89 Human Rights Commission imprisonment of Ihaka and his people wrongful and against the instructions of the Attorney General. As recently as 2011, the Te Ākitai Waiohua Iwi Authority requested the return of the missing 16 bodies. If not in body, then in soul they too were confiscated (Taonui, 9 August 2019). Under special housing legislation Fletcher Development and the Auckland City Council, without consulting with mana whenua Ngāti Māhuta – Te Ahiwaru, attempted to build a residential project at Ihumātao. Save Our Unique Landscape (SOUL), an organisation comprising the descendants of those who had been evicted from the land many years before, organised direct action and occupation of the site from 2016. SOUL protested that the land should be returned to mana whenua, given its significant historical-cultural and archaeological significance (Fernandes, 2019) and the grave injustice of the 1860s. In July 2019, SOUL was served eviction notices on the basis they were outside occupiers and not mana whenua. On 5 August 2019, dozens of police were sent to enforce the eviction just before the community’s time of prayer (Radio New Zealand, 2019). A five-hour standoff ensued. For SOUL co-founder Pania Newton, “It was very intimidating, I was concerned for the safety of the people” (Radio New Zealand, 2019). Although considered a relatively “peaceful and calm” event by SOUL (Radio New Zealand, 2019) the fundamental error of the evictions and the disproportionate police response was a repeat of the history their ancestors had suffered. Later, the Kingitanga would confirm that the occupiers were indeed mana whenua. The eventual outcome saw the government purchase the land and initiate ongoing dialogue toward an enduring solution. Institutional racism in criminal justice The intergenerational impact of colonisation, racism, white supremacy,nd over-policing the dispossession of Māori lands, and marginalisation of Māori explains the over-representation of Māori in the criminal justice system (Department of Corrections, 2007, p. 4). The imprisonment of Māori has reached a crisis point with the highest-ever number of Māori being caught in the justice pipeline (Te Uepū Hāpai i te Ora, 2019a, p. 2). The racism of colonial criminal justice He Whaipaanga Hou (1988) was a pivotal report highlighting Māori experiences of institutional racism in criminal justice. Built on Eurocentric monocultural attitudes, the criminal justice system actively oppressed Māori notions of justice and alienated Māori (Jackson, 1988; see also Webb, 2017: 687). Colonisation introduced an Anglo-Saxon centred notion of western justice based on the fundamental principle of individual responsibility. This approach minimises the personal and social circumstances of accused persons (Department of Corrections, 2007, p. 38). This means that the historical social, economic and political marginalisation of Māori, through colonisation, were not considered as factors shaping the overrepresentation of Māori in the criminal justice system (Jackson, 1988; Webb, 2017, p. 688): Rather what occurs is that Pākehā racism stereotypes Māori as racially inferior, prone to violence because of a savage cannibalistic heritage, and presumed dishonest and cunning because they are non-white and therefore impure. Consequently, the system assumes they require a white disciplinarian regime to shake out the brownness, that afflicts their core and so eagerly encourages their apprehension and punishment (Taonui, 2021). The impoverishment and urbanisation of Māori The urbanisation of Māori brought them in close proximity to Pākehā racism and the criminal justice system: Land Alienation marginalised Māori. At the turn of the twentieth century, Māori made up less than five per cent of inmates in prison. Unable to sustain their communities, between 1950 and 1980, Māori urbanised en masse. This increased the alienation of Māori, particularly young Māori, from the tikanga support of home marae. Raised in appalling, impoverished conditions, young Māori were further alienated by an education