Peters remained as a National backbencher, continuing to publicly criticise the party. In late 1992, when the National Party was considering possible candidates for the elections in the following year, it moved to prevent Peters from seeking renomination (under any banner). In "Peters v Collinge", Peters successfully challenged the party's actions in the High Court, and in early 1993, he chose to resign from the party and from Parliament. This prompted a by-election in Tauranga some months before the scheduled general election. Peters stood in Tauranga as an independent and won easily.