Lord Nuku Nehasi Finefeuiaki died leaving no male heir. Than the title went to his brother, Lord Nuku Sosaia Finefeuiaki and his son, Lord Nuku Pulu Finefeuiaki. After he died, the title returned to the descendant of Lord Nuku Nehasi Finefeuiaki. Not long after the matter was taken to court. The investigation revealed, Lord Nuku Makoni Kailahi, was a descendant through the female line in three generations. The Tongan Constitution ruled him out and the title reverted to the descendants of Lord Nuku Sosaia Finefeuiaki.