Western Samoa became independent in 1962. Subsequent New Zealand legislation caused a significant number of Samoans already living in the country to become illegal immigrants. In 1982, the Judicial Committee of the Privy Council ruled that all Western Samoans born between 1924 and 1948 were British subjects and automatically became New Zealand citizens in 1949. This decision would have granted New Zealand citizenship for an estimated 100,000 Samoans. However, the New Zealand Parliament effectively nullified this ruling with the Citizenship (Western Samoa) Act 1982. This Act affirmed citizenship for Samoans who were already present in New Zealand before 15 September 1982. Those who enter the country after that date must become permanent residents before acquiring citizenship.