The New Zealand police put 38 teenagers into restraint chairs between 2015 and 2020 - the youngest just 13 years old.
Restraint chairs leg, waist, wrist and chest straps to immobilise a person deemed a serious risk to themselves or others.
The Chair of the Independent Police Conduct Authority says the organisation hasn't received any complaints stemming from the incidents involving the teenagers.
But Judge Colin Doherty says in adult cases, restraint chairs are generally used on people undergoing a mental health crisis, displaying extreme violent behaviour.
He told youth affairs reporter Katie Doyle police are more often the first responders to mental health crisis callouts.
