Supreme Court grants brief period for State to legislate before declaring asylum work ban unconstitutional.
Legislator summary
AI generatedThe Supreme Court previously ruled the absolute prohibition on asylum seekers working was unconstitutional but deferred immediate invalidation. The State now plans to opt into the EU Reception Directive, prompting the Court to set a short deadline for legislative action. The Court will declare the ban unconstitutional on February 9th without further hearings, emphasizing that the Legislature must make the necessary choices.
Legislator headnote
AI generatedConstitution Art. 40.3.1°; Constitution Art. 40.1: While legislation inconsistent with the Constitution must generally be declared immediately invalid, the Court may exceptionally defer such declaration to allow the Legislature time to enact remedial measures when the State has indicated specific plans to address the constitutional defect.
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THE SUPREME COURT
Clarke C.J.
O’Donnell J.
MacMenamin J.
Dunne J.
O’Malley J.
N H V (THIHA)
APPLICANT
AND
THE MINISTER FOR JUSTICE AND EQUALITY
RESPONDENT
AND
THE ATTORNEY GENERAL AND THE IRISH HUMAN RIGHTS AND EQUALITY COMMISSION
NOTICE PARTIES
Judgment (ex tempore) of the Court delivered on the 30th day of November, 2017 by Clarke C.J.
1. This Court has already given judgment in this matter and has ruled that in certain respects the absolute prohibition on working for
persons who are in the asylum system was inconsistent with the Constitution.
2. Exceptionally the Court did not take the normal course of immediately declaring the relevant legislative provisions to be
unconstitutional thus rendering them of no continuing legal effect. Rather the Court in its judgment recognised that there were
choices to be made as to how the difficulty which had been identified by the Court in its judgment was to be addressed and that at
least the first port of call in making those choices rested with the Legislature.
3. It does have to be strongly emphasised that the general rule must be that, on finding a measure of legislation to be
unconstitutional, the Court should immediately declare it to be so and thereby render it inoperative under the terms of the
Constitution. While the Court has not as yet had the opportunity to consider in any detail the parameters of any exceptional
circumstances which might allow the Court to depart from that general proposition, nonetheless it must be made clear that the
circumstances in which it would be appropriate for the Court not to follow the general rule must necessarily be exceptional. The Court
has identified this case as one in which such exceptional circumstances did arise.
4. However, in the Court’s view, there are significant limitations on the appropriate scope of further interaction between the Court
and the parties. I appreciate that it has not been sought on the part of the State that the Court should involve itself in any approval
or discussion as to the merits of the choices which the State has now made or the choices which were available to the State at the
time when the Court gave judgment. But nonetheless, it is important to emphasise that the whole point of the affording of a period of
time to the State was to allow the Legislature to make the decisions which it has to make. It must be emphasised that the Court has
no role in those matters.
5. Essentially, the issue which, therefore, faces the Court today is as to the appropriate course of action to adopt in the light of the
fact that it has been indicated by counsel on behalf of the State that, firstly a decision has been made as to how this matter is to be
approached and, secondly that plans are afoot to take the necessary legislative measures so that Ireland will opt into the Reception
Directive.
6. The Court appreciates that the State has taken measures to use the time which the Court gave, but the Court does not want to
become involved in the question of monitoring even the speed of progress of those measures because the Court does not consider
that to be its function under the Constitution.
7. In all the circumstances, the Court feels that the balance of justice would be met by affording a relatively brief period to the State
to, as it were, take whatever measures it considers necessary prior to a declaration of inconsistency with the Constitution being
made. But the Court would wish strongly to emphasise that what is envisaged is not that there will be any further hearing, sitting,
consideration of submissions, receipt of letters or the like. What follows is simply an indication of what the Court will do.
8. The Court proposes to sit again on this matter on Friday the 9th February and on that day the Court will make the declaration
which was sought on behalf of the applicant. Therefore, this is simply an indication of what is going to happen. It is not an
adjournment as such, the matter is not being put back for any further consideration on that date. It is therefore a matter for the
State to take whatever measures it considers appropriate within that timeframe. But I want to make clear on behalf of the Court that
the relevant declaration will be made on that date.