Lieutenant-Colonel Walter Gudgeon (seated, left), a New Zealander appointed as British resident commissioner in the Cook Islands in 1898, was photographed with the islands' chief justice (seated, right) in 1900. As colonial control was imposed, the authority of indigenous leaders was considerably weakened, and their judicial role was reduced to making local regulations which had to be approved by the resident commissioner. By 1902 Gudgeon had become chief justice and chief judge of the Cook and Other Islands Land and Titles Court.

For Gudgeon, who had fought in the New Zealand wars and worked for years as a Native Land Court judge, New Zealand’s ‘success’ in dealing with Māori gave it the right – if not the responsibility – to govern all Polynesians. He remained in the Cook Islands until 1909, becoming notorious for belittling Cook Island Māori and favouring his friends and relatives.