Helen Clark In 1999, Clark was involved in a defamation case in the High Court of New Zealand with Auckland orthopaedic surgeon Joe Brownlee, resulting in Clark making an unreserved apology. The case centered on a press statement issued by Clark criticising Brownlee, triggered by a constituent's complaint over the outcome of a hip replacement. Clark admitted the criticism was unjustified in that the complication suffered by her constituent was rare, unforeseen and unavoidable. Under Clark's leadership, Labour became the largest party in parliament from 1999 to 2008. Clark became the second woman to serve as Prime Minister of New Zealand, and
Prime Minister of Australia the governing party or senior coalition party elects an alternative party leader. This has resulted in the party leaders from the Country Party (now named National Party) being appointed as Prime Minister, despite being the smaller party of their coalition. This occurred when Earle Page became caretaker Prime Minister following the death of Joseph Lyons in 1939, and when John McEwen became caretaker Prime Minister following the disappearance of Harold Holt in 1967. However in 1941, Arthur Fadden became the leader of the Coalition and subsequently Prime Minister by the agreement of both coalition parties, despite being the leader of