Ben specialises in advice and advocacy to solve commercial, regulatory and public law problems, and has a particular interest in competition, consumer, and economic regulation matters.
Ben can advise on how to conduct or respond to regulatory investigations and public inquires. He can also assist public agencies making decisions, or private parties seeking to influence them.
Ben has worked as a trial and appellate litigator in the civil and criminal jurisdictions for nearly twenty years, appearing in the District Court, High Court, Court of Appeal and Supreme Court. He has a particular focus on prosecutions, regulatory enforcement proceedings, judicial review and statutory appeals.
Ben has worked across a range of sectors including construction, telecommunications, energy, transport, media, health, financial services, FMCG, and both local and central government.
Advisory Experience
Ben’s recent experience includes:
Competition, consumer and regulatory matters
Ben has strong established relationships with the New Zealand Commerce Commission and other regulators, having worked in the field for nearly twenty years.
Ben advises on all aspects of New Zealand competition & regulatory law including merger control, cartel investigations, abuse of market power investigations, restrictive trade practices investigations, market studies and sector specific economic regulation.
Ben also advises on all aspects of consumer law, including misleading conduct, substantiation, unfair and unconscionable conduct, and sector specific consumer regulation.
Judicial review and public decision making
Ben is experienced in public decision making in contentious, high profile and complex environments. He can assist with advice on robust and impartial information gathering, fair and lawful decision making, and dealing with potential challenges.
Investigations and inquiries
Ben can provide advice on conducting or responding to a regulatory investigation, including evidence gathering, witness interviews, and prosecution decision making. He is also experienced in working with quasi-judicial and administrative inquiries, including Ombudsman investigations.
Law Reform
Ben is experienced in the law reform process, including working with government agencies on policy and legislative design, preparing and presenting submissions at Select Committees, and implementation of legislative changes.
Disclosure of information
Ben is experienced in working with requests and complaints under the Official Information Act 1982 and Privacy Act 2020. He can also assist with disclosures of confidential or private information.
Litigation Experience
Ben has worked on litigation of all sizes, from small prosecutions to large multi-party commercial proceedings. Prior to joining the Bar in 2022, Ben was responsible for an extensive portfolio of Competition and Consumer litigation for the Commerce Commission.
Some of his significant cases as counsel in the competition, consumer and regulatory fields include:
- New Zealand’s leading appellate cases on the Fair Trading Act, Godfrey Hirst v Cavalier Bremworth [2014] 3 NZLR 611 (CA) and Commerce Commission v Steel & Tube Holdings Limited [2020] NZCA 549.
- New Zealand’s leading appellate cases on the investigatory powers of the Commerce Commission, Commerce Commission v Air New Zealand Ltd [2011] 2 NZLR 194 (CA) and AstraZeneca Ltd v Commerce Commission [2010] 1 NZLR 297 (SC).
- New Zealand’s leading case on merger clearances, Commerce Commission v Woolworths (2008) 12 TCLR 194 (CA).
- Significant appellate cases in relation to the regulation of the telecommunication and dairy industries, Vodafone v Telecom [2012] 3 NZLR 153 (SC) and Fonterra v Grate Kiwi [2012] 2 NZLR 184 (SC).
- Significant cartel cases including the ‘Cardboard’ cartel (Commerce Commission v Visy Board [2012] NZCA 383 (jurisdiction), [2013] NZHC 2097 (penalty) and Commerce Commission v Hodgson [2014] NZHC 649), and the Compressors cartel (Commerce Commission v Whirlpool SA [2011] NZHC 2109).
- Significant competition cases including Commerce Commission v Bay of Plenty Electricity (HC), Commerce Commission v New Zealand Diagnostic Group (HC), and Godfrey Hirst v Commerce Commission (HC).
- Significant fair trading prosecutions including Commerce Commission v Trustpower Limited [2016] NZDC 18850, Commerce Commission v Brand Developments Limited [2015] NZDC 21374, and Commerce Commission v Love Springs & Smart (the largest penalty against a director under the Fair Trading Act).
Outside of this work, Ben has taken a range of cases for other regulators including:
- Civil pecuniary penalty cases under the Unsolicited Electronic Messages Act 2007: Department of Internal Affairs v Image Marketing Group [2014] NZHC 139 and Department of Internal Affairs v Mansfield [2013] NZHC 2064.
- Criminal prosecutions in relation to fraud associated with the proceeds of regulated gambling, R v Cosgrave (DC) and Department of Internal Affairs v Raki (DC) (upheld on appeal in Raki v Department of Internal Affairs [2013] NZHC 3550).
- Defending a collateral challenge to the Northern Gateway toll regime, Grueber v New Zealand Transport Agency [2014] NZHC 2924.
As a Crown prosecutor, Ben prosecuted serious criminal offending on behalf of the Crown including as lead counsel in criminal trials in the District Court, and numerous criminal appeals to the High Court. Appeals of interest included Thompson v Police [2013] 1 NZLR 848 (a New Zealand Bill of Rights Act case on disorderly conduct), Alan Shore v Police [2014] NZHC 503 (counsel error) and Landmark v Police [2014] NZHC 1280 (encouragement of antisemitic desecration of graves).
At the Commerce Commission, Ben advised on a wide range of investigations and decisions, and was responsible for a range of significant proceedings that resulted, including:
- Over 70 mergers clearances and section 47 investigations, across a wide range of sectors, resulting in four successful section 47 proceedings (Commerce Commission v OfficeMax Holdings, Commerce Commission v Wilson Parking NZ, Commerce Commission v First Gas [2019] NZHC 231, Commerce Commission v Objective Corporation [2022] NZHC 1864), two clearance appeals (both of which were withdrawn), and one judicial review (withdrawn).
- Eight authorisations, including two authorisations that were unsuccessfully challenged in the High Court and Court of Appeal (Godfrey Hirst NZ Limited v Commerce Commission [2016] NZCA 560 and NZME Limited v Commerce Commission [2018] NZCA 389).
- A wide range of restrictive trade practice and cartel investigations, resulting in eight successful cartel proceedings (Commerce Commission v GEA Milfos, Commerce Commission v Ronovation, Commerce Commission v Prices Pharmacy, Commerce Commission v International Racehorse Transport, Commerce Commission v Specialised Container Services, Commerce Commission v Hutt & City Taxis, Commerce Commission v Moola, Commerce Commission v Oceanbridge [2022] NZHC 1371, Commerce Commission v Mondiale [2022] NZHC 1370), as well as the trial and appeal stages of Commission’s successful prosecution of the Hamilton Real Estate cartel, concluding with Lodge Real Estate v Commerce Commission [2020] NZSC 25.
- A range of substantial consumer prosecutions, including the Commission’s successful Steel Mesh Prosecutions, and the Commission’s successful prosecution of Vodafone over its ‘FibreX’ campaign, the Commission’s first Crimes Act case to go to trial, R v Mehta (sentence of imprisonment upheld on appeal in Mehta v R [2017] NZCA 491), and a range of significant corporate penalties including Harmoney, Youi, Bike Barn, and Reckitt Benckiser.
- Significant consumer credit prosecutions, including a campaign of successful prosecutions against mobile traders resulting in penalties in excess of $1,500,000.
Appointments
In 2022 Ben was appointed by the Solicitor-General to the Cartel Prosecutors Panel under the Commerce Act 1986.
In 2023 Ben was appointed by the New Zealand Law Society as a member of the National Standards Committee (No 2) under the Lawyers and Conveyances Act 2006.
Memberships
- New Zealand Law Society
- New Zealand Bar Association
- New Zealand Criminal Bar Association
- Competition Law and Policy Institute of New Zealand
- Law and Economics Association of New Zealand
Contact Ben Hamlin
Level 2 Solnet House
70 The Terrace
Wellington 6011
PO Box 48036
Silverstream 5142
Mobile: +64 22 067 7493
ben.hamlin@cliftonchambers.co.nz