Letter to Public Service Commissioner Sir Brian Roche about HRC
Re: Concerns regarding Human Rights Commission Intervention on Puberty Blocker policy
I promised a few people that I would share the letter I sent to Sir Brian Roche about the Human Rights Commission. I encourage you to do the same. The HRC is no longer fit for purpose. They are clearly incapable of exercising good, impartial governance. We do not have to accept this.
Sir Brian Roche
Public Service Commissioner
Public Service Commission | Te Kawa Mataaho
Wellington
Dear Sir Brian,
Re: Concerns Regarding Human Rights Commission Intervention on Puberty Blocker Policy
I write to express my strong condemnation and profound concern at the Human Rights Commission’s recent public statement responding to the Government’s decision to prohibit the prescription of puberty blockers for the treatment of gender dysphoria in children and adolescents. The statement, made under the authority of Commissioner Prudence Walker and published on the Commission’s website on 26 November 2025, alleges that the Government’s decision represents a “serious human rights infringement”. This claim is hyperbolic, ideologically charged, and demonstrably inconsistent with both clinical evidence and international practice.
It is essential to set out the factual context that the Human Rights Commission has chosen to ignore. Puberty blockers used for the management of gender distress are not approved by Medsafe for this purpose. Their use in this context has been entirely off-label, without the regulatory scrutiny or evidential standards ordinarily required for paediatric medical interventions. There is now a significant and growing body of clinical literature documenting serious risks, including impacts on bone density, brain development, sexual function, and long-term fertility. These concerns have been influential in policy reversals across multiple jurisdictions whose public health systems we traditionally trust, including the United Kingdom, Sweden, Norway, and Finland. Each of these countries has now prohibited or severely restricted the use of puberty blockers for treating gender dysphoria in minors due to insufficient evidence of benefit and clear evidence of harm.
The Government’s decision is therefore neither fringe nor reactionary; it reflects mainstream, cautious, evidence-based public health practice.
This makes the Human Rights Commission’s intervention all the more extraordinary. I question whether the Commission similarly intervenes every time Medsafe declines to approve a medication, or when PHARMAC determines not to fund a pharmaceutical agent. The Commission does not ordinarily treat such decisions, which are based on risk, efficacy, and regulatory standards, as “human rights infringements”. Their willingness to do so in this instance underscores a long-standing and well-documented pattern of ideological bias within the Commission on matters relating to sex and gender.
The Commission’s assertion that denying minors access to an unapproved, high-risk medical intervention constitutes a violation of human rights is not only incorrect, it inverts the very logic of child protection. If anything, children have stronger human rights protections against being prescribed drugs that carry sterilising effects and long-term developmental consequences, particularly when they are too young to fully understand those implications. The Human Rights Commission has entirely failed to acknowledge this core principle.
As a lesbian, I must also emphasise a serious concern that is often overlooked: the use of puberty blockers for gender non-conforming youth operates as a modern form of conversion therapy. Young people who would otherwise grow into healthy gay adults are being taught that their non-conformity is a sign of being “born in the wrong body”, and that their distress requires pharmaceutical suppression of natural puberty. This is a deeply regressive and homophobic ideology, and it is alarming to see our national human rights watchdog endorsing it uncritically.
I therefore raise a further matter: whether the Human Rights Commission and Commissioner Prudence Walker may be in breach of the Code of Conduct for Crown Entity Board Members (“the Code”). The Code is explicit that Board members must “use information properly”, “use care, diligence and skill”, and “be fair”, among other obligations. The Commission’s statement contains no recognition whatsoever of the substantial body of international evidence documenting the harms of puberty blockers or the regulatory status of these drugs in New Zealand. It is reckless for the Human Rights Commission to publicly make ideological assertions unsupported by clinical expertise or medical regulatory standards.
According to her profile on the HRC website, Commissioner Walker holds no clinical qualifications and appears to lack any training that would equip her to make authoritative judgments about paediatric medical treatment. That she nevertheless issued statements of this nature, statements portraying a contested and evidence-sensitive medical decision as a human rights abuse, raises legitimate questions about whether she has met her obligations under the Code. It also raises broader concerns about ideological capture within the Human Rights Commission, and its staggering deviation from impartiality.
Sir Brian, the Commission’s conduct in this matter is serious. A Crown entity charged with protecting the rights and liberties of all New Zealanders has instead issued a dangerously one-sided, factually incomplete, and ideologically driven condemnation of a lawful, evidence-based Government decision designed to protect vulnerable children.
I ask that you urgently examine whether the Human Rights Commission, and Commissioner Walker in particular, have complied with the standards set out in the Code, and whether further guidance, corrective action, or review is required to ensure the Commission fulfils its statutory role with neutrality, diligence, and respect for evidence.
I would appreciate acknowledgement of this letter and advice on the steps you intend to take.
Regards,
Ani O’Brien
I have also written to the Minister in charge of the Human Rights Commission, the Minister of Justice Paul Goldsmith. I have requested the following action:
Engage with the Human Rights Commission Board to seek an explanation for their intervention and to ensure that the Commission’s public commentary meets the standards of independence, accuracy, and neutrality required by law.
Consult with the Public Service Commissioner regarding whether the conduct of Commissioner Walker and the Commission as a whole complies with the Code.
Consider whether a performance or governance review of the Human Rights Commission is warranted, given its shift away from evidence-based, impartial analysis.
Not all heroes wear capes Ani…
Thanks for this 🙏🌹
Ani I honour your skill in writing- persuasive, direct, informed, fearlessly searching for the truth and protecting those who have no voice- and a delight to read! A true journalist/social commentator. As soon as I can work the tech I'm gonna give you some dough! Keep writing please, we need it. I'll try to follow up your letter to the commisioner with one of my own. I also seriously question the Human Rights Commissioner's 'fitness for purpose'.