School leaders are worried that a small but defiant group of high school bullies are headed for the courts.

The Online Safety Advisory Group - which has representatives from secondary schools, police, Netsafe, the Children's Commissioner, Human Rights Commissioner, Crown Law and the Ministry of Education - provides guidance for safe school online strategies and handling incidents involving cyberbullying.

Advisory group chairman Patrick Walsh, the principal of Rotorua's John Paul College, said online abuse by school pupils remained an extensive and growing problem.

"We're still getting complaints of cyberbullying, sextortion, sexting," said Mr Walsh.

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"There's a small group who are resistant to attempts to stop them from cyberbullying and those students will ultimately be dealt with under the Harmful Digital Communications Act."

He said schools were focused on tackling the issue through education in a carrot and stick approach.

"The carrot approach works with most students but [there is] the small group that just continually resist any attempts to change their behaviour.

"It ... tends to be a group of young males, who think that they have an entitlement to harass [others]."

But it remained a minefield for schools, with blurred jurisdictional issues over bullying taking place out of school hours and parents reluctant to see their children exposed to the justice process.

"Often [girls] who are ... evident victims of ... sexting and sextortion don't wish to lay a complaint or are not very co-operative."

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New Zealand Principals' Federation president Iain Taylor said it was not helped when parents deliberately hindered investigations.

"Some [parents] just don't want to get engaged."

Mr Walsh said latest research and what was working was to develop in teenagers a high level of empathy.