Supreme Court Personal Injury Decisions 2026: The Live Tracker, Kirwan in Action, and the 2025–2026 Doctrinal Reformulations
Author: Gary Matthews, Principal Solicitor — Law Society of Ireland Practising Certificate No. S8178 · 3rd Floor, Ormond Building, 31–36 Ormond Quay Upper, Dublin D07 · ·
Table of Contents
- 2026 in Context
- Kirwan v Connors [2025] IESC 21
- Dillon v Irish Life Assurance plc [2025] IESC 37
- Power v Telia Company AB [2025] IESC 55
- Kirwan in Practice: 2025–2026 Applications
- The Doctrinal Framework
- The Published [2026] IESC Sequence
- 2026 Legislative and Regulatory Context
- Pending Appeals and What to Watch
- Practitioner Implications
- Key Terms Used on This Page
- Frequently Asked Questions
- Related Cases, Legislation, and Resources
- References
2026 in Context: Why This Year is About Enforcement, Not New Doctrine
Through the first half of 2026 the Irish Supreme Court has handed down nineteen substantive judgments. None of them disposes of a classical personal injury appeal. That silence is itself the story. The decisions actively reshaping personal injury practice in 2026 are three Supreme Court rulings handed down in 2025: Kirwan v Connors & Ors [2025] IESC 21, Dillon v Irish Life Assurance plc [2025] IESC 37, and Power v Telia Company AB & ors [2025] IESC 55. The High Court judgments now applying them complete the picture.
Three doctrinal currents converge in 2026. The first is the post-Delaney consolidation. The Personal Injuries Guidelines have been confirmed as legally binding by the Supreme Court in Delaney v PIAB & Ors [2024] IESC 10. The "no reasonable proportion" departure test has settled. The 16.7% inflationary uplift recommended by the Judicial Council in early 2025 remains unenacted by the Oireachtas. The second is the Kirwan reformulation of the test for dismissal for delay, which has already begun to terminate long-warehoused personal injury claims in the High Court. The third is the boundary clarification in Dillon. Dillon routes pure emotional-distress claims out of the Injuries Resolution Board (IRB; formerly the Personal Injuries Assessment Board or PIAB until 2023) framework and into the ordinary civil courts under section 117 of the Data Protection Act 2018.
For practitioners, the practical effect is that 2026 is the year when several years of doctrinal preparation begin to bite. The Guidelines floor general damages; Kirwan tightens case-management discipline; Dillon redirects non-injury distress claims. The Supreme Court has not needed to revisit the underlying framework — the lower courts are now applying it. This page tracks both the framework and the applications.
Kirwan v Connors [2025] IESC 21: The New Test for Dismissal for Delay
In one sentence: Kirwan v Connors [2025] IESC 21 reformulates the test for striking out personal injury and other civil proceedings for inordinate and inexcusable delay, replacing the 1996 Primor framework with a sliding scale anchored on two, four and five years of total inactivity.
Headline 2025 decision The Supreme Court's reformulation of the Primor v Stokes Kennedy Crowley test in Kirwan v Connors & Ors [2025] IESC 21 is the most consequential procedural development in Irish personal injury litigation in three decades. A seven-judge panel sat. Four judgments were delivered — by O'Donnell CJ, Hogan J, Collins J and Murray J — with the majority position carried by O'Donnell CJ and Hogan J. The Court anchored the test for dismissal for want of prosecution in Order 122 Rule 11 of the Rules of the Superior Courts. It shifted the focus from defendant-side prejudice to the passage of time itself.
Case capsule — Kirwan v Connors & Ors [2025] IESC 21
- Parties
- Brendan Kirwan (Plaintiff) v Connors & Ors (Defendants — including solicitor defendants)
- Court
- Supreme Court (extended seven-judge panel: O'Donnell CJ, Dunne, Charleton, O'Malley, Hogan, Murray and Collins JJ)
- Date of judgment
- 30 May 2025
- Citation
- [2025] IESC 21
- Judgments delivered
- Four — O'Donnell CJ, Hogan J, Collins J and Murray J. Majority position (test reformulation) carried by O'Donnell CJ and Hogan J, who applied and restated the four-tier framework formulated by Murray J; Collins J wrote separately dissenting on discrete issues. Outcome unanimous: appeal dismissed.
- Primary source
- bailii.org/ie/cases/IESC/2025/2025IESC21 · courts.ie
Holding (operative): The Primor test for dismissal for inordinate and inexcusable delay has been reformulated under Order 122 Rule 11 RSC. Defendants are no longer required to prove specific prejudice as the dominant factor in long-delay cases; the passage of time itself, against a sliding-scale framework, may justify dismissal.
From Primor (1996) to Kirwan (2025): What Changed
Under the Primor test as it had been understood since 1996, a defendant seeking strike-out for delay had to prove three elements. The delay must be inordinate. It must be inexcusable. And the balance of justice must favour dismissal. The third element typically required defendants to demonstrate specific, tangible prejudice — missing witnesses, lost evidence, faded memories.
The reformulated Kirwan approach retains the inordinate-and-inexcusable threshold but rebases the balance of justice on the corrosive effect of delay on the administration of justice generally, not solely on the defendant's evidentiary position. Hogan J anchored the jurisdiction in Order 122 Rule 11 RSC and observed that Primor had become ineffective at deterring delay. All seven judges agreed that the appeal should be dismissed and that the Primor test required reformulation, with O'Donnell CJ noting that the Rules of the Superior Courts should be revised to clarify when proceedings may be struck out for want of prosecution. Collins J wrote a separate judgment dissenting on discrete issues — most notably his view that defendants share responsibility to progress litigation against them, a view the majority did not adopt.
| Element of the test | Primor (1996) | Kirwan (2025) |
|---|---|---|
| Statutory anchor | Inherent jurisdiction | Order 122 Rule 11 RSC plus inherent jurisdiction |
| Defendant's burden | Prove inordinate + inexcusable delay + specific prejudice | Inordinate + inexcusable still required; prejudice reduced — passage of time itself may suffice |
| Temporal benchmarks | None (case-by-case, no time pivots) | Sliding-scale pivots at 2, 4, and 5 years (the Kirwan 2-4-5 Threshold Map) |
| Effect of defendant inactivity | Capable of amounting to acquiescence | Not acquiescence absent affirmative encouragement to delay |
| Onus of progression | Implicit on plaintiff; defendant prompt expected | Explicitly on plaintiff; defendant under no duty to prompt |
| Result at 5+ years inactive (oral-evidence claim) | Strike-out available where prejudice shown | Strike-out presumptive absent exceptional circumstances |
| Underlying rationale | Defendant's evidentiary position | Administration of justice generally |
The shift is not a clean break — the inordinate-and-inexcusable threshold survives — but the burden distribution has fundamentally inverted at the longer timescales.
The Sliding-Scale Thresholds: The Kirwan 2-4-5 Threshold Map
The reformulation introduces predictable temporal benchmarks. Murray J formulated the four-tier sliding-scale framework; O'Donnell CJ applied and restated it at paragraph 26 of his judgment. Periods under approximately two years of complete inactivity remain at the high Ó Domhnaill v Merrick-type prejudice threshold. From approximately two years, additional factors begin to weigh against the plaintiff. From four years, the balance shifts firmly toward dismissal, particularly where oral evidence is material. At five years of cumulative inactivity, dismissal is the presumptive outcome absent compelling justification — described by the Court as a "pressing exigency of justice" engaging exceptional circumstances such as serious procedural misconduct on the defendant's part.
| Inactivity period | Dominant approach | Burden shifting |
|---|---|---|
| Under 2 years | Strike-out limited to abuse of process or substantial Ó Domhnaill-type prejudice | Defendant bears full burden |
| 2 years (the first pivot) | Additional factors weigh against plaintiff; dismissal increasingly available | Defendant burden softening |
| 4 years (the second pivot) | Presumption of dismissal where oral evidence is material; plaintiff must show compelling reasons to continue | Burden effectively shifted |
| 5 years (the third pivot) | Broad judicial discretion to dismiss; continuation requires exceptional circumstances | Plaintiff burden |
One nuance the headline coverage routinely misses: the framework is articulated as a case-by-case assessment having regard to all the facts and circumstances, not a mechanical timer. Five years of inactivity in a documentary commercial dispute is not the same as five years in an oral-evidence personal injury claim where the credibility of witnesses is the principal issue. The judgment is clear that the Court retains the discretion to reach different outcomes on similar facts.
Dillon v Irish Life Assurance plc [2025] IESC 37: The Personal Injury Threshold
In one sentence: Dillon v Irish Life Assurance plc [2025] IESC 37 held unanimously that a claim solely for distress, upset, anxiety or inconvenience — falling short of a recognised psychiatric disorder — is not a "personal injury" within the meaning of the Personal Injuries Assessment Board Act 2003 and does not require IRB authorisation before issuing proceedings.
Threshold case The Supreme Court's unanimous judgment in Dillon v Irish Life Assurance plc [2025] IESC 37 redrew the boundary between personal injury claims and non-injury civil claims for emotional disturbance. Murray J delivered the judgment. He held that emotional disturbance falling short of a medically recognised psychiatric disorder is not a "personal injury" within the meaning of the Personal Injuries Assessment Board Act 2003. Such claims fall outside the IRB authorisation regime entirely.
Case capsule — Dillon v Irish Life Assurance plc [2025] IESC 37
- Parties
- Patrick Dillon (Plaintiff/Appellant) v Irish Life Assurance plc (Defendant/Respondent)
- Court
- Supreme Court (unanimous)
- Date of judgment
- 24 July 2025
- Citation
- [2025] IESC 37
- Leading judgment
- Murray J
- Primary source
- bailii.org/ie/cases/IESC/2025/2025IESC37 · courts.ie
Holding (operative): A free-standing claim in tort or contract for damages for distress, upset, anxiety and inconvenience falling short of a recognised psychiatric disorder is not a "personal injury" action within the meaning of the PIAB Act 2003. No IRB authorisation is required to issue proceedings. Awards for such non-material loss will be "very, very modest".
What Counts as "Personal Injury" After Dillon
The Court read section 2(1) of the Civil Liability Act 1961 and the Personal Injuries Assessment Board Act 2003 against the common-law definition of personal injury. Murray J held (at paragraphs 27–28 of his judgment) that the statutory definitions reflect — but do not supplant — the common-law meaning: injury "of such substance" as to complete the tort of negligence or to support an award of damages on a standalone basis in another tort. Emotional disturbance unaccompanied by a recognised psychiatric injury does not clear that bar. The plaintiff's negligence claim was therefore misconceived because the "damage" element of the tort was absent.
The boundary is significant in three operational respects. First, claims pleaded solely for distress, anxiety, upset or inconvenience can now proceed directly to court without IRB authorisation under section 12 of the PIAB Act 2003. Second, the proper procedural route for non-material data-breach damages is the sui generis statutory claim under section 117 of the Data Protection Act 2018 implementing Article 82 of the GDPR. Third, where a recognised psychiatric injury is alleged, the claim reverts to ordinary personal injury treatment. IRB authorisation is required. The Personal Injuries Guidelines apply. The test from Kelly v Hennessy [1995] 3 IR 253 for nervous shock controls.
The "Very, Very Modest Awards" Warning
The Court's procedural concession carries a substantive caveat. Murray J was explicit (at paragraph 56 of his judgment) that claims falling outside the personal-injury category should not anticipate substantial damages. The phrase used — that such plaintiffs "cannot expect anything other than very, very modest awards" — has been quoted across partner-firm commentary including A&L Goodbody, Matheson, RDJ and Byrne Wallace Shields. It is doing real work. It signals that the procedural simplification of Dillon is not an invitation to mass claims.
The line between mere distress and a recognised psychiatric injury runs through the medical evidence. In practice, where a claim plausibly approaches the psychiatric-injury threshold, the strategic decision is binary. Either secure consultant psychiatric evidence, preserving access to the IRB framework and Guidelines quantum. Or plead distress simpliciter under section 117 of the 2018 Act for faster but modest quantum. Dillon does not pick one over the other. It just makes the choice unavoidable at the pleadings stage.
Power v Telia Company AB [2025] IESC 55: Summons Renewal and Service-Out
In one sentence: Power v Telia Company AB [2025] IESC 55 is the controlling Irish authority on renewal of an expired personal injuries summons under Order 8 RSC and on service out of the jurisdiction in mixed EU/non-EU defendant proceedings under Order 11A RSC, with Woulfe J holding (at paras 95–96 and 120) that "special circumstances" justifying renewal must normally arise within the original twelve-month validity period.
Procedural authority The Supreme Court's December 2025 judgment in Power v Telia Company AB & ors [2025] IESC 55 is the controlling 2025–2026 authority on renewal of personal injuries summonses under Order 8 of the Rules of the Superior Courts. It also controls service-out under Order 11A in mixed EU/non-EU defendant proceedings. Woulfe J gave the leading judgment in a five-judge bench that allowed the appeal in part.
Case capsule — Power v Telia Company AB & ors [2025] IESC 55
- Parties
- Power (Plaintiff) v Telia Company AB, Aga Khan Fund for Economic Development SA & ors (Defendants)
- Court
- Supreme Court
- Date of judgment
- 17 December 2025
- Citation
- [2025] IESC 55
- Bench
- O'Malley J · Woulfe J (judgment) · Murray J · Collins J · Donnelly J
- Primary source
- bailii.org/ie/cases/IESC/2025/2025IESC55 · courts.ie
Holding (operative): The "special circumstances" threshold for renewal of a personal injuries summons under Order 8 Rule 1(4) RSC requires more than the plaintiff's own difficulty in serving — practical impediments must be assessed against the requirement that defendants are not unfairly disadvantaged by delayed service. Order 11A Rule 4(1) service-out in mixed EU/non-EU defendant proceedings is re-interpreted.
The relevance of Power v Telia to personal injury practitioners is operational rather than doctrinal. The decision controls how renewal applications must now be framed where a personal injuries summons has lapsed without service, and where some defendants sit within the Brussels Recast / Lugano regime while others sit outside. It pairs naturally with Kirwan: the two decisions together close several of the procedural gaps through which long-warehoused claims previously survived.
Kirwan in Practice: 2025–2026 High Court Applications
The doctrinal interest of Kirwan is the reformulated test. The operational interest is what the High Court has done with it. In the months since the Supreme Court delivered the judgment in May 2025, the new framework has been applied to dismiss personal injury claims that would likely have survived under Primor. Two applications in particular set the pattern.
Murphy v Aer Lingus is the cleaner illustration. The plaintiff issued a personal injuries summons in respect of an alleged workplace injury and then allowed substantial cumulative inactivity to accrue. The High Court applied the reformulated Kirwan framework directly. The decision confirms that the new test reaches squarely into employer liability and standard personal injury torts — there is no residual carve-out for personal injury claims that previously enjoyed a more lenient approach under Primor.
Holmes illustrates how cumulative procedural delay — slow replies to particulars, late discovery, periods between procedural steps — is now treated. The High Court emphasised that the onus of progression rests on the plaintiff. Defendant inactivity does not amount to acquiescence absent positive encouragement to allow the case to continue.
The cumulative direction is plain. Practitioners with files older than four years — particularly in cases dependent on oral evidence — are now under sustained pressure to either progress to trial or face strike-out. Partner-firm commentary across William Fry, Kennedys Law, Mason Hayes & Curran, McCann FitzGerald and Cantillons Solicitors converges on the same operational reading: Kirwan is being enforced.
The Doctrinal Framework These Decisions Sit Within
The 2025–2026 Supreme Court decisions do not operate in a vacuum. They sit on top of a framework that has been built by judgments over the previous two decades. Three anchor decisions in particular control the practical assessment of any personal injury claim heard in 2026.
Delaney v PIAB [2024] IESC 10 — Guidelines Binding Force
The 5:2 majority decision in Delaney v PIAB & Ors [2024] IESC 10 (9 April 2024) remains the foundational decision for general damages quantum in 2026. The seven-judge panel — comprising four Supreme Court and three Court of Appeal judges (because some Supreme Court judges hold positions with the Judicial Council) — upheld the Personal Injuries Guidelines as legally binding while finding that section 7(2)(g) of the Judicial Council Act 2019 was unconstitutional in its original form. The Guidelines were re-validated through section 30 of the Family Leave and Miscellaneous Provisions Act 2021. The departure threshold the majority articulated (per Charleton J at paragraphs 122–124 of his judgment) is that the Guidelines should only be departed from where there is "no reasonable proportion" between the bracket and the award the judge believes should be made. The 16.7% inflationary uplift recommended by the Judicial Council in January 2025 has not been laid before the Oireachtas — and in July 2025 the Government signalled its intention not to seek parliamentary approval — leaving the 2021 Guidelines binding in their original form as of 11 May 2026.
Morrissey v HSE [2020] IESC 6 — Cap and Medical Standard
The Supreme Court's decision in Morrissey v HSE [2020] IESC 6 controls two distinct points in 2026 practice. It reaffirmed the €500,000 judicial cap on general damages first articulated against the inflation-adjusted line from Sinnott v Quinnsworth [1984] ILRM 523. It also reaffirmed the Dunne v National Maternity Hospital [1989] IR 91 test for medical negligence, rejecting suggestions that a higher "absolute confidence" standard applied. See the dedicated /case-law/morrissey-v-hse/ page for full analysis. For practitioners, the relevance in 2026 is that no 2025–2026 Supreme Court decision has disturbed either point.
Russell v HSE [2015] IECA 236 — Discount Rates
The Court of Appeal decision in Russell v HSE [2015] IECA 236 controls the discount rates applied to future pecuniary loss calculations in catastrophic personal injury awards. Leave to appeal was refused by the Supreme Court on 1 February 2017 at [2017] IESCDET 10. The dual rates of 1% (future care, wage-linked) and 1.5% (other future pecuniary loss) were confirmed by the Expert Working Group on the Discount Rate in its July 2024 report; the Minister for Justice has accepted those recommendations. No 2025–2026 Supreme Court decision has engaged with the rates, leaving the Russell framework intact. See the dedicated /case-law/russell-v-hse/ page.
Ireland vs England & Wales vs Northern Ireland: How the Three Jurisdictions Compare in 2026
Irish personal injury practitioners are routinely asked how the 2025 doctrinal shifts here compare to the position in neighbouring common-law jurisdictions. The short answer is that all three systems share the same broad architecture but diverge meaningfully on the operational settings that determine quantum and procedural availability. The table below sets out the headline differences as of 11 May 2026.
| Question | Ireland | England & Wales | Northern Ireland |
|---|---|---|---|
| Limitation period for personal injury | 2 years from date of knowledge (s.7 Civil Liability and Courts Act 2004) | 3 years from date of knowledge (Limitation Act 1980) | 3 years from date of knowledge (Limitation (NI) Order 1989) |
| Strike-out for delay test | Kirwan v Connors [2025] IESC 21 — 2/4/5-year sliding scale; reduced defendant burden | CPR 3.4 and Birkett v James — retains stronger requirement of demonstrable prejudice | Order 3 Rule 6 RCJ (NI) 1980 — 2-year inactivity trigger; closely analogous to Ireland |
| Personal injury discount rate | 1% for future care; 1.5% for future earnings (per Russell v HSE) | +0.5% (Lord Chancellor, 2 December 2024; in force 11 January 2025) | +0.5% (from 27 September 2024; previous rate of −1.5% set March 2022 superseded by the 2024 Government Actuary review) |
| Cap on general damages | €500,000 judicial cap (Morrissey 2020); €550,000 catastrophic Guidelines figure (2021) | Judicial College Guidelines (no statutory cap; 16th edition 2022 + uplifts) | Green Book / Judicial College Guidelines (adopted with local modifications) |
| Pre-issue authorisation regime | Mandatory IRB (formerly PIAB) authorisation under s.12 PIAB Act 2003 for personal injury (post-Dillon: distress-only excluded) | Pre-action protocols (non-statutory) for personal injury, clinical negligence, etc. | Pre-action protocols similar to England & Wales |
| Periodic payments orders | Available under Civil Liability (Amendment) Act 2017 for catastrophic injuries | Available under Damages Act 1996 s.2 (as amended) | Available under Damages (Variation of Periodical Payments) Order (NI) 2011 |
The cross-jurisdictional pattern matters operationally. Practitioners citing English authorities in post-Kirwan applications should be cautious — the English position retains a higher prejudice threshold and the Court of Appeal in Ireland has signalled that pre-2025 English authority is of reduced persuasive value on the operational settings of the reformulated test. Northern Irish authority — particularly Bannon v Craigavon Development Commission [1984] NI 387 — was expressly relied on in Kirwan itself and remains highly persuasive.
The Published [2026] IESC Sequence: What Has and Has Not Reached Personal Injury
Audited to 11 May 2026, the published [2026] IESC sequence contains nineteen substantive judgments and none of them disposes of a personal injury appeal substantively. The sequence to date covers planning, valuation, revenue, asylum, commercial, and costs matters.
The non-PI 2026 decisions handed down so far include:
- Protect East Meath Ltd v Meath County Council [2026] IESC 1 (22 January 2026) — planning
- Redwood Extended Care Facility v Tailte Eireann; Nua Healthcare Services Ltd v Tailte Eireann [2026] IESC 3 (28 January 2026) — valuation
- Flaherty v Revenue Commissioner [2026] IESC 4 (28 January 2026) — revenue
- Coolglass Wind Farm Ltd v An Coimisiún Pleanála [2026] IESC 5 — planning and climate obligations
- E v IPAT / FOM v Minister for Justice & Ors [2026] IESC 17 (19 March 2026) — international protection
- ACE Autobody Ltd v Motorpark Ltd & Ors [2026] IESC 18 (23 March 2026) — commercial
- ACE Autobody Ltd v Motorpark Ltd & Ors (Costs) [2026] IESC 19 (23 March 2026) — costs
The absence of a 2026 substantive personal injury judgment from the Supreme Court is not anomalous. It reflects what has already been observed in the leave-to-appeal data published by the Court for 2025: the proportion of personal injury appeals surviving the Article 34.5.3° gateway has fallen as the post-Delaney framework has settled. Practitioners watching the Supreme Court's quarterly judgment lists should also watch the determinations database for IESCDET grants of leave in personal injury matters, which feed forward into the next year's judgments.
2026 Legislative and Regulatory Context
Three legislative and one regulatory development sit in the active 2026 background for personal injury practitioners.
General Scheme of the Civil Reform Bill 2025
Published on 6 January 2026, the General Scheme of the Civil Reform Bill 2025 proposes raising the Circuit Court monetary jurisdiction for personal injury claims from €60,000 to €100,000. The practical effect, if enacted, is that personal injury claims with general damages between €60,000 and €100,000 — currently a substantial High Court tranche — would shift to the Circuit Court. The shift has obvious implications for litigation cost, hearing timelines, and forum selection in mid-tier personal injury matters. See oireachtas.ie for the active legislative status.
Judicial Council (Amendment) Bill 2026
Minister for Justice Jim O'Callaghan published the General Scheme of the Judicial Council (Amendment) Bill 2026 in early 2026. The Bill proposes a fixed five-year review cycle for the Personal Injuries Guidelines. If enacted, the Bill would address the discretionary character of the existing review framework — under which the Minister declined to lay the Judicial Council's recommended 16.7% inflationary uplift before the Oireachtas in early 2025 — by mandating periodic review. The current 2021 Guidelines remain in force.
Frozen Guidelines Uplift
The Judicial Council recommended a 16.7% inflationary uplift to the 2021 Personal Injuries Guidelines in early 2025, which would have raised the catastrophic injury cap from €550,000 to approximately €642,000. The Minister did not lay the resolution before the Oireachtas. The 2021 figures remain legally binding as of 11 May 2026. The Civil Reform Bill 2025 General Scheme and the Judicial Council Amendment Bill 2026 together signal active government attention to the Guidelines mechanism, but no uplift has been enacted.
Two Supreme Court Appointments (February 2026)
In February 2026 two judges were nominated for appointment to the Supreme Court. The composition of the Court is relevant to the digest because the panels hearing personal injury appeals in the back half of 2026 may include newly appointed judges. The Law Society Gazette and gov.ie press release record the appointments; the practical question for 2026 jurisprudence is whether any reformulation of Kirwan or Dillon emerges from a different bench composition. So far there is no signal that either decision will be revisited.
Pending Appeals and What Practitioners Should Watch in 2026
Four areas of Supreme Court engagement are realistic possibilities for the back half of 2026, based on the determinations record and the cumulative direction of lower-court activity.
The first is any direct challenge to the Kirwan framework on appeal. The High Court applications in Murphy v Aer Lingus and Holmes v AG were not appealed to the Court of Appeal as of this review. The volume of cases now exposed to strike-out under the new framework makes Court of Appeal — and ultimately Supreme Court — engagement with the application of the test increasingly likely. The questions practitioners should anticipate include three areas. The first is the application of the five-year threshold to claims under disability. The second is the treatment of cases where the limitation period is itself extended (statute-paused for minors, for example). The third is the application of Kirwan to cases proceeding in tandem with statutory tribunals.
The second is the borderline of the post-Dillon psychiatric-injury threshold. Where a plaintiff alleges "anxiety amounting to a depressive episode" rather than "anxiety alone", and the medical evidence is contested, the trial-level treatment will generate appeals. The architecture of the Kelly v Hennessy five-part test for nervous shock is preserved by Dillon, and 2026 may produce a Supreme Court re-engagement.
The third is any direct challenge to the Russell v HSE discount rates. The Expert Working Group report of July 2024 recommended retaining the current rates, and the Minister for Justice accepted those recommendations. The gap between the Irish 1%/1.5% rates and the England and Wales +0.5% rate (Lord Chancellor, 2 December 2024; in force 11 January 2025) and the Northern Ireland +0.5% rate (in force from 27 September 2024, following the Government Actuary's review under the Damages (Return on Investment) Act (NI) 2022 framework; the previous NI rate of −1.5%, set in March 2022, was superseded by that review) creates pressure for test-case litigation, but no superseding judgment has emerged in 2026.
The fourth is the unresolved indexation question for Periodic Payment Orders under the Civil Liability (Amendment) Act 2017. The post-Hegarty v HSE paralysis has continued through 2026 with no Supreme Court engagement. Practitioners running catastrophic claims continue to default to lump-sum settlements with Russell rates.
Practitioner Implications: Case-Management Discipline After Kirwan
Translating the 2025 Supreme Court decisions into 2026 practice involves several operational shifts that are now visible in firm case-management protocols across the personal injury bar.
The first is active file review against the Kirwan thresholds. Any personal injury file approaching two years of inactivity is now a candidate for documented review; any file approaching four years requires either active progression or candid client communication about strike-out risk. The High Court applications in Murphy and Holmes make clear that defendant inactivity does not insulate a plaintiff — the onus of progression rests squarely on the plaintiff side.
The second is procedural discipline around personal injuries summons renewal. After Power v Telia, renewal applications should be framed against the tightened "special circumstances" threshold and supported by documented contemporaneous service efforts. Defendants in mixed EU/non-EU defendant proceedings face new tactical opportunities to challenge service-out.
The third is pleading discipline for emotional-distress claims. Dillon made it clear that plaintiffs must identify the nature of the harm — recognised psychiatric injury or non-injury emotional disturbance — and the legal basis of the claim at the pleadings stage. Mislabelling carries hard procedural consequences: dismissal for failure to obtain IRB authorisation where authorisation was required, or dismissal for misconceived negligence pleading where the damage element is absent.
The fourth is Guidelines departure analysis. With the 16.7% uplift not enacted, the 2021 figures remain binding. Departure applications under the "no reasonable proportion" test from Delaney remain available but rare; the post-Delaney consolidation has narrowed the practical scope of departure.
Key Terms Used on This Page
Short definitions of the core terms used throughout this digest. Each term is also annotated with DefinedTerm structured data.
- Want of prosecution
- An application by a defendant to strike out a claim on the ground that the plaintiff has failed to progress it. In Ireland, controlled since 1996 by Primor and reformulated in 2025 by Kirwan v Connors [2025] IESC 21.
- Inordinate and inexcusable delay
- The two-part threshold a defendant must establish under both Primor and Kirwan before the balance of justice is assessed. Inordinate means objectively excessive; inexcusable means without adequate explanation.
- Order 122 Rule 11 of the Rules of the Superior Courts
- The procedural rule under which the High Court may strike out proceedings for delay. Hogan J in Kirwan anchored the reformulated test here, supplemented by the inherent jurisdiction of the Court.
- The Kirwan 2-4-5 Threshold Map
- A practitioner shorthand introduced on this page for the three temporal pivots in the Kirwan reformulation: 2 years (additional factors begin to weigh), 4 years (presumption of dismissal where oral evidence is material), 5 years (only exceptional circumstances preserve the claim).
- Personal injury (statutory definition)
- Defined by reference to section 2(1) of the Civil Liability Act 1961 and the Personal Injuries Assessment Board Act 2003. Dillon v Irish Life [2025] IESC 37 held that emotional disturbance falling short of a recognised psychiatric disorder is not a personal injury within that meaning.
- Recognised psychiatric injury
- A psychiatric disorder that meets the diagnostic threshold under expert clinical evidence (typically DSM-5 or ICD-11 categories). Required for a nervous-shock claim under Kelly v Hennessy; preserved as the boundary for personal injury treatment under Dillon.
- Special circumstances (Order 8 Rule 1(4) RSC)
- The threshold a plaintiff must meet to renew an expired personal injuries summons. Tightened in Power v Telia Company AB [2025] IESC 55 — the plaintiff's own difficulty in serving is not enough on its own.
- No reasonable proportion (the Delaney departure test)
- The threshold at which a judge may depart from the bracket in the Personal Injuries Guidelines, per the majority in Delaney v PIAB & Ors [2024] IESC 10. The bracket and the award must lack reasonable proportion before departure is justified.
- Neutral citation format ([Year] IESC / IECA / IEHC X)
- The Irish court neutral citation: IESC = Supreme Court; IECA = Court of Appeal; IEHC = High Court. The number is the sequential judgment number for that year.
- IESCDET (determinations)
- A Supreme Court determination on an application for leave to appeal under Article 34.5.3° of the Constitution (appeal from the Court of Appeal) or Article 34.5.4° (direct leapfrog appeal from the High Court). Not a substantive judgment — a leave decision only.
- Catastrophic injury general damages cap
- The judicial ceiling on general damages for the most serious personal injuries in Ireland. Morrissey v HSE [2020] IESC 6 confirmed the cap at €500,000. The 2021 Personal Injuries Guidelines published a figure of "in or about €550,000" for the most devastating and catastrophic of injuries, and that figure remains in force. The proposed 16.7% inflationary uplift (which would raise the catastrophic bracket to approximately €642,000) has not been enacted.
Frequently Asked Questions
Is Kirwan v Connors still good law in 2026?
Yes. Kirwan v Connors & Ors [2025] IESC 21 is the controlling Supreme Court authority on dismissal for want of prosecution in 2026.
No Supreme Court decision since May 2025 has disturbed the reformulated framework, and the High Court has applied it to personal injury claims in Murphy v Aer Lingus and Holmes v AG. The judgment expressly anchored the test in Order 122 Rule 11 RSC and signalled that further procedural rule clarification would be welcome but is not necessary to the test's operation.
Practitioner note: The framework is articulated as case-by-case assessment, not a mechanical timer. The temporal benchmarks are presumptions, not bright-line rules — but they are strong presumptions.
Read next: Kirwan v Connors primary source on BAILII.
Does emotional distress count as personal injury in Ireland after Dillon?
Not on its own. Dillon v Irish Life Assurance plc [2025] IESC 37 holds that distress, anxiety, upset and inconvenience falling short of a recognised psychiatric disorder is not a "personal injury" within the meaning of the PIAB Act 2003.
Where a recognised psychiatric injury is alleged and supported by consultant psychiatric evidence, the claim remains a personal injury action — IRB authorisation is required, the Personal Injuries Guidelines apply, and the test from Kelly v Hennessy for nervous shock controls. Where no psychiatric injury is alleged, the claim proceeds directly to court under section 117 of the Data Protection Act 2018 with the caveat that awards will be modest.
Practitioner note: The decision is procedural, not substantive — it shifts which forum hears the case, not what it is worth. Quantum for non-injury emotional disturbance remains low.
Read next: Psychological injury claims in Ireland and the Dillon primary source on BAILII.
Are the Personal Injuries Guidelines still binding in 2026?
Yes. The 2021 Personal Injuries Guidelines remain legally binding throughout 2026 following the Supreme Court's confirmation in Delaney v PIAB & Ors [2024] IESC 10.
The Judicial Council recommended a 16.7% inflationary uplift in early 2025, which would have raised the catastrophic injury cap from €550,000 to approximately €642,000. The Minister for Justice did not lay the resolution before the Oireachtas. The General Scheme of the Judicial Council (Amendment) Bill 2026 proposes a five-year review cycle going forward but has not yet been enacted.
Practitioner note: Departure from the Guidelines is available under the "no reasonable proportion" test articulated by the majority in Delaney, but the threshold is high. Most departure applications fail.
Read next: General damages in medical negligence claims.
How long can a personal injury claim sit idle after Kirwan?
Under the Kirwan 2-4-5 Threshold Map explained above, the reformulated test sets sliding thresholds: less than two years is generally safe, two-to-four years is increasingly exposed, four-to-five years carries a presumption of dismissal, and beyond five years dismissal is the default outcome absent exceptional circumstances.
The thresholds are presumptions on a case-by-case basis. Cases dependent on oral evidence — where witness credibility is central — are treated more strictly than cases turning principally on documentary evidence. Inactivity under disability (where the plaintiff is a minor or lacks capacity) is treated differently because the limitation clock is paused.
Practitioner note: Defendant inactivity does not protect a plaintiff. The Court was explicit in Kirwan that defendants are not required to prompt plaintiffs into action absent affirmative acquiescence. Both entries in the Kirwan Application Tracker were claims that crossed the 5-year pivot.
Read next: the Kirwan section above on 2025–2026 High Court applications.
What 2026 Supreme Court personal injury judgments have been handed down so far?
None substantive as of 11 May 2026. The published [2026] IESC sequence (IESC 1 through 19) covers planning, valuation, revenue, asylum, commercial and costs matters — no classical personal injury appeal has been disposed of substantively.
The decisions actively shaping 2026 personal injury practice were handed down in 2025: Kirwan v Connors [2025] IESC 21 in May, Dillon v Irish Life [2025] IESC 37 in July, and Power v Telia [2025] IESC 55 in December. Several appeals on related procedural and quantum questions sit in the determinations pipeline for hearing in the back half of 2026.
Practitioner note: The thin 2026 personal injury list reflects post-Delaney doctrinal settlement — the Supreme Court has not needed to revisit the underlying framework.
Read next: the published [2026] IESC sequence above and the determinations database.
How is the Kirwan test different from Primor?
The two-part threshold (inordinate and inexcusable delay) survives, but the burden distribution at longer timescales has inverted. Kirwan anchors the jurisdiction in Order 122 Rule 11 RSC, introduces sliding-scale pivots at 2, 4 and 5 years, and reduces the defendant's burden to prove specific prejudice.
The most operationally significant change is that defendant inactivity no longer counts as acquiescence absent affirmative encouragement, and the onus of progression rests explicitly on the plaintiff. The full element-by-element comparison is in the Primor vs Kirwan table above.
Practitioner note: Primor remains relevant for the inordinate-and-inexcusable threshold itself. It is the third leg of the test (balance of justice) that the reformulation reshapes.
Read next: the Kirwan section and the Kirwan 2-4-5 Threshold Map.
Does Kirwan apply where the plaintiff is a minor or under disability?
The general framework applies but its application is materially different. Inactivity while the limitation clock is statutorily paused (under section 49 of the Statute of Limitations 1957 for minors or section 48 for persons of unsound mind) is treated separately from inactivity once the disability has ceased.
The Supreme Court in Kirwan was explicit that the reformulated framework is a case-by-case assessment, not a mechanical timer. Disability-paused periods are an obvious category in which mechanical application would produce unjust outcomes. The questions practitioners should anticipate the Court of Appeal addressing in 2026 include how the 2-4-5 pivots interact with the limitation pause and where the inactivity clock begins for cases under disability.
Practitioner note: The position is settled in principle (limitation pauses are recognised) but unsettled in operational application of the Kirwan thresholds to paused periods. No reported High Court application to date has tested this directly.
Read next: the pending appeals section for the operational questions watched in 2026.
What should I do if my personal injury case is already three years old?
A claim three years from the last procedural step is past the two-year pivot but not yet at the four-year presumption-of-dismissal threshold. The practical answer is to take a substantive procedural step now and document it.
Substantive steps include serving a notice of intention to proceed (Order 122 Rule 11), filing a notice for trial, raising particulars, or issuing a motion. Sending correspondence that merely flags an intention to progress is not a procedural step. The clock for the four-year pivot resets on each substantive step. The longer the gap, the more important contemporaneous evidence of progression effort becomes if a strike-out motion follows.
Practitioner note: The reformulated Kirwan framework is not retrospective in the sense of converting previously safe claims into dismissable ones overnight, but the High Court has made clear that pre-May-2025 inactivity is counted in calculating total elapsed time.
Read next: the Kirwan 2-4-5 Threshold Map and the Practitioner Implications section above.
Can I appeal a strike-out order made under Kirwan?
Yes. A High Court order striking out a personal injury claim for delay can be appealed to the Court of Appeal as of right. A further appeal to the Supreme Court requires leave under Article 34.5.3 of the Constitution and is granted only where the appeal raises a matter of general public importance or where the interests of justice require it.
The Court of Appeal has been receptive to appeals raising the operational application of Kirwan — particularly on how the 2-4-5 thresholds interact with limitation pauses, infancy, and disability. The Supreme Court has not yet granted leave in any post-Kirwan Court of Appeal decision, but the determinations pipeline for late 2026 contains at least one appeal challenging the application of the reformulated test to cases predominantly progressed before May 2025.
Practitioner note: An appeal does not stay the strike-out order absent a separate application. Plaintiffs intending to appeal should consider an application for a stay pending appeal in the same notice of motion.
Read next: the Pending Appeals section and the Supreme Court determinations database.
Does Kirwan apply in the Circuit Court as well as the High Court?
Yes. While Kirwan formally concerned the Rules of the Superior Courts (specifically Order 122 Rule 11 RSC), the principles it articulates apply by analogy to Circuit Court personal injury proceedings under the Circuit Court Rules.
The Circuit Court has the same inherent jurisdiction to dismiss for want of prosecution as the High Court, and Circuit Court judges have applied the Kirwan reasoning in unreported decisions in the second half of 2025. The General Scheme of the Civil Reform Bill 2025 (published 6 January 2026) proposes raising the Circuit Court personal injury jurisdictional ceiling from €60,000 to €100,000, which would move more claims into the Circuit Court where the same delay principles apply.
Practitioner note: Circuit Court strike-out applications have a lower evidentiary threshold for "special circumstances" justifying continuation, but the underlying 2-4-5 inactivity pivots from Kirwan are read across.
Read next: Which court hears my personal injury claim?.
What happens if I miss the two-year personal injury limitation period?
A claim issued outside the two-year limitation period under section 7 of the Civil Liability and Courts Act 2004 is liable to be struck out on the limitation point alone, before any Kirwan delay analysis arises. The two-year period runs from the date of knowledge, not the date of accident.
Date-of-knowledge issues — when the plaintiff first knew or ought to have known of the injury and its connection to the defendant's act or omission — remain the most heavily litigated limitation question. Kirwan does not change the limitation period; it changes what happens to claims that were issued in time but then warehoused. A claim issued one day inside the limitation period and then left idle for five years would be liable to strike-out under Kirwan notwithstanding that it was issued in time.
Practitioner note: The Personal Injuries Assessment Board (now styled the Injuries Resolution Board) application pauses the limitation clock under section 50 of the PIAB Act 2003, but the pause is not indefinite — practitioners should track the IRB authorisation date carefully.
Read next: Time limits for personal injury claims in Ireland.
How does Irish personal injury delay law compare to England, Wales and Northern Ireland?
Irish, English and Northern Irish courts each have an inherent jurisdiction to dismiss for want of prosecution, but they apply meaningfully different operational tests. The Irish reformulated Kirwan test draws explicitly on Carswell J's reasoning in the Northern Irish decision Bannon v Craigavon Development Commission [1984] NI 387.
In England and Wales, the equivalent jurisdiction is governed by CPR 3.4 (strike-out for abuse of process) and the Birkett v James line, which retains a stronger requirement of demonstrable prejudice than the post-Kirwan Irish position. In Northern Ireland, Order 3 Rule 6 of the Rules of the Court of Judicature (NI) 1980 carries a two-year inactivity trigger directly analogous to Order 122 Rule 11 RSC in this jurisdiction. Quantum frameworks also diverge: England and Wales operate on a personal injury discount rate of +0.5% (Lord Chancellor, 2 December 2024; in force 11 January 2025), Northern Ireland on +0.5% (in force from 27 September 2024, following the Government Actuary's 2024 review; the previous NI rate of −1.5% set in March 2022 was superseded), and Ireland on the 1% / 1.5% framework approved in Russell v HSE.
Practitioner note: Cross-jurisdictional citation is permitted but practitioners should not assume English authorities post-Birkett v James still represent best practice in Ireland after Kirwan. The Northern Irish line of authority is more closely aligned.
Read next: the Doctrinal Framework section and Russell v HSE on discount rates and periodic payments.
What are the cost implications of a strike-out for delay?
Where a personal injury claim is struck out for want of prosecution under Kirwan, costs normally follow the event under section 169(1) of the Legal Services Regulation Act 2015. The plaintiff is ordinarily liable for the defendant's costs of the strike-out motion and may also be liable for costs reasonably incurred in defending the action up to the date of strike-out.
Practitioners should be aware of the professional indemnity exposure that follows from a client's case being struck out for delay attributable to solicitor inaction. Partner-firm commentary from Beale & Co (June 2025) highlights that the post-Kirwan environment is expected to generate an increase in solicitor professional negligence claims grounded on inactivity. The Law Society's Solicitors Disciplinary Tribunal also has an interest in chronic case-warehousing.
Practitioner note: A strike-out for delay is not the same as a finding of professional negligence against the solicitor, but it is materially supportive of one in subsequent proceedings. File audit protocols and time-tracking systems are now defensive necessities.
Read next: the Practitioner Implications section above.
References (OSCOLA Format)
Cases
- Kirwan v Connors & Ors [2025] IESC 21 (30 May 2025; seven-judge panel: O'Donnell CJ, Dunne, Charleton, O'Malley, Hogan, Murray, Collins JJ. Four judgments delivered; majority by O'Donnell CJ and Hogan J. Four-tier sliding-scale test formulated by Murray J; applied and restated by O'Donnell CJ at para 26 of his judgment) <https://www.bailii.org/ie/cases/IESC/2025/2025IESC21.html> · courts.ie (search "Kirwan Connors" — four PDFs: O'Donnell CJ, Hogan J, Murray J, Collins J)
- Dillon v Irish Life Assurance plc [2025] IESC 37 (24 July 2025; Murray J, unanimous; "very, very modest awards" at para 56) <https://www.bailii.org/ie/cases/IESC/2025/2025IESC37.html> · courts.ie
- Power v Telia Company AB & ors [2025] IESC 55 (17 December 2025; Woulfe J; five-judge bench: O'Malley, Woulfe, Murray, Collins, Donnelly JJ; "special circumstances" clarified at paras 95–96 and 120) <https://www.bailii.org/ie/cases/IESC/2025/2025IESC55.html> · courts.ie
- Delaney v PIAB & Ors [2024] IESC 10 (9 April 2024; seven-judge panel with four Supreme Court and three Court of Appeal judges; 5:2 majority on constitutional validity of the Guidelines; 4:3 majority on appellant's lack of vested property/personal rights) <https://www.bailii.org/ie/cases/IESC/2024/2024IESC10.html>
- Morrissey v HSE [2020] IESC 6 (19 March 2020; Clarke CJ; unanimous five-judge bench; €500,000 cap on general damages; Dunne test reaffirmed) <https://www.bailii.org/ie/cases/IESC/2020/2020IESC6.html>
- Murphy v Aer Lingus Group plc & Anor [2025] IEHC 589 (31 October 2025; Heslin J; first Kirwan application to personal injury) <courts.ie>
- Holmes v The Attorney General & Ors [2026] IEHC 2 (January 2026; Kirwan applied to clinical-negligence cumulative inactivity ~17 years; claim struck out) <courts.ie>
- Primor plc v Stokes Kennedy Crowley [1996] 2 IR 459 (original delay test; reformulated by Kirwan).
- Ó Domhnaill v Merrick [1984] IR 151 (residual prejudice threshold; preserved by Kirwan at the under-2-year band).
- Sinnott v Quinnsworth [1984] ILRM 523 (original general damages cap; inflation-adjusted line to Morrissey).
- Dunne v National Maternity Hospital [1989] IR 91 (medical negligence standard; reaffirmed in Morrissey).
- Kelly v Hennessy [1995] 3 IR 253 (nervous shock five-part test; preserved by Dillon).
- Russell v HSE [2015] IECA 236 (Court of Appeal; 1% / 1.5% discount rates); leave refused at [2017] IESCDET 10 (1 February 2017) <courts.ie/determinations>.
- Nowak v The Institute of Chartered Accountants in Ireland [2025] IEHC 408 (early Kirwan application — non-PI context).
- Doyle v Commissioner of An Garda Síochána & Ors [2025] IEHC 591 (Kirwan applied to non-PI claim issued 2003).
Legislation
- Civil Liability Act 1961 (in particular s 2(1), s 34, Part IV) <https://www.irishstatutebook.ie/eli/1961/act/41/enacted/en/html>.
- Personal Injuries Assessment Board Act 2003 (in particular s 3(d) and s 12) <https://www.irishstatutebook.ie/eli/2003/act/46/enacted/en/html>.
- Civil Liability and Courts Act 2004, s 7 <https://www.irishstatutebook.ie/eli/2004/act/31/enacted/en/html>.
- Civil Liability (Amendment) Act 2017 (periodic payment orders) <https://www.irishstatutebook.ie/eli/2017/act/30/enacted/en/html>.
- Data Protection Act 2018, s 117 <https://www.irishstatutebook.ie/eli/2018/act/7/section/117/enacted/en/html>.
- Judicial Council Act 2019 (in particular s 7(2)(g) and s 18) <https://www.irishstatutebook.ie/eli/2019/act/33/enacted/en/html>.
- Family Leave and Miscellaneous Provisions Act 2021 (in particular s 30) <https://www.irishstatutebook.ie/eli/2021/act/4/enacted/en/html>.
- Rules of the Superior Courts: Order 8 Rule 1(4) (renewal of summons); Order 11A Rule 4(1) (service out); Order 122 Rule 11 (want of prosecution) <https://www.courts.ie/content/court-rules>.
- Statute of Limitations 1957, ss 48–49 (disability provisions) <https://www.irishstatutebook.ie/eli/1957/act/6/enacted/en/html>.
- Court Proceedings (Delays) Act 2024 <https://www.irishstatutebook.ie/eli/2024/act/12/enacted/en/html>.
Policy documents and secondary sources
- Judicial Council, Personal Injuries Guidelines (adopted 6 March 2021) <https://judicialcouncil.ie/personal-injuries-guidelines-committee/>.
- Judicial Council Board, draft amended Personal Injuries Guidelines (16.7% uplift recommendation; submitted to Minister for Justice 4 February 2025; not laid before the Oireachtas as of 11 May 2026).
- Department of Justice, Report of the Expert Working Group on the Discount Rate (July 2024) <https://www.gov.ie>.
- Department of Justice, General Scheme of the Civil Reform Bill 2025 (published 6 January 2026; Head 30 raises Circuit Court PI jurisdiction from €60,000 to €100,000) <https://www.gov.ie>.
- Beale & Co, From Delay to Dismissal — Implications of Kirwan Decision for Professional Indemnity (PI) Insurers (June 2025) <https://beale-law.com>.
- A&L Goodbody, Supreme Court simplifies Primor test on delay (June 2025) <https://www.algoodbody.com>.
- RDJ LLP, Dismissal of Actions for Want of Prosecution — Supreme Court Reformulates Primor Principles (5 June 2025) <https://www.rdj.ie>.
- Kennedys Law, Supreme Court tightens the rules on litigation delay — implications for insurers (June 2025) <https://www.kennedyslaw.com>.
- Kennedys Law, High Court in Ireland confirms applicability of the Kirwan criteria to address cumulative inactivity in litigation (11 February 2026) — Holmes commentary <https://www.kennedyslaw.com>.
- McCann FitzGerald, Supreme Court Overhauls Rules on Delay in Prosecuting Claims (June 2025) <https://www.mccannfitzgerald.com>.
- William Fry, High Court Clarifies Law on Dismissal of Cases for Delay (December 2025) <https://www.williamfry.com>.
- Matheson, Strike out for delay: impact of the Supreme Court decision in Kirwan (January 2026) <https://www.matheson.com>.
- Matheson, Supreme Court Opens the Door to More Data Breach Claims (August 2025) — Dillon commentary <https://www.matheson.com>.
- Byrne Wallace Shields LLP, Supreme Court judgement set to shape the nature of litigation claims resulting out of data breaches (July 2025) <https://byrnewallaceshields.com>.
- CaseMine commentary, Order 122 Rule 11 RSC as Exclusive Basis for Dismissal for Want of Prosecution (May 2025) <https://www.casemine.com>.
- BAILII (British and Irish Legal Information Institute) <https://www.bailii.org/ie/cases/IESC/>.
- Courts Service of Ireland, judgment search <https://www.courts.ie/judgments>.
- Supreme Court of Ireland, determinations database <https://www.supremecourt.ie/supreme-court/decisions/determinations>.
Gary Matthews Solicitors
Medical negligence solicitors, Dublin
We help people every day of the week (weekends and bank holidays included) that have either been injured or harmed as a result of an accident or have suffered from negligence or malpractice.
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