Civil Registration (Amendment) Act 2014: Preventing Marriages of Convenience

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18th May 2020 Law Reference this

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Does the Civil Registration (Amendment) Act 2014 strike an appropriate response between the right to marry and preventing marriages of convenience?

The “Civil Registration ( amendment) Act 2014[1]” was written into Law by the president on the 4th of December 2014. The Act “amended and extended the Civil Registration Act 2004 to amend the immigration act 2003 and to provide for matters connected therewith.”[2]This Act has fundamentally change the law and “made spousal motive relevant to the validity of marriage”[3].

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The aim of this act was to prevent marriages of convenience. The act bestowed rights on Registrars to investigate an intended marriage. “A registrar who forms an opinion that an intended marriage would constitute a marriage of convenience based on the criteria listed , . “.[4]  A thorough investigation will take place. If following the investigation it is believed that the marriage is a marriage of convenience then“ a marriage registration form will not be issued and the Department of Justice and Equality will be advised….. and, consequently, there is an impediment to the marriage[5]. “Arranging a “sham marriage” for the purpose of obtaining immigration status is not a criminal offence in Ireland, but operation vantage had been largely facilitated by the enactment of the Civil Registration (Amendment) Act 2014,4 which allows An Garda Síochána to lodge an objection, and thus prevent a marriage proceeding, where there is a suspicion that it is motivated by a desire to obtain residency status in the European Union[6]

The ten grounds laid out by the act include,

a)     “if the parties to the intended marriage speak a common language;

b)     the period prior to the relevant notification of the intended marriage under this Part during which the parties to the intended marriage are known to each other;

c)      the number and frequency of meetings of the parties to the intended marriage

d)     if the parties to the intended marriage have lived together in the past or if they currently live together;

e)      the extent to which each party to the intended marriage is familiar with the personal details of the other party;

f)       the extent to which each party to the intended marriage intends to continue an existing commitment to mutual emotional and financial support of the other party to the intended marriage;

g)     the immigration status of one or each of the parties to the intended marriage who is a foreign national;

h)     other than in a case where money is paid as a dowry as appropriate to the culture of one or each party to the intended marriage, if money was paid as an inducement for the marriage;

i)       if the one or each of the parties to the intended marriage has previously been the subject of an objection under subsection (1), an opinion formed under subsection (4A) or an objection under section 59F(1) or an opinion formed under section 59F(4A);

j)       any other information regarding the intended marriage which gives reasonable grounds for considering the marriage to be a marriage of convenience.”,[7]

A marriage to convenience is in itself the complete opposite of a marriage based on love. Otherwise known as a “sham marriage” stems from selfishness or personal gain. For reasons such as money , immigration status or religious reasons.. A marriage of convenience is defined as “a marriage where at least one of the parties to the marriage (a) at the time of entry into the marriage is a foreign national and (b) enters into the marriage solely for the purpose of securing an immigration advantage for at least one of the parties to the marriage.”[8] It is a union motivated not so much by personal convenience.  Therefore, a marriage which is considered as a strong social institution relaxes its meaning will consequently create a disruption within society. “Marriage provides a unique legal status, bringing with it a host of reciprocal obligations, rights and protections. Any further changes to the Constitution must not undermine the marital family as an institution or permit the State to arbitrarily intrude on family life and violate family privacy.”[9] Humphreys J stated in the case of “KP v Minister for Justice and Equality[10] in relation to rights associated with marriages of convenience that “Legal action designed to enforce ‘rights’ deriving from a marriage of  convenience is an affront to the court and makes a mockery of the constitutional commitments to legality, human rights, and to  marriage and the family. The court is an institution of State and, while obviously not in any way to be identified with the interests of the government of the day, is certainly to be identified with values fundamental to the Constitution, the State and to an ordered society.[11]

Marriages of convenience are usually done to exploit immigration laws. Prior to the introduction of the Civil Registration (Amendment) Act 2014, non-EU residents could many an Irish citizen and automatically gain citizenship. Now steps have been put in place to stop theses marriages from occurring. However , some argue that the current law can lead to discrimination. The act does not apply to marriages between two Irish citizens. The act will only come into force in relation to marriages that occur to advance immigration status. The impediment created by the 2014 Act only arises where the intention is to gain an immigration advantage under EU free movement rules….. An investigation will however be carried out by the Irish Naturalisation and Immigration Service (INIS) if an application for family reunification is made”.[12] The INIS policy states that “Irrespective of the status of the sponsor, family reunification in all cases must be subject to proper checks and balances against immigration abuse, such as marriage of convenience, and each case must be looked at on its merits. The onus of proof as to the genuineness of the family relationship rests squarely with the applicant and sponsor whether that person is an Irish national or non-EEA national”[13]

“It indicates that a stricter test, for immigration purposes, may apply to Irish citizens than to EU citizens exercising free movement rights. The Free Movement Regulations allow denial of free movement rights on the grounds that the sole motive for the marriage was obtaining an immigration advantage. Immigration rules applying to the spouses of Irish citizens require that it be the predominant motive.. “[14]

In article 41.3.1 of the Constitution , the state promises “to guard with special care the institution of marriage , on which the family is founded , and to protect it against attack”[15]. Marriages of convenience can be seen as major threats to the core values of a marriage and therefore threaten the basis of the state. In “Ryan v Attorney General”[16] the court made the argument that “,the right to marry is an unenumerated right under Art.40 of the Constitution. Nevertheless, like all unenumerated rights, it is not absolute and is subject to limitation or restriction by the State if same is necessary and justified. For example, such a restriction or limitation is evident by regulating a minimum age to marry or prohibiting marriage between persons who are within the forbidden degree of relationship.[17]

The United States is a prime example of where marriages of conveniences occur. With such strict immigration laws and some countries even banned from entering the US many foreign nationals turn to sham marriages, also known as “green card marriages”. The United Stated have tightened restrictions regarding marriages between US citizens and foreign nations seeking citizenship or green cards. The law titled “8 USC 1154: Procedure for granting immigrant status ..Title 8-ALIENS AND NATIONALITY” sets out the law regarding immigration”. The law states that“ “Any individual who knowingly enters into a marriage for the purpose of evading any provision of the immigration laws shall be imprisoned for not more than five years, or fined not more than $250,000, or both.”[18] The law sets out many tests that individuals seeking citizenship through their spouse must go through. Individuals seeking citizenship must stay married and living in the US and apply for citizenship through the process known as naturalisation. “Naturalization is the manner in which a person not born in the United States voluntarily becomes a U.S. citizen[19]. There is also a number of other requirements such as good moral character , ability to read and write in English and the ability to pass a US civics test. “At the two-year mark of the relationship, immigration officials review the marriage to see if the couple is still together. Those spouses that satisfy officials of the bona fides of their relationship get approved for permanent status. Those who fail are required to leave the country.”[20]  Another requirement which differs from that of the laws in Ireland is the signing of an Affidavit of support to sponsor a foreign spouse. “Filing such a document imposes a 10-year liability on the sponsor for certain types of government-based financial assistance that the foreign spouse – and the spouse’s children – may access in the future”[21]Detecting marriage frauds is a top priority for U.S.Citizenship and Immigration Services) and its affiliated agency, Immigration and Customs Enforcement ,also known as ICE. Government officers still quote a survey from the 1980s which found that up to 30% of marriages between aliens and U.S. citizens are suspect. “[22]

 

There is also a more woeful side of sham marriages. Many individuals in poorer Middle Eastern and Asian countries attempt to flee to western countries to avoid violence or religious persecution. There is also cases of faking legitimate relationships where there was no actual relationship exists. After the After the objective is achieved they divorce. The introduction of the “Immigration of Marriage Fraud Amendment Acts, 1986” in the USA has attempted to combat these situations. In Ireland with the introduction of the new act has seen major changes within the country. The Irish Examiner newspaper reported that in 2019 “the Civil Registration Service investigated 41 weddings last year as suspected “marriages of convenience”, with 20 ceremonies ultimately prevented from proceeding.”[23]According the department: “Marriages of this nature have been us[24]ed as a means of circumventing national and EU immigration controls in many jurisdictions.”[25]

The current act in place stemmed from the decision of the European court in the case of Case of “ Metock and Ors v Minister for Justice, Equality and Law Reform”[26].  Prior to this case the Irish courts transferring “Directive 2004/38/EC” [27] A family member of a European union citizen who reside outside the EU may join that citizen in the Republic of Ireland only if they are currently living in another country within the European Union. In this case the Court found that “if EU citizens were not allowed to lead a normal family life in the host Member State, the exercise of their guaranteed freedoms would be seriously obstructed, since they would be discouraged from exercising their rights of entry into and residence in, that Member State. “[28].   Furthermore, “This interpretation implied that third country nationals, not lawfully in the EU, could potentially regularise their position and gain residency status by marrying EU citizens exercising free movement rights.”[29] The European Court of Justice also emphasised in their judgment that the Directive develops the current rights of EU citizens rather than further restrict laws that were put in place beforehand.  “The Directive does not require the non-EU spouse to have been lawfully resident in the EU prior to exercising free movement rights”[30]. The rulings of “ Minister voor Vreemdelingenzaken en Integratie V R.N.G. Eind”[31]and “The Queen v Immigration Appeal Tribunal et Surinder Singh, ex parte Secretary of State for Home Department”[32]  further verify that non-EU residents are still entitled to the same rights in relation to family status as one would enjoy elsewhere in the European Union.

In the case of “Izmailovic Anor -v- Commissioner of An Garda Síochána & Anor “[33].A Lithuanian woman intended to marry an Egyptian man who had been unsuccessfully applied for asylum and was consequently going to be deported. When attempting to marry “two officers from the Garda National Immigration Bureau arrived and gave a letter to the registrar from a chief superintendent objecting to the marriage on the grounds that it was a marriage of convenience and that the matter was being investigated by the bureau”[34].Justice Hogan ruled that “There was no impediment to the marriage of a Lithuanian woman to an Egyptian failed asylum seeker, which would have been valid in Irish law even if it were a marriage of convenience. The arrest of the man was unlawful, and he was ordered to be released…. While a plurality of motives would not invalidate an otherwise lawful arrest, this was not the case where the main object of the arrest was to prevent a person exercising a right which, once exercised, would mean he could no longer be validly arrested, Mr. Justice Hogan said.”[35]. Deirdre McGowan further stated on the case that “a situation such as Izmailovic, the non-EU spouse would gain a reprieve on an existing deportation order pending investigation of the circumstances of the marriage, but ultimately, if the marriage was found to have been entered into for the sole purpose of obtaining an immigration advantage, residency could be refused, or revoked if already granted…. The combined effect of Metock, Izmailovic and Igunma was to create a route to lawful residence for non-EU nationals. Marriage to an EU citizen exercising free movement rights in Ireland could, at the very least, offer a reprieve from existing deportation orders issued pursuant to the Immigration Acts. The State was powerless to prevent such marriages in the absence of a specific legal authority to do so.”[36]

[37]

The outcome of the “Izmailovic Anor -v- Commissioner of An Garda Síochána & Anor”[38]is quite conflicting to the judgment of the case of “McHugh V Minister for Justice and Equality”[39].  As Deirdre McGowan explains “a marriage between an Irish citizen not exercising free movement rights and a non-EU national will not automatically invalidate any outstanding deportation orders or immigration proceedings”[40].  Hogan J ruled that in the case of “Izmailovic Anor -v- Commissioner of An Garda Síochána & Anor”[41]if the marriage was to go ahead the applicant would gain rights under the free movemnet directive to live within the Republic of Ireland. This did not occur in “McHugh V Minister for Justice and Equality”[42].

In the case of “Gorry v Minister for Justice and Equality”[43]the main question throughout the case was if an Irish citizen is subject to rights under Article 41. The court ruled  that an Irish Citizen does not inherently receive rights to allow their spouse reside with them. They further stated that  “the right to control aliens, their entry into the State, their departure, and their activities within the State, is part of the inherent power of the State as a sovereign State.”[44] The court advised the minister to reflect on the rights of married couples under the Irish constitution and the rights of individual Irish citizens under the constitution and subsequently calculate theses rights against the State’s best Interests. This will consequently lead the state to a position on a non-EU citizens right to reside in Ireland with their Irish Spouse. “At issue inter alia was the correct approach required of a decision-maker in relation to an immigration decision concerning a non-national spouse of an Irish citizen where the Irish citizen is relying upon rights conferred or protected by the Constitution (in particular Art.41) and both spouses are relying on rights under art.8 of the European Convention on Human Rights “.[45] The final decision did not provide rights to Irish citizens to live in harmony with their spouses, Although the judgment did shed light on the duty of the Irish state to view every case individually and consequently delivers a high threshold that a state must meet to show that the refusal of this individual to reside in the state is in the state’s best interest..

In future proceedings “ It may accordingly be appropriate to re-state some key legal propositions in this area. Before doing so, it is important to stress that the analysis which follows is premised entirely on the existence of a valid and regular marriage which would be so recognised under the law of this State. It also assumes that the marriage in question is a genuine and subsisting one.”[46]

 

The main question which remains is that if the “Civil Registration ( amendment) Act 2014” strikes a balance between the right to marry and preventing marriages of convenience.  “Anne Staver has identified a trend toward increasing scrutiny of family relationships across the EU as countries attempt to ensure relationships are “real”, and the 2014 Act certainly reflects this movement. It also creates a distinction between Irish and other EU citizens in relation to the validity of marriage, a type of reverse discrimination that creates problems for legal certainty and equal treatment.”  The addition of this “extra hurdle” or “impediment” to marriage has led to the topic of discrimination being thrown around. As we have seen from the outcome of various cases, the threshold of rejecting one of the core rights to being a human being “the right to marry” is a high one. Therefore this attempt on prevent marriages of convenient which seek to undermine one of the essential parts of society is justified. I t therefore is proportionate in striking a balance between the right to marry and preventing marriages of convenience.

Bibliography

Journal Articles

  1. Deirdre Mc Gowan, ’Irish Journal of Family Law’ [2016] 23(2) Impeding Free Movement with Marriage Law: The Civil Registration (Amendment) Act 2014 1
  2. Caroline Bergin-cross, ’The Evolution of the Definition of Family and Marriage under the Irish Constitution’ [2015] (2) Irish Journal of Family Law <https://login-westlaw-ie.dcu.idm.oclc.org/maf/wlie/app/document?src=toce&docguid=I566F5F630733469BA8EAB9D524001478&crumb-action=append&context=18> accessed 31 July 2019
  3. Estelle Feldman, ‘Constitutional Law’ (2017) (1 )Annual review of Irish Law

Cases

  1. Case C-127/08 – Metock and Ors v Minister for Justice, Equality and Law Reform
  2. Izmailovic Anor -v- Commissioner of An Garda Síochána & Anor (2011) IEHC 3
  3. KP v Minister for Justice and Equality [2017] IEHC 95
  4. GLADYS RYAN Plaintiff  v. THE ATTORNEY GENERAL Defendant. (1962. No. 913 P.)

5.      Case C-291/05 Minister voor Vreemdelingenzaken en Integratie v R.N.G. Eind

6.      The Queen v Immigration Appeal Tribunal et Surinder Singh, ex parte Secretary of State for Home Department.

7.      Gorry v Minister for Justice and Equality [2017] IECA 282

Blogs

  1. Civil Registration (Amendment) Act 2014’ (Houses of the Oireachtas, 4th December 2014)<https://www.oireachtas.ie/en/bills/bill/2014/71/> accessed 14 July 2019
  2. ‘Civil Registration Act Commencement Order’ (Welfareie, 18/08/2015) <https://www.welfare.ie/en/pressoffice/Pages/pr180815.aspx>accessed 14 July 2019
  3. Case C-127/08 – Metock and Ors v Minister for Justice, Equality and Law Reform’ (European Migration Network, .)<http://emn.ie/cat_search_detail.jsp?clog=6&itemID=160> accessed 30 July 2019
  4. Ilona bray, ’What Is Marriage Fraud Under US Immigration Law?’ (NOLO, .) <https://www.nolo.com/legal-encyclopedia/free-books/fiance-marriage-visa-book/chapter1-6.html> accessed 31 July 2019
  5. §1325 Improper entry by alien’ (United States Code, ,) <http://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title8-section1325&num=0&edition=prelim> accessed 14 July 2019
  6. US homeland security, ’Naturalization Information’ (US Citizen and Immigration Services, ,)<https://www.uscis.gov/citizenship/educators/naturalization-information> accessed 27 July 2019

Articles

  1. Marriage ‘of convenience’ not illegal and man’s arrest ruled unlawful’ (The Irish Times, march 11th)<https://www.irishtimes.com/news/crime-and-law/marriage-of-convenience-not-illegal-and-man-s-arrest-ruled-unlawful-1.565276>accessed 31 July 2019
  2. Noel Baker, ’The Irish Examiner’ (,, April 27th 2019) <https://www.irishexaminer.com/breakingnews/ireland/20-marriages-of-convenience-blocked-last-year-920316.html> accessed 27 July 2019
  3. AndyJ semotiuk, ’Immigration And Marriage: What Happens If You Marry Or Divorce A Foreign Spouse?’ [November 17th 2014] 1(1) Forbes<https://www.forbes.com/sites/andyjsemotiuk/2014/11/17/immigration-and-marriage-what-happens-if-you-marry-or-divorce-a-foreign-spouse/#1e78ae8b4ef9> accessed 27 July 2019

Legislation

  1. Bunreacht na hEireann 41.3.1
  2. Civil Registration (Amendment) Act 2014, S18
  3. Department of Justice and Equality, Policy Document on Non-EEA Family Reunification (2013), 22.

[1] Civil Registration ( amendment) Act 2014

[2] Civil Registration (Amendment) Act 2014’ (Houses of the Oireachtas, 4th December 2014)<https://www.oireachtas.ie/en/bills/bill/2014/71/> accessed 14 July 2019

[3] Deirdre Mc Gowan, ’Irish Journal of Family Law’ [2016] 23(2) Impeding Free Movement with Marriage Law: The Civil Registration (Amendment) Act 2014 1

[4] ‘Civil Registration Act Commencement Order’ (Welfareie, 18/08/2015) <https://www.welfare.ie/en/pressoffice/Pages/pr180815.aspx>accessed 14 July 2019

[5] Civil Registration Act Commencement Order’ (Welfareie, 18/08/2015) <https://www.welfare.ie/en/pressoffice/Pages/pr180815.aspx>accessed 14 July 2019

[6] Deirdre Mc Gowan, ’Irish Journal of Family Law’ [2016] 23(2) Impeding Free Movement with Marriage Law: The Civil Registration (Amendment) Act 2014 1

[7] Civil Registration (Amendment) Act 2014, S18

[8] Civil Registration (Amendment) Act 2014, S18

[9] Caroline Bergin-cross, ’The Evolution of the Definition of Family and Marriage under the Irish Constitution’ [2015] (2) Irish Journal of Family Law <https://login-westlaw-ie.dcu.idm.oclc.org/maf/wlie/app/document?src=toce&docguid=I566F5F630733469BA8EAB9D524001478&crumb-action=append&context=18> accessed 31 July 2019

[10] KP v Minister for Justice and Equality [2017] IEHC 95

[11] KP v Minister for Justice and Equality [2017] IEHC 95

[12] Deirdre Mc Gowan, ’Irish Journal of Family Law’ [2016] 23(2) Impeding Free Movement with Marriage Law: The Civil Registration (Amendment) Act 2014 1

[13] Department of Justice and Equality, Policy Document on Non-EEA Family Reunification (2013), 22.

[14] Deirdre Mc Gowan, ’Irish Journal of Family Law’ [2016] 23(2) Impeding Free Movement with Marriage Law: The Civil Registration (Amendment) Act 2014 1

[15] Bunreacht na hEireann 41.3.1

[16] GLADYS RYAN Plaintiff  v. THE ATTORNEY GENERAL Defendant. (1962. No. 913 P.)

[17] Caroline Bergin-cross, ’The Evolution of the Definition of Family and Marriage under the Irish Constitution’ [2015] (2) Irish Journal of Family Law <https://login-westlaw-ie.dcu.idm.oclc.org/maf/wlie/app/document?src=toce&docguid=I566F5F630733469BA8EAB9D524001478&crumb-action=append&context=18> accessed 31 July 2019

[18] §1325 Improper entry by alien’ (United States Code, ,) <http://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title8-section1325&num=0&edition=prelim> accessed 14 July 2019

[19] US homeland security, ’Naturalization Information’ (US Citizen and Immigration Services, ,)<https://www.uscis.gov/citizenship/educators/naturalization-information> accessed 27 July 2019

[20] AndyJ semotiuk, ’Immigration And Marriage: What Happens If You Marry Or Divorce A Foreign Spouse?’ [November 17th 2014] 1(1) Forbes<https://www.forbes.com/sites/andyjsemotiuk/2014/11/17/immigration-and-marriage-what-happens-if-you-marry-or-divorce-a-foreign-spouse/#1e78ae8b4ef9> accessed 27 July 2019

[21] AndyJ semotiuk, ’Immigration And Marriage: What Happens If You Marry Or Divorce A Foreign Spouse?’ [November 17th 2014] 1(1) Forbes<https://www.forbes.com/sites/andyjsemotiuk/2014/11/17/immigration-and-marriage-what-happens-if-you-marry-or-divorce-a-foreign-spouse/#1e78ae8b4ef9> accessed 27 July 2019

[22] Ilona bray, ’What Is Marriage Fraud Under US Immigration Law?’ (NOLO, .) <https://www.nolo.com/legal-encyclopedia/free-books/fiance-marriage-visa-book/chapter1-6.html> accessed 31 July 2019

[23] Noel Baker, ’The Irish Examiner’ (,, April 27th 2019) <https://www.irishexaminer.com/breakingnews/ireland/20-marriages-of-convenience-blocked-last-year-920316.html> accessed 27 July 2019

[24]

[25] Noel Baker, ’The Irish Examiner’ (,, April 27th 2019) <https://www.irishexaminer.com/breakingnews/ireland/20-marriages-of-convenience-blocked-last-year-920316.html> accessed 27 July 2019

[26] Case C-127/08 – Metock and Ors v Minister for Justice, Equality and Law Reform

[27]

[28] Case C-127/08 – Metock and Ors v Minister for Justice, Equality and Law Reform’ (European Migration Network, .)<http://emn.ie/cat_search_detail.jsp?clog=6&itemID=160> accessed 30 July 2019

[29] Deirdre Mc Gowan, ’Irish Journal of Family Law’ [2016] 23(2) Impeding Free Movement with Marriage Law: The Civil Registration (Amendment) Act 2014 1

[30] Deirdre Mc Gowan, ’Irish Journal of Family Law’ [2016] 23(2) Impeding Free Movement with Marriage Law: The Civil Registration (Amendment) Act 2014 1

[31] Case C-291/05 Minister voor Vreemdelingenzaken en Integratie v R.N.G. Eind

[32] The Queen v Immigration Appeal Tribunal et Surinder Singh, ex parte Secretary of State for Home Department.

[33] Izmailovic Anor -v- Commissioner of An Garda Síochána & Anor  (2011) IEHC 32.

[34] Marriage ‘of convenience’ not illegal and man’s arrest ruled unlawful’ (The Irish Times, march 11th)<https://www.irishtimes.com/news/crime-and-law/marriage-of-convenience-not-illegal-and-man-s-arrest-ruled-unlawful-1.565276>accessed 31 July 2019

[35] Marriage ‘of convenience’ not illegal and man’s arrest ruled unlawful’ (The Irish Times, march 11th)<https://www.irishtimes.com/news/crime-and-law/marriage-of-convenience-not-illegal-and-man-s-arrest-ruled-unlawful-1.565276>accessed 31 July 2019

[36] Deirdre Mc Gowan, ’Irish Journal of Family Law’ [2016] 23(2) Impeding Free Movement with Marriage Law: The Civil Registration (Amendment) Act 2014 1

[37] Deirdre Mc Gowan, ’Irish Journal of Family Law’ [2016] 23(2) Impeding Free Movement with Marriage Law: The Civil Registration (Amendment) Act 2014 1

[38] Izmailovic Anor -v- Commissioner of An Garda Síochána & Anor (2011) IEHC 32.

[39]

[40] Deirdre Mc Gowan, ’Irish Journal of Family Law’ [2016] 23(2) Impeding Free Movement with Marriage Law: The Civil Registration (Amendment) Act 2014 1

[41] Izmailovic Anor -v- Commissioner of An Garda Síochána & Anor (2011) IEHC 32.

[42]

[43] Gorry v Minister for Justice and Equality [2017] IECA 282

[44] Gorry v Minister for Justice and Equality [2017] IECA 282

[45] Estelle Feldman, ‘Constitutional Law’ (2017) 1 Annual review of Irish Law

[46] Estelle Feldman, ‘Constitutional Law’ (2017) 1 Annual review of Irish Law

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