Although the treaty had never been incorporated into New Zealand municipal law, its provisions were first incorporated into legislation as early as the Land Claims Ordinance 1841 and the Native Rights Act 1865. However, in the 1877 "Wi Parata v Bishop of Wellington" judgement, Judge Prendergast argued that the treaty was a "simple nullity" in terms of transferring sovereignty from Māori to the United Kingdom. This remained the legal orthodoxy until at least the 1970s. Māori have since argued that Prendergast's decision, as well as laws later based on it were a politically convenient and deliberate ploy to legitimise the seizure of Māori land and other resources.