It is usually a failure of the upper tailgate latch, which is located in the lower tailgate. The lower itself doesn't seem to fail.
There is nothing you can do until you get access to the inside of lower tailgate.
The process starts like this (photos copied from Disco3, link below):
Then comes the tricky part.
There's a pretty good description and more photos in this Disco3 thread by Disco_Mickey:
DISCO3.CO.UK - View topic - How To - Tailgate latch replacement
Good luck!
Cheers,
Scott


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