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 the United Kingdom statutory duties as Prime Minister, his name occurs in no Acts of Parliament, and though holding the most important place in the constitutional hierarchy, he has no place which is recognised by the laws of his country. This is a strange paradox." In 1905 the position was given some official recognition when the "Prime Minister" was named in the order of precedence, outranked, among non-royals, only by the Archbishops of Canterbury and York, the Moderator of the General Assembly of the Church of Scotland and the Lord Chancellor. The first Act of Parliament to mention the Premiership – albeit in