There is limited Hawaiian legal material relating to water rights in groundwater. For any understanding, it is necessary to consider the case of City Mill Company v. Honolulu Sewer and Water Commission, 30 Haw. 912 (1929). It is also necessary to consider the effect of Chapter 87B of the Revised Laws of Hawaii 1955, as amended (which was Act 122, Session Laws of Hawaii 1961), relating to the regulation of groundwater use under the administration of the Board of Land and Natural Resources. This statute assumes that the doctrine of correlative rights, rather than what has been referred to as the “common law” doctrine of absolute ownership, will be applicable to all groundwater in Hawaii.