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In New Zealand, Fell J in Stewart v Auckland Transport Board [1951] NZLR 576 at
578, distinguished Grepe v Loam on the basis that it had involved interlocutory
applications and concluded that there was no inherent jurisdiction to stop the plaintiff
issuing fresh proceedings "without some special authority". As the court explained in
AG v Reid [2000] 2 NZLR 377 at §10, the New Zealand provision dealing with
vexatious litigants (section 88A of the Judicature Act in 1965), had been inserted as a
result of the decision in Stewart v Auckland Transport Board that the court "had no
power under its inherent jurisdiction to make an order that a party should not be
permitted to commence proceedings without leave of the Court."
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