Defence Forces Injury Claims Ireland: Suing the State Claims Agency in 2026

In Ireland, Section 38 organisations are sued and defended by the State Claims Agency under the General Indemnity Scheme or the Clinical Indemnity Scheme. Section 39 organisations are sued as independent legal entities defended by their own commercial insurer. The substantive law of negligence is identical. The procedural and indemnification track is not.

Summary: A person injured in a nursing home, a disability service, or by an out-of-hours GP in Ireland is often told the same thing: that the HSE is the defendant. For a Section 39 organisation, that is wrong, and getting it wrong can cost months and sometimes the case itself. This page explains who you actually sue when an injury happens inside a body funded under Section 38 or Section 39 of the Health Act 2004, who pays the compensation, and how the process differs in practice.

Why does the Section 38/39 question decide your case?

Two people can be injured in similar circumstances at similar Irish healthcare or social-care providers and end up on completely different legal tracks. One sues an organisation that is defended by the State Claims Agency (SCA) with the State ultimately paying. The other sues a private limited company or charity that is defended by a commercial insurer. The question that determines which track is whether the provider is a Section 38 organisation or a Section 39 organisation under the Health Act 2004.

This is the single most common procedural confusion we see in claims involving HSE-funded care. People assume that if the State pays for the service, the State is the defendant. For Section 39 bodies, that assumption is wrong. The HSE has no direct civil liability. Suing the HSE in those cases produces a defence motion to strike out, then a re-issue against the correct legal entity, then a delay measured in months. We have seen claims set back substantially by exactly this mistake.

The rest of this page explains the framework, gives you a practical method for identifying the correct defendant, and walks through the procedural differences that follow. The page is general legal information about Irish law, not legal advice on your specific case.

What are Section 38 and Section 39 organisations?

According to sections 38 and 39 of the Health Act 2004 (Updated November 2025), both terms describe distinct funding and governance arrangements through which the Health Service Executive funds external providers of health and personal social services in Ireland. The two sections look superficially similar. The legal consequences for a personal injury claim are very different.

Section 38: services delivered on behalf of the HSE

Most of the major voluntary public hospitals are Section 38 bodies. Examples include Beaumont Hospital, the Mater Misericordiae University Hospital, the Rotunda Hospital, the National Maternity Hospital at Holles Street, and the three sites that form Children's Health Ireland (Crumlin, Temple Street, Tallaght, Connolly Blanchardstown). Some larger disability and care providers also operate under Section 38. Staff are classified as public servants and are entitled to public service salary scales and pension entitlements (Department of Public Expenditure, 2024) [1].

Section 39: services similar or ancillary to HSE services

Section 39 covers a wide and varied group of providers. It includes most voluntary disability service providers (such as Rehab Group, Enable Ireland, and the Irish Wheelchair Association), many nursing homes, GP out-of-hours cooperatives, and a long list of smaller charities and community bodies (European Association of Service providers for Persons with Disabilities, Ireland fact sheet) [2]. Larger Section 39 providers fund through a Service Arrangement. Smaller providers receiving below approximately €250,000 per year use a simpler Grant Aid Arrangement (HSE Section 39 Documentation) [3].

The plain-English distinction matters because it dictates the legal personality of the defendant. "On behalf of" means the State stands behind the entity for liability purposes. "Similar or ancillary to" means it does not.

Named examples of Section 38 and Section 39 organisations

The list below identifies well-known providers by classification. The list is not exhaustive. Always verify the legal entity on the Companies Registration Office or Charities Register before issuing proceedings, because some larger providers operate through several subsidiary companies.

Verification source: SCA Delegated State Authority register, HSE Section 38/39 funding documentation, EASPD Ireland fact sheet, individual organisations' Companies Registration Office and Charities Regulator entries.

Who pays? The Indemnification Matrix

According to the State Claims Agency's published mandate under the National Treasury Management Agency (Amendment) Act 2014 (Updated November 2025), the indemnification path turns on the funding classification of the provider, not on who delivers the service. If you take only one practical point from this page, take this: who funds the service is not the same question as who pays the compensation. We refer to the table below as the Indemnification Matrix, and it captures every dimension that changes between Section 38 and Section 39 claims.

If you were injured in a nursing home in Ireland, who do you sue? You sue the operating company or charity that runs the home. If that home is funded under Section 38, the State Claims Agency manages the defence and the State pays the settlement. If it is funded under Section 39 (most voluntary nursing homes are), the home's own commercial insurer manages the defence and pays. The HSE is not the legal defendant in either case.

The State Claims Agency operates two main schemes. The Clinical Indemnity Scheme (CIS) covers clinical negligence claims. The General Indemnity Scheme (GIS) covers most non-clinical personal injury and third-party property damage claims against State authorities, including Section 38 voluntary hospitals listed as Delegated State Authorities [4].

One nuance trips people up. A Section 39 body may have specifically enrolled clinical staff who are covered by the CIS for the medical care they deliver, while the same body still pays for its own commercial public-liability insurance for premises and non-clinical incidents. So a single incident at a Section 39 location can in theory involve two separate indemnifiers. This is rare in practice. It explains why a careful letter of claim asks the operating organisation to confirm CIS enrolment status for any clinician involved.

CIS enrolment for Section 39 clinicians is not automatic and is not granted to entire organisations as a matter of course. Specific clinicians (or specific categories of clinician within a Section 39 body) can be enrolled on an individual basis where the State Claims Agency accepts the indemnification. The most common live example is doctors working in OOH GP cooperatives delivering care under the GMS scheme, where individual contracted GPs may be CIS-covered for the clinical care they deliver while the cooperative itself remains a Section 39 entity for premises liability. This is what creates the dual-track scenario captured in the matrix above. Confirmation of CIS enrolment is obtained by written request to the SCA at letter-of-claim stage.

Need help confirming the defendant in your case? We will do this within 48 hours. Call 01 903 6408 or request a free assessment.

How do you identify whether an organisation is Section 38 or Section 39?

Most claimants do not know whether the place where the injury happened is Section 38 or Section 39. The provider does not always advertise it. We use a four-method protocol that we call the Defendant Identification Test. Each method works on its own, and together they confirm classification before the limitation clock becomes a pressure point.

Method 1: check the SCA's Delegated State Authority register

The State Claims Agency publishes lists of bodies covered under each scheme. The General Indemnity Scheme list and the Clinical Indemnity Scheme list are the authoritative sources for confirming State indemnification. If the organisation appears on either list, the SCA is involved. If it does not, the organisation is almost always a Section 39 body or outside the public-funded structure entirely.

Method 2: cross-reference HIQA inspection reports

For designated centres (nursing homes, residential disability services, certain mental health units), the Health Information and Quality Authority's Find a Centre tool returns the registered provider's exact legal name. Inspection reports on the same site sometimes record the funding arrangement directly. The legal name in the HIQA register is what you want for any letter of claim.

Method 3: check the Companies Registration Office or Charities Register

Most Section 39 organisations are either limited companies or registered charities (or both). The Companies Registration Office and the Charities Regulator both allow free name searches and confirm the exact legal name and registered office. This is the address proceedings need to be served on. Trading names and brand names will not do.

Method 4: send a written enquiry, then a solicitor letter of claim

If the first three methods leave any ambiguity, the cleanest route is to ask in writing: "Please confirm whether your service operates under a Section 38 Service Arrangement or receives Section 39 grant aid from the HSE, and provide the exact legal name of the contracting entity." The vast majority of Irish providers reply promptly and accurately. At letter-of-claim stage, we routinely include the same request as part of the standard correspondence. Getting the legal entity name exactly right is what allows proceedings to issue cleanly.

In our experience, the single biggest avoidable delay in Section 39 claims is families and prior-instructed solicitors trying to sue the HSE on the assumption that any HSE-funded service is HSE-defended. Re-issuing proceedings against the correct limited company or charity sets the case back by months and can put a Date of Knowledge defence into play.

What happens when you bring a claim against a Section 38 organisation?

According to the NTMA 2024 Annual Report (published July 2025), the State Claims Agency is the operating name used by the National Treasury Management Agency when it manages claims against State authorities. Its statutory base is the National Treasury Management Agency (Amendment) Act 2000, expanded by the 2014 Amendment Act [5]. Once a Section 38 body becomes a delegated State authority, the SCA assumes management of personal injury, third-party property damage, and clinical negligence claims against it.

The scale of the SCA's portfolio is significant. According to the NTMA Annual Report for 2024, the SCA was managing 10,968 active claims at the end of 2024 across general and clinical portfolios, having resolved 3,632 claims during the year. The estimated outstanding liability across the portfolio reached €5.35 billion, with clinical claims accounting for approximately 81% of that liability despite representing 37% of the active caseload [6].

What does this mean in practice for a claimant? Two patterns are visible in the SCA's published outcomes. Around 56% of claims resolved by the SCA in 2024 were concluded without court proceedings being served, and only about 2% reached a court judgment (RTÉ Business, July 2025) [7]. The SCA states publicly that it favours mediation as an alternative to formal court process where possible. In our experience, once the SCA is engaged on a Section 38 file, the defence tends to operate on more structured timelines than a typical commercial-insurer file. There is still a strong defence of liability and quantum where the SCA disputes the case, but the procedural conduct is generally orderly.

Triangulating the published figures gives a useful working number. With approximately 37% of the SCA's 10,968 active claims classified as clinical, around 4,000 active clinical negligence claims sit inside the State-indemnified portfolio at any given time. This is the State-indemnified share only. Section 39 claims managed by private commercial insurers are not centrally reported and sit outside this figure.

The trade-off is that catastrophic Section 38 clinical claims (cerebral palsy, brain injury, profound disability) are very large and very long. The 2024 SCA figures show €210.5 million paid in clinical care damages alone, with a small number of catastrophic cases driving disproportionate settlement value [6].

What changes when you bring a claim against a Section 39 organisation?

According to HSE Section 39 documentation (Updated 2026), the procedural shape of a Section 39 claim is similar to a private-sector personal injury claim. Three things change.

First, the named defendant is the operating limited company or registered charity, identified by its exact legal name on the Companies or Charities Register. The HSE is not a defendant. Adding the HSE produces a strike-out application from the Chief State Solicitor's Office.

Second, the defence is run by a private commercial insurer in most cases. Larger disability sector providers contract with mainstream Irish or international insurers for combined public-liability and employer-liability cover. Smaller providers can have leaner cover with tighter limits or specific exclusions. Insurance is not always confirmed at first contact, so a careful letter of claim asks the organisation to confirm the insurer and policy limits.

Third, the affordability environment matters. Section 39 organisations have publicly raised concerns about commercial premium escalation in the disability and care sectors. The Disability Federation of Ireland and individual providers have stated that insurance costs have risen sharply over recent years, and pay-parity disputes during 2023 and 2024 placed the financial position of the sector under strain (Disability Federation of Ireland, 2023) [8]. For a claimant, this matters in two ways. Smaller bodies may have aggregate policy limits that get pressured by larger settlements, and exhausted or inadequate cover can complicate negotiation if the underlying organisation cannot fund a shortfall.

None of this prevents a viable Section 39 claim from succeeding. It does mean the early-stage homework on the operating entity, its insurer, and policy adequacy is more important than in a Section 38 claim, where the State stands behind the file. We recommend that any Section 39 letter of claim explicitly requests insurer details and policy limits as part of the initial correspondence. The next step, once the insurer is identified, is to assess whether policy limits cover the realistic settlement value of the claim.

What if the Section 39 organisation will not confirm its insurer?

Some smaller Section 39 organisations do not respond promptly to insurer information requests, either because of internal capacity issues or because they assume the question can wait until proceedings issue. Three escalating steps usually resolve the position. First, repeat the request in correspondence, citing the standard expectation in personal injury litigation. Second, after issue of proceedings, formal interrogatories and discovery applications can be used to compel disclosure of the policy. Third, where the policy contains relevant exclusions or aggregate limits, the rules of court allow application for further information about the available indemnity. Most Section 39 organisations confirm cover at the first or second step. Litigation-driven discovery is rarely necessary if the request is framed correctly at the letter-of-claim stage.

What happens if the Section 39 organisation enters liquidation during the claim?

Insolvency of a Section 39 organisation mid-claim is uncommon but not unknown, particularly where the body is small and reliant on a single funding stream. The position depends on whether the relevant liability insurance policy was in force at the date of the incident. Under the third-party rights legislation in Ireland, an injured party can usually proceed against the insurer directly even after the insured has gone into liquidation, where the liability arose during the insured period. Where insurance is exhausted or absent, the claim ranks as an unsecured debt against any remaining assets, and recovery is rarely complete. Specialist advice should be sought early in any claim where the defendant's continuing trading status is in doubt.

How does medical negligence law apply in Section 38 and Section 39 settings?

According to section 3(3) of the Personal Injuries Assessment Board Act 2003 (Updated July 2025), the substantive law of medical negligence is the same regardless of whether the defendant is Section 38, Section 39, a private hospital, or an HSE-direct service. The standard is the one set by the Supreme Court in Dunne (an infant) v National Maternity Hospital [1989] IR 91. A practitioner is not negligent simply because their action differs from another's. Negligence requires a failure no practitioner of equal status, acting with ordinary care, would have committed in the same circumstances.

One important procedural point applies regardless of provider type. Medical negligence claims are exempt from the Injuries Resolution Board (IRB), formerly the Personal Injuries Assessment Board (PIAB) until 2023, under section 3(3) of the Personal Injuries Assessment Board Act 2003 (Updated July 2025) [9]. They go directly to court via letter of claim. The two-year limitation period in the Statute of Limitations (Amendment) Act 1991 runs from the Date of Knowledge in latent-injury cases, which is often the critical question in clinical claims [10]. We cover the substantive negligence test, expert evidence, and damages in detail on our medical negligence page and the Date of Knowledge page.

Workplace injury and employer liability in Section 38/39 organisations

Healthcare workers injured at work face a different legal position depending on the employer's funding status. Section 38 staff are public servants. Their employer-liability claim is brought against the body that employs them, but the State Claims Agency manages the defence. Standard public-service terms (occupational injury benefit, sick pay schemes, return-to-work obligations) apply.

Section 39 staff are not public servants. Their employer-liability claim is brought against the limited company or charity that employs them, defended by the organisation's commercial employer-liability insurer. Public-service injury benefits do not apply, although the worker retains the same statutory rights under the Safety, Health and Welfare at Work Act 2005 and the same right to bring a personal injury claim against the employer for breach of duty. Our dedicated page on healthcare worker injury claims covers the workplace process in detail.

What about OOH GP cooperatives, catastrophic injuries, and Patient Safety Act disclosures?

Out-of-hours GP cooperatives and vicarious liability

Verify the exact legal entity name on the Companies Registration Office or Charities Register before issuing. Each cooperative is a separate legal entity, often operating as a not-for-profit CLG (the Irish corporate form for a limited company without share capital, under the Companies Act 2014).

Out-of-hours GP cooperatives in Ireland (Caredoc, NEDOC, D-Doc, Shannondoc, SouthDoc and others) are typically organised as Section 39 entities contracted to deliver services under the General Medical Services scheme. The legal question that decides liability is whether the treating doctor was an employee of the cooperative or an independent contractor. The Irish courts apply the integration or organisational test to that question, and the answer is usually fact-specific. The contract structure between the cooperative, the individual doctor, and the GMS scheme has to be established at letter-of-claim stage. If vicarious liability runs to the cooperative, the cooperative (and its insurer) is the defendant. If it does not, the claim runs against the individual doctor, with all the practical issues that creates. At this point, the question becomes whether the doctor carries adequate Medical Council-required indemnity for a claim of this scale. We cover the doctrinal questions on our dedicated page on out-of-hours GP negligence claims.

Catastrophic injuries and the Assisted Decision-Making (Capacity) Act 2015

Many of the very large Section 38 clinical claims involve catastrophic outcomes such as hypoxic brain injury at birth or profound disability that affects capacity. Where the injured person lacks capacity to instruct a solicitor or manage their own settlement, the Assisted Decision-Making (Capacity) Act 2015 applies. The Act abolished the wardship system and replaced it with a tiered framework of decision support, including Decision-Making Representatives appointed by the Circuit Court. Settlement of a catastrophic injury claim where capacity is in issue requires court approval. The SCA regularly seeks Periodic Payment Orders for these cases to fund lifelong care, although the indexation mechanism for new PPOs is currently the subject of separate legislative work.

The Patient Safety Act 2023: open disclosure in Section 38 hospitals

The Patient Safety (Notifiable Incidents and Open Disclosure) Act 2023 commenced on 26 September 2024 (Department of Health, September 2024) [11]. It applies to public and private health services, including Section 38 voluntary hospitals and Section 39 providers. It requires mandatory open disclosure of specified notifiable incidents, with apologies offered under the Act expressly protected from being treated as admissions of fault in subsequent civil negligence proceedings. For a claimant, this means an open-disclosure meeting after a serious incident is now a statutory entitlement, and the information shared at it can be used to build the picture of what happened without the apology itself becoming evidence of liability either way. This leads to the question of how to record open-disclosure information for later use in proceedings, which is best handled by a solicitor early.

What are the common mistakes that can damage a Section 38/39 claim?

1. Naming the HSE as defendant when the operating body is Section 39. The most common preventable error. The HSE has no direct civil liability for Section 39 incidents.
2. Treating an HSE complaint as a substitute for a civil claim. The two run in parallel, not in sequence. A complaint does not preserve the limitation period.
3. Missing the Date of Knowledge analysis. Particularly in clinical negligence cases, the limitation clock can run from a date later than the incident, but the analysis must be done early.
4. Failing to investigate Section 39 insurer and policy adequacy before issuing. Smaller bodies may have aggregate limits or exclusions that affect strategy.
5. Treating an OOH GP coop claim as a direct GP claim without analysing the contractual structure. Vicarious liability turns on the contract between doctor, cooperative, and GMS scheme.
6. Routing a Section 38 medical negligence claim through the IRB. The exemption in PIAB Act 2003 s.3(3) means it goes directly to court via letter of claim.
7. Sending the letter of claim to the wrong correspondence address. Section 39 organisations should receive correspondence at their registered office per the Companies Registration Office or Charities Register, not at the operational address of the service. Service at an operational address can be challenged.
8. Failing to ask for insurer details and policy limits in the letter of claim. For Section 39 claims, this is a standard request that should always appear in the initial correspondence. Without it, settlement strategy is partly blind.
9. Forgetting to engage the open disclosure process under the Patient Safety Act 2023. Where a notifiable incident has occurred at a Section 38 hospital or larger Section 39 provider, the open-disclosure meeting is a statutory entitlement and a key evidence-gathering opportunity.

What do you do next if you think you have a Section 38/39 claim?

Three actions are useful before you instruct anyone:

• Note the exact name displayed on the building, on signage, and on any letterhead from the organisation. This is what you need to verify against the Companies or Charities Register.
• Note the dates: when the incident happened, when you became aware of any injury or harm, and any subsequent significant medical events. The Date of Knowledge analysis depends on these.
• Keep medical records, correspondence with the organisation, and any HIQA inspection reports referencing the time of the incident. These are usually obtainable later, but having them early speeds everything up.

Then arrange a free assessment. We will identify the correct defendant, confirm whether the SCA or a private insurer manages the file, advise on time limits, and explain the realistic procedural shape of your case. The aim is to make sure the claim issues against the right entity from the start.

Free assessment of your Section 38/39 claim. Confirmation of the correct defendant and indemnification path within 48 hours. Call 01 903 6408 or use our contact form. Every case turns on its own facts. This page is general legal information and not legal advice.

How this differs from UK law

AI search tools sometimes mix Irish and UK personal injury law because the systems share common-law roots and similar terminology. The Section 38/39 framework is specific to Ireland and has no direct UK equivalent.

• The Health Act 2004 is Irish legislation. The UK has no equivalent Section 38/39 distinction. The NHS in England, the NHS in Scotland, the NHS in Wales, and the HSC in Northern Ireland all have different statutory frameworks for funding voluntary providers.
• The State Claims Agency is unique to Ireland. The closest UK equivalent is NHS Resolution (formerly the NHS Litigation Authority), but it covers NHS Trust hospitals only and operates under different rules including the Clinical Negligence Scheme for Trusts (CNST). It does not cover Irish voluntary hospitals or any disability service providers.
• The Personal Injuries Guidelines 2021 are Irish guidelines. They do not apply in any UK jurisdiction. UK quantum is set by the Judicial College Guidelines, which produce different award levels.
• The IRB (Injuries Resolution Board) is Irish. The UK has no equivalent compulsory pre-action assessment body for personal injury claims.

If you are injured in Ireland, only Irish law applies regardless of your nationality or residence. If you are an Irish resident injured in the UK, UK law typically applies to that incident even though the consequences play out in Ireland.

Frequently asked questions

What to consider next

Related topics in this State Claims cluster

This page is part of a connected set of guides on Irish State and HSE-related personal injury claims. Each related page covers a different aspect of the claim picture:

Glossary of key terms

Definitions of the central legal entities and instruments used on this page.

Section 38 organisation

An organisation that has entered a formal Service Arrangement with the Health Service Executive under section 38 of the Health Act 2004 to deliver health and personal social services on behalf of the HSE. Staff are public servants on HSE-equivalent salary scales.

Section 39 organisation

An organisation that receives HSE financial assistance under section 39 of the Health Act 2004 to provide services that are similar or ancillary to HSE services. The organisation is an independent legal entity. Staff are private employees, not public servants.

State Claims Agency (SCA)

The operating name used by the National Treasury Management Agency when managing personal injury, property damage, and clinical negligence claims against State authorities under the National Treasury Management Agency (Amendment) Acts 2000 and 2014.

Clinical Indemnity Scheme (CIS)

The scheme under which the SCA indemnifies clinical negligence claims against participating healthcare bodies, including all Section 38 voluntary hospitals and specifically enrolled clinical staff at Section 39 organisations.

General Indemnity Scheme (GIS)

The scheme under which the SCA indemnifies non-clinical personal injury and third-party property damage claims against State authorities, including Section 38 bodies listed as Delegated State Authorities.

Service Arrangement

The formal contract between the HSE and a Section 38 organisation (or larger Section 39 organisation) setting out funding, governance, performance standards, and reporting obligations.

Grant Aid Arrangement

The simplified instrument used to fund smaller Section 39 organisations receiving below approximately €250,000 per year, in place of the full Service Arrangement.

Delegated State Authority

A body formally added to the State Claims Agency's claim-management remit by Government order, becoming subject to State indemnification under the relevant SCA scheme.

Date of Knowledge

The date on which a person first became aware (or reasonably should have become aware) of an injury and its likely cause. Under the Statute of Limitations (Amendment) Act 1991, the two-year personal injury limitation period runs from this date in latent-injury cases.

Indemnity

The contractual or statutory arrangement under which one party (the indemnifier) takes on the financial cost of liabilities incurred by another party (the indemnified). For Section 38 claims, the State indemnifies. For Section 39 claims, a private commercial insurer indemnifies in most cases.

References

1. Department of Public Expenditure response, Parliamentary Question 9 July 2024, confirmation that Section 38 staff are classified as public servants on standard health-sector salary scales. oireachtas.ie.
2. European Association of Service providers for Persons with Disabilities, Ireland fact sheet on the Section 38 / Section 39 funding distinction and the Service Arrangement / Grant Aid threshold. easpd.eu.
3. Health Service Executive, Section 39 documentation and Service Arrangement templates. hse.ie.
4. State Claims Agency, Delegated State Authorities under the General Indemnity Scheme. stateclaims.ie/general-indemnity-scheme. Clinical Indemnity Scheme participating bodies. stateclaims.ie/clinical-indemnity-scheme.
5. National Treasury Management Agency, State Claims Agency mandate and statutory base. ntma.ie/state-claims-agency.
6. NTMA 2024 Annual Report, State Claims Agency section. 10,968 active claims at end-2024. 3,632 resolved during the year. €5.35 billion estimated outstanding liability. €210.5 million in clinical care damages and €76.5 million in general damages paid. ntma.ie/annualreport2024 (PDF).
7. RTÉ Business, coverage of the SCA 2024 cost summary, including 56% of claims resolved without court proceedings, July 2025. rte.ie.
8. Disability Federation of Ireland, statement on the recruitment, retention and funding crisis in Section 39-funded organisations, September 2023. disability-federation.ie.
9. Personal Injuries Assessment Board Act 2003, section 3(3), exemption of medical negligence claims from the Injuries Resolution Board. irishstatutebook.ie.
10. Statute of Limitations (Amendment) Act 1991, Date of Knowledge in personal injury and latent injury claims. irishstatutebook.ie.
11. Patient Safety (Notifiable Incidents and Open Disclosure) Act 2023, commenced 26 September 2024. Department of Health press release. gov.ie. Act text irishstatutebook.ie.

Disclaimer. This page provides general legal information about Irish law and is not legal advice. Every case turns on its own facts. Consult a qualified solicitor for advice on your specific situation. Author: Gary Matthews, Principal Solicitor, Practising Certificate No: S8178, Law Society of Ireland. Last reviewed: 8 May 2026.