Gray v M [1998] 2 NZLR 161 is a cited case in New Zealand regarding the legal defence of absolute privilege of matters raised in judicial proceedings that were subsequently used in defamation claims in tort.

[1] Mrs M lodged a complaint with the Methodist church about the "inappropriate behavior" of its Timaru Minister Robin J G Gray.

The matter was subsequently resolved via mediation between the parties, which amongst other things, Gray agreed to give the complainant a written apology, which he duly did.

Facing defending a potentially long and expensive defamation action, she applied, successfully in the District Court, that laying a complaint with the Complaints Committee was an absolute privilege under the Defamation Act, akin to making a similar statement in Court, and Grays action was struck out.

The Court of Appeal, sitting as a bench, disagreed, saying the Complaints Committee was not judicial, and Gray's defamation claim was reinstated.