The alienation of Taranaki land was challenged by Te Whiti o Rongomai and Tohu Kākahi at Parihaka and their followers cultivated and planted confiscated land. When Bryce became Minister in 1879, two hundred Maori ploughmen were already imprisoned, and his introduction of the Confiscated Lands Inquiry and Maori Prisoners' Trials Act in 1879 allowed them to stay in prison awaiting trail for up to two years. By January 1881, his actions were being questioned in the British parliament, and he resigned to be replaced by the more moderate William Rolleston.