In New Zealand, the right of persons arrested to refrain from making a statement and to be informed of that right is contained in the Bill of Rights Act 1990, as further reflected in a practice note on police questioning issued in 2006, by then Chief Justice Sian Elias.. The Evidence Act 2006 explicitly prohibits the inference of guilt in a criminal proceeding from a defendant exercising their right to silence. At common law the leading case is "Taylor v New Zealand Poultry Board" where Justice Cooke held, "The starting point ... unless an Act of Parliament imposes or authorises the imposition of a duty to the contrary, every citizen has in general a right to refuse to answer questions from anyone, including an official."