This study considers the challenges and features of law and development faced by small island developing states (SIDS) during the COVID-19 global pandemic. This research analyzes the pre- and post-pandemic situation of access to justice in SIDS to clarify the transformation of society and the critical impact of the pandemic and to consider potential negative effects and revealed features of fragile justice in small island states. In this context, this research focuses on the case study of Niue, which is a self-governing state in free association with New Zealand since 1974 and is recognized as a small island developing state by the United Nations. Niue, known as “the Rock of Polynesia,” is home to approximately 1900 people and consists of a single isolated island of only 261 square kilometers. The principal research question to be addressed is as follows: What did the COVID-19 pandemic reveal in Niue as a challenge in the context of law and development? By exploring the current situation of access to justice among people in Niue and based on interview responses with local people, government officers, and legal practitioners, this research aims to provide policy suggestions for initiatives and assistance to guarantee the right of access to justice in Niue.