1. The Law Association of New Zealand (TLANZ) has been granted leave to intervene in this appeal.
These submissions address two matters of general application for consideration by the Court in addition to those advanced by the applicants:
1.1. The inclusion of two further factors in determining whether leave ought to be given to appeal out of time. These are youth and the risk of impingement on unalienable rights.
1.2. Whether the manifest injustice test pursuant to s 102 of the Sentencing Act 2002 ought to be considered first for young offenders where s 104 of the Act is engaged.









