Fathers, grandparents and "baby farmers" like Minnie Dean, the only woman to be executed in New Zealand history, and Daniel Cooper in the 1920s were viewed as more culpable for the death of such infants.
Without the complex life support technology available in the late 20th and early 21st centuries, this would often prove fatal due to the lack of sufficient infant respiratory development.
However, it is highly probable that the advent of colonialism and introduction of European transport and weapons technology affected the severity and scale of prior tribal conflicts, so this may not reflect an accurate prognosis of Māori infanticide.
Usually, if the birth had been concealed, the maximum penalty was two years imprisonment, and as Bronwyn Dalley notes, women could often plead mitigating circumstances through male sexual coercion (a "seduction" narrative), although this was not always successful.
[3]: 232 Originally, concealment arose in 17th century Anglo-Scottish law and sought to punish secret illegitimate pregnancies and childbirths in which mothers hid the bodies of the infants after birth or stillbirth.
As noted above, not all mothers were successful in pleading concealment- the cases of Phoebe Veitch and Sarah-Jane and Anna Flannagan stand out as exceptions to this general rule, although the defense was usually effective when it came to mitigated imprisonment or even acquittal, in some circumstances.
Minnie Dean and others may have been viewed as equivalents to John and Sarah Makin and Frances Lydia Alice Knorr in adjacent New South Wales in Australia, or Amelia Dyer in the United Kingdom, who were her historical contemporaries.
Bates confessed to the apparent concealment of the infant when she was apprehended, but held that it had been stillborn when she gave birth alongside the Grey River adjacent to the town.
was illiterate and had no family available in New Zealand to assist her covert pregnancy and childbirth, thus leading to her slashing her newborn baby's throat and hiding the body under her mattress in Milton in 1875.
The presiding judge in that case, Chief Justice James Prendergast, suggested three options to the jurors- they could either find Smith guilty of murder, manslaughter or insanity.
In 1878, Margaret Wilson gave birth to a daughter at Timaru's Benevolent Society, an emergency housing facility for indigent women, their infants and children, but the baby only survived for three months before it was strangled.
Postmortem medical investigation revealed that it had been alive at its birth and had several superficial scratch wounds on its trunk, and cause of death was determined to be haemorrhaging from the umbilical cord.
Doctor Thomas Porter noted that Bonnington appeared to be experiencing what might be defined today as post-partum depression, as had one of the defendant's sisters after her pregnancy and childbirth.
Bonnington was found not guilty of concealment through reason of insanity at the time of birth and although held for three months doing kitchen work at the Wellington Lunatic Asylum, she was subsequently released and returned to Blenheim.
[13] In 1895, Edward Tregear, a civil servant and local intellectual, suggested to Wellington's Evening Post newspaper that New Zealand society was responsible for the spate of infanticides in recent years of colonial history.
He was referring to the contemporary case of Mary Davis (1889), in which that Wellington domestic servant had given birth secretly, and as with Margaret Heads/Edwards had concealed the baby's body in her wardrobe.