"R" v Attorney General for England and Wales [2003] UKPC 22 is a New Zealand contract law case, heard by the Privy Council acting as the final court of appeal of New Zealand and not as part of the judiciary of the UK, relating to duress and undue influence.

After the Gulf War, a Special Air Service soldier of the Bravo Two Zero patrol, known in the proceedings as "R",[1] was told to sign a confidentiality agreement or be demoted.

The New Zealand Court of Appeal denied an injunction, but allowed an account of profits and an assessment of damages for breach of contract.

'In addition, the court reviewed whether a type of relationship existed between the Crown and the Ministry of Defence that raised the presumption of undue influence.

The court found that such a relationship had in law arisen but went on to state that, for this presumption to arise, there must be a transaction that requires explanation.