of the Registrar’s function under the objection procedures to reach a conclusion that Ms Bunkle was not qualified – that was never a decision which it was for her to make. The only decision she could make was that she was not satisfied as to eligibility which is (albeit subtly) different. This means that the expression of the Registrar’s preliminary conclusion in her letter of 19 March 2001 that Ms Bunkle had not been qualified for registration in Wellington Central did not fall within the scope of the Registrar’s specific functions under ss 95 - 96, nor ss 118 - 120. Nor was it reasonably incidental thereto, nor did it fall within the scope of the Registrar’s general functions under s 22(4). It follows that everything that followed that expression of a preliminary conclusion was likewise outside the scope of the Registrar’s functions under those sections.

Natural Justice

[40] Wild J described Mr Edwards’ submission that the Registrar failed to conduct her inquiry in accordance with the principles of natural justice or fairly, as resting on three grounds:

(a) That Mr Sowry’s complaint was beyond doubt an elector objection under s 95 of the Act and that the Registrar had failed in two respects to comply with s 95A – she did not serve it forthwith, and she did not serve the whole of Mr Sowry’s letter of objection on Ms Bunkle;

(b) A similar complaint was made in respect of Mr Prebble’s objection; and

(c) That the Registrar did not send Ms Bunkle at any stage a full copy of the opinion she had obtained from the Crown Law Office on 20 February.

[41] The discussion in the preceding section of this judgment deals with the contention that s 95A was not followed. For the reasons we have given, we do not consider that the Registrar was bound to treat either objection as an elector’s objection under s 95. Her letter of 21 February was not, and did not purport to be, a notice of objection under s 95A. There was accordingly no requirement on the Registrar to comply with that section.
[42] As to the contention that there was a breach of natural justice in failing to disclose at that stage the opinion which had been obtained the previous day from Crown Law, Wild J rejected that submission. He noted that legal advice privilege attached to the advice and there was accordingly no obligation to disclose it, though it was disclosed later. In writing the letter of 21 February, the only functions which the Registrar could potentially have been exercising (ignoring the effect of the enrolment in Otaki) were the administrative functions of determining whether a ss 95A or 96 notice should be issued, or whether further inquiry under the offence provisions was appropriate. Legal advice obtained by an official exercising administrative functions is subject to legal professional privilege, and natural justice considerations will not generally override that privilege. For these reasons we consider that Wild J’s conclusion is clearly right.
[43] Wild J further held that although the Registrar did not comply with the strict requirements of s 95A, she had in other respects acted fairly and reasonably and in accordance with the principles of natural justice. Leaving aside the jurisdictional issues which we have addressed, we consider that, if she was able to make the inquiries that she did, there was nothing in the way in which those inquiries were undertaken which would lead us to a different conclusion.

Registrar acting under dictation and lack of dictation

[44] It is convenient to deal with these two aspects together. Wild J described as the nub of the first of these grounds the appellant’s allegation that, virtually from the start of her inquiry to the end of it, the Registrar was acting under dictation from others and not independently as her office required. The second he described as being that the Registrar was under a duty to accept advice from the Ministry of Justice but ultimately failed to do so. Those contentions are, as Wild J noted, at first blush irreconcilable. The important aspect, in dealing with these grounds, is what happened at the meeting on 26 March, and following that meeting.
[45] Before turning to that it is appropriate to deal briefly with events up to that meeting. The Registrar’s letter of 21 February followed the form which was recommended in the Crown Law opinion. That opinion had been sought by the Deputy Chief Registrar, on behalf of the Registrar. We consider that the involvement of the Deputy Chief Registrar was, in the circumstances, both understandable and permissible. The matter had generated considerable political heat, and considerable public interest. It was appropriate for the Deputy Chief Registrar, who is, under s 21(2) exercising the duty of carrying Part 5 of the Act into effect, to ensure that the Registrar was performing her statutory function. The letter of 21 February occurred at a stage in the process where the functions of the Registrar are essentially administrative, as we have earlier discussed. These are not functions which require the exercise of her own independent judgment. They are of a nature which may properly be the subject of direction. That is specifically recognised in s 22(4). The request for an opinion from Crown Law was consistent with an appropriate level of supervision and direction.
[46] So far as the drafting of the letter by Crown Law is concerned, the nature of the Registrar’s functions was such that it was appropriate for her to take and rely on legal advice as to the extent of the inquiries which she could make, and the advice could properly extend to the terms of the letter by which the inquiry was undertaken. The Registrar did not act improperly by adopting the form of letter which was recommended in the advice.
[47] The essential point of the appellant’s contention concerning the events at the meeting on 26 March and following, and the apparently inconsistent submissions which are made concerning acting under dictation, arises from the difference between the file note set out at [11] above, and the draft letter set out at [12] above, on the one hand, and the letter dated 30 March as set out at [14] on the other. The file note and draft letter suggest that the outcome of the meeting was that there was not a proper basis to question Ms Bunkle’s qualification to be registered. The final outcome as expressed in the letter of 30 March was that no conclusion could be reached.
[48] The essence of what the appellant alleges is that Ms Uren had changed her mind between 26 March and 30 March, and that some improper influence had been brought to bear on her to induce that. He says that the letter of 30 March was the subject of dictation to Ms Uren of the outcome. Ms Uren’s evidence is to the contrary. The relevant part of her evidence is set out at paragraph [13]. She says that she did not agree with the conclusion expressed in the file note. She also says that she read and approved the 30 March letter.

Oppressive and negligent inquiry

[49] We have held that the steps which were taken by the Registrar in expressing the preliminary conclusion in her letter of 19 March, and everything that followed that, was outside the scope of the Registrar’s functions. However, it is necessary to bear in mind that, in continuing after the preliminary conclusion the Registrar was essentially acceding to the requests of Ms Bunkle and her advisors, rather than continuing on her own initiative. We do not consider that there is any aspect of the way in which the inquiry was conducted, apart from the question of jurisdiction, which could properly be criticised. Wild J rejected the allegations against the Chief Registrar and the Deputy Chief Registrar, except so far as they related to the delay which he held in giving notice under s 95A. We have differed from Wild J on that point. In other respects, we uphold his conclusions on this aspect.

Irrelevant/relevant considerations

[50] Our conclusion that the Registrar’s inquiries were not within her statutory function makes any discussion of what considerations would or would not have been relevant if the matter had been within her jurisdiction inappropriate. We need say no more on this aspect.

Other submissions

[51] In following the categorisation adopted by Wild J, we have dealt with most of the points raised by Mr Edwards in his submissions. There are some further points on which comment is desirable.
[52] Mr Edwards placed considerable emphasis in his written submissions, on an affidavit dealing in particular with the meeting on 26 March 2001. We have had regard to this evidence, but the views which we have reached have made it unnecessary to discuss the evidence in detail. We have referred specifically only to Ms Uren’s affidavit. That is because, on the essential question of what was in her mind, hers is the only evidence which can be relevant.
[53] Mr Edwards also placed emphasis on a submission that the legal advisers who were initially involved (including attendance at the meeting on 26 March), Ms Sim from the Ministry of Justice and Messrs Hogden and Keith from the Crown Law Office, were apparently not involved in drafting the final letter of 30 March 2001. The evidence does not indicate who had drafted that letter. We do not consider it appropriate to comment further.

The relief sought

[54] In his statement of claim Mr Edwards had sought findings that the claims made in the statement of claim are valid, well founded or soundly based, as well as a number of other forms of relief. The relief which may be granted on an application for judicial review is specified in s 4 of the Judicature Amendment Act 1972. The essential question, in the light of the conclusions we have reached, is what, if any, relief is appropriate. The granting of relief is discretionary. Cooke J in A J Burr & Co Ltd v Blenheim Borough Council [1980] 2 NZLR 1 at 4 (CA) said:

The determination by the Court whether to set the decision aside or not is acknowledged to depend less on clear and absolute rules than on overall evaluation; the discretionary nature of judicial remedies is taken into account.

[55] The statement of claim sought various declarations, none of which are appropriate to express the conclusions which we have reached. We consider that the reasons we have expressed stand as a sufficient recognition of the extent to which the procedures have miscarried, and as sufficient guidance to avoid any repetition. The events are now quite old and the public attention and controversy which attended them has long subsided. It may well be questionable what practical effect a decision to set aside the Registrar’s conclusion might now have. It is also relevant that Ms Bunkle is not a party to this proceeding. We are reluctant to make any order in respect of the decision in these circumstances. The terms of this judgment adequately reflect such interest (if any) as Mr Edwards may properly have in elucidating the powers of the Registrar.
[56] The appropriate outcome is that the appeal should be allowed, and a declaration made that there was no power for the Registrar to undertake the inquiries in and following her letter of 21 February 2001. No other declaratory relief is appropriate. The award of costs made against the appellant by Wild J on 22 April 2005 is set aside. The appellant is entitled to an award of disbursements in the High Court, to be fixed by the Registrar of that Court.
[57] In this Court, the respondent must pay the appellant usual disbursements.

Solicitors:
Crown Law Office, Wellington

APPENDIX: RELEVANT PROVISIONS OF ELECTORAL ACT 1993

21 Chief Registrar of Electors

(1) There shall be a Chief Registrar of Electors who shall be the person exercising the powers, duties, and functions for the time being of the Chief Executive of New Zealand Post Limited.

(2) The Chief Registrar shall, under the direction of the Minister of Justice, be charged with the duty of carrying Part 5 of this Act into effect and to that end the Chief Registrar may, both in that capacity and in the capacity of the Chief Executive of New Zealand Post Limited, provide such computer and other services and such facilities as the Chief Registrar thinks necessary.

(2A) Without limiting the duty imposed by subsection (2), the Chief Registrar must take all reasonable steps to ensure the accuracy of information held on the electoral roll.

(3) The Chief Registrar may from time to time appoint an officer or employee of New Zealand Post Limited to be the Deputy Chief Registrar of Electors, who, subject to the control of the Chief Registrar, shall have and may exercise all the functions, duties, and powers of the Chief Registrar.

.....

22 Registrar of Electors

(1) There shall be for each electoral district a Registrar of Electors to be appointed by the Chief Registrar.

(2) Every Registrar shall be an employee of New Zealand Post Limited appointed by name or as the holder for the time being of any specified office and shall, subject to subsection (3) of this section, be stationed at an office occupied by New Zealand Post Limited within the electoral district of which he or she is Registrar.

...

(4) The Registrar shall, under the direction of the Chief Registrar,—

(a) Compile and keep, as required by this Act, the electoral roll for the Registrar's electoral district; and

(b) Carry out such other functions and duties as are specified in this Act.

...

72 Rules for determining place of residence within New Zealand

(1) Subject to the provisions of this section, the place where a person resides within New Zealand at any material time or during any material period shall be determined for the purposes of this Act by reference to the facts of the case.

(2) For the purposes of this Act, a person can reside in one place only.

(3) A person resides at the place where that person chooses to make his or her home by reason of family or personal relations, or for other domestic or personal reasons.

...

95 Elector's objection

(1) Any elector may at any time object to the name of any person being on the roll for any district on the ground that that person is not qualified to be registered as an elector of that district.

(2) Every such objection—

(a) Shall be made in writing to the Registrar for the district; and

(b) Shall specify—

(i) The name of the objector; and

(ii) Sufficient particulars to inform the person objected to of the ground for the objection and the reason or reasons supporting the ground for objection.

(3) Where the Registrar considers that the particulars included in an objection are insufficient to inform the person objected to of the ground for the objection or the reason or reasons supporting that ground, the Registrar shall by written notice require the objector to provide within 14 days of the giving of the notice such further particulars as the Registrar thinks fit.

(4) Where any objector fails to comply with a notice given under subsection (3) of this section, the Registrar shall give a second such notice to the objector and, if the objector fails to comply with the second such notice, the Registrar shall take no further action in relation to the objection and shall notify the objector accordingly.

95A Notice of elector's objection

(1) Subject to subsections (3) and (4) of section 95 of this Act, the Registrar shall, on receipt of an objection under section 95 of this Act, forthwith serve on—

(a) The person objected to; or

(b) The person who, under section 12(1) of the Protection of Personal and Property Rights Act 1988, is the welfare guardian for the person objected to; or

(c) The attorney appointed by the person objected to under an enduring power of attorney,—

notice in writing of the objection, which notice shall include both the name of the objector and the particulars specified by the objector (being particulars sufficient to inform the person objected to of the ground for the objection and the reason or reasons supporting the ground for objection).

(2) Any notice issued under subsection (1) of this section shall be served personally in accordance with the rules governing personal service contained in the District Courts Rules 1992.

(3) The notice issued by the Registrar under subsection (1) of this section shall also inform the person objected to—

(a) That he or she may forward to the Registrar a statement signed by him or her giving reasons why his or her name should be retained on the roll; and

(b) That his or her name will be retained on the roll if he or she provides the Registrar with evidence that satisfies the Registrar that the name of the person objected to should be retained on the roll; and

(c) That if he or she fails to forward a statement to the Registrar within 14 days after the day on which that notice is served on the person objected to, the Registrar will, under section 95B of this Act, remove from the roll the name of the person objected to.

(4) Where, after making such inquiry as he or she thinks fit, or the Chief Registrar directs, the Registrar is unable, after making at least 2 attempts to do so, to serve the notice of objection on that person personally, the Registrar shall remove the name of that person from the roll and include the name in the dormant roll maintained under section 109 of this Act.

95B Power to remove name from roll

Where, within 14 days after the day on which a notice under section 95A(1) or section 96(2) of this Act is served on the person objected to,—

(a) The person objected to; or

(b) The person who, under section 12(1) of the Protection of Personal and Property Rights Act 1988, is the welfare guardian for the person objected to; or

either fails to provide evidence of eligibility to be on the roll or notifies the Registrar that he or she consents to the removal from the roll of the name of the person objected to, the Registrar shall, unless the objection has been withdrawn by the objector, remove from the roll the name of the person objected to and shall notify the parties accordingly.

95C Power to retain name on roll

Where, within 14 days after the day on which a notice under section 95A(1) or section 96(2) of this Act is served on the person objected to,—

(a) The person objected to; or

(b) The person who, under section 12(1) of the Protection of Personal and Property Rights Act 1988, is the welfare guardian for the person objected to; or

provides the Registrar with evidence that satisfies the Registrar that the person objected to is qualified to be on the roll, the name of the person objected to shall be retained on the roll and the Registrar shall notify the parties accordingly.

95D Reference of elector's objection to District Court

(1) Unless,—

(a) Within 14 days after the day on which a notice under section 95A(1) or section 96(2) of this Act is served on the person objected to, the objection is withdrawn; or

(b) The name of the person who is objected to is removed from the roll under section 95B of this Act or retained on the roll under section 95C of this Act,—

the Registrar shall refer the objection to a District Court, and shall notify the parties of the time and place appointed for the hearing.

(2) Subject to subsection (3) of this section, where any party notifies the Registrar that the party is dissatisfied with a decision of the Registrar made under section 95B or section 95C of this Act, the Registrar shall refer the objection to a District Court, and shall notify the parties of the time and place appointed for the hearing.

(3) Any notification given by a party under subsection (2) of this section shall be in writing and shall be given within 14 days after the day on which the party is notified by the Registrar under section 95B or section 95C of this Act, as the case may be.

96 Registrar's objection

(1) The Registrar for any district may at any time object to the name of any person being on the roll for the district on the ground that the person is not qualified to be registered as an elector of that district.

(2) The Registrar shall forthwith give to—

(a) The person objected to; or

(b) The welfare guardian appointed for the person objected to under section 12(1) of the Protection of Personal and Property Rights Act 1988; or

notice in writing of the objection and of such particulars of the objection as are sufficient to inform the person objected to of the ground for the objection and the reason or reasons supporting the ground for objection.

(3) The notice issued by the Registrar under subsection (2) of this section shall be served personally in accordance with the rules governing personal service contained in the District Courts Rules 1992.

(4) The notice issued by the Registrar under subsection (1) of this section shall also inform the person objected to—

(a) That he or she may forward to the Registrar a statement signed by him or her giving reasons why his or her name should be retained on the roll; and

(5) Where, after making such inquiry as he or she thinks fit, or as the Chief Registrar directs, the Registrar is unable, after making at least 2 attempts to do so, to serve notice of objection on that person personally, the Registrar shall remove the name of that person from the roll and include the name in the dormant roll maintained under section 109 of this Act.

(6) Nothing in this section affects the provisions of this Act as to the removal of names from the roll by the Registrar.

97 Procedure on reference of application or objection to District Court

(1) The following provisions of this section shall apply with respect to proceedings on the reference to a District Court of an objection under section 95 or section 96 of this Act.

(2) The Registrar of Electors, any objector, and the person objected to may appear before the Court either in person or by some person appointed by him or her in writing or by a barrister or solicitor.

(3) In the case of an objection, the person objected to may forward to the Registrar of the Court a statement signed by him or her giving reasons why his or her name should be retained on the roll, and the Court shall take any such statement into account in determining the objection.

(4) If any person objected to does not either appear or forward a statement as aforesaid, the Court shall make an order that his or her name be removed from the roll.

(5) Except as otherwise provided in this section, the name of any person objected to shall not be removed from the roll until the objection has been determined.

(6) At the hearing of an objection no grounds of objection shall be taken into account except those specified in the particulars of the objection.

(7) In any proceedings to which this section applies the Court may make such order as to costs as the Court thinks fit.

(8) Subject to the provisions of this section, the ordinary rules of procedure of the Court shall apply.

(9) The Registrar of Electors shall make any additions, deletions, and alterations to the roll that may be necessary to give effect to the order of the Court.

118 False statements or declarations

Every person who knowingly and wilfully makes a false statement in any application, certificate, or declaration for the purposes of this Part of this Act shall be liable on summary conviction to a fine not exceeding $2,000 or to imprisonment for a term not exceeding 3 months.

119 Wilfully misleading Registrar

Every person shall for each offence be liable on summary conviction to a fine not exceeding $2,000 who—

(a) Wilfully misleads any Registrar in the compilation of any roll or list, or wilfully enters or causes to be entered thereon any false or fictitious name or qualification or the name of any person whom he or she knows to be dead:

(b) Signs the name of any person, whether requested to do so or not, or any false or fictitious name to any form of application or objection for the purposes of this Part of this Act either as applicant, objector, or witness:

(c) Signs his or her name as witness to any signature upon any such form of application or objection without either seeing the signature written or hearing the person signing declare that the signature is in his or her own handwriting and that the name so signed is his or her own proper name.

120 Duty to report suspected offences

Where the Registrar believes that any person has committed an offence against section 119 of this Act, he or she shall report the facts on which that belief is based to the Police.

122 Assistance to be given to Registrar

(1) All members of the Police—

(a) Shall, at the request of the Registrar, assist the Registrar by informing him or her of the name of any person whom they have reason to believe is qualified to be registered as an elector but is not registered, or is registered but is not qualified to be registered; and

(b) Shall give the Registrar any information the Registrar requests relating to the qualifications of any person for registration as an elector.

(2) All members of the Police shall also assist the Registrar by making such inquiries and obtaining such information as he or she requests.

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