In 2005 Tūhoe activist Tame Iti shot this flag – reputedly an Australian flag which he used as a substitute for the New Zealand flag – during a Waitangi Tribunal hearing at Tauaarau marae in Bay of Plenty. He took this action to demonstrate Tūhoe anger over the treatment of iwi members by the government since the 19th century. Iti was convicted of firearms offences, but his conviction was overturned in 2007. The Court of Appeal judges ruled that his actions had been foolhardy rather than harmful.