²⁰Moonen v Film & Literature Board of Review [2000] NZLR 9 , 17 p er T ipping J. T he ap proach in Moonen  to the co ncep t of reaso nable justification, although not explicitly stated, is essentially the same as the approach of the Supreme Co urt of Canada in R v O akes [1986] 1 SCR 103.      ²¹[1992] 3 NZLR 260.      ²²Paul Rishworth, Grant Huscroft, Scott Optican, Richard  Mahony The  New  Zealand  Bill of R ights, Chapter 4  “Interp reting E nactm ents”: S ections 4, 5, and 6, Oxfo rd U niversity P ress, p 1 16ff. 12 18 In Moonen v Film & Literature Board of Review, the Court of Appeal suggested an approach that those concerned with Bill of Rights issues may find helpful. That is to identify the different interpretations that are open and, if only one interpretation is plainly possible, adopt that meaning. If more than one interpretation is open, the interpretation that is the least inconsistent with the particular right or freedom is the interpretation that must be adopted. In determining which of two or more competing meanings is possible, consideration must be given to whether the limitation on the right or freedom that is contended for is justified. That assessment is also a multi- step process. Does the provision, that is the enactment alleged to limit a protected right or freedom, serve an important and significant objective? If it does, is there a rational  and  proportionate  connection  between  the  objective  and  the  provision? There must also be as little interference as possible with the right or freedom.²⁰ At its heart, it is an exercise in balancing objective against means. 19 The Moonen analysis follows on from an earlier majority decision of a strong Court of Appeal in Ministry of Transport v Noort.²¹ The Moonen approach is itself now the subject of a detailed analysis and a suggested reordering by a group of leading Bill  of  Rights  lawyers.²²  This  paper  is  not  the  place  to  debate  the  competing positions. One could, however, be forgiven for thinking that, after almost a decade and  a  half  since  the  Bill  of  Rights  Act  came  into  operation,  there  would  be  a consensus about the way in which the interpretative provisions of the Act should be applied. Regrettably, that is not so. Controversy still rages about the logical steps required in determining whether a particular enactment is or is not inconsistent with