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 France largest party in the Assembly, it did not have an absolute majority. The RPR had an alliance with the UDF, which gave them a majority. Such a situation, where the President is forced to work with a Prime Minister who is an opponent, is called a cohabitation. Édith Cresson is the only woman to have held the position of Prime Minister. Aristide Briand holds the record for number of cabinet formations as Prime Minister with 11 times. He served between 1909 and 1929 with some terms as short as 26 days. According to article 21 of the Constitution, the Prime