 The decision was based on common law and the Treaty of Waitangi (1840).Chapman J went farther than any judge—before or since—in declaring that aboriginal title "cannot be extinguished (at least in times of peace) otherwise than by the free consent of the Native occupiers".The New Zealand Parliament responded with the Maori Lands Act 1862 and the Native Rights Act 1865 which established the Native Land Court (today the Māori Land Court) to hear aboriginal title claims, and—if proven—convert them into freehold interests that could be sold to Pākehā (New Zealanders of European descent).