The Native Land Court was set up in the 1860s, after virtually all the South Island had been purchased by the Crown. Rangitoto ki te Tonga (D’Urville Island) was one of the relatively few South Island areas that went through the court. The title for D’Urville and adjacent islands was settled in favour of Ngāti Koata in a hearing in 1883, and further hearings in 1895 refined the list of title-holders. By 1900 much of the island had been leased by, or was under offer to, Pākehā.
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