Infanticide in 19th-century New Zealand was difficult to assess, especially for newborn indigenous Maori infants. Resultantly, many New Zealand women who might otherwise have been sentenced to penal servitude or capital punishment in New Zealand had their sentences commuted to the lesser charge of "concealment of birth" under the . However, this relative leniency only extended to mothers of concealed or hidden infants who subsequently died. 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.