In a previous insight here, RDJ examined the 2018 case of
Noirin O'Sullivan v Irish Examiner where the
High Court refused former Garda Commissioner Noirin O'Sullivan
an extension of time within which to issue defamation proceedings.
The judicial trend of refusing such applications has continued,
largely unabated, since that decision. More recently, in the
judgement of Proudfoot v MGN Limited [delivered in
December 2019], the High Court also refused an application to
extend the one year limitation period for defamation actions
provided for under section 38 of the Defamation Act 2009. Despite
the difference in facts between the two cases, this most recent
judgement confirms the Irish courts' general reluctance to
grant an extension of the one year limitation period in defamation
cases.