Norwich Pharmacal Jurisdiction Under Irish Law Continues To Develop

Our previous article on the Court of Appeal judgment in Blythe v Commissioner of An Garda Siochana [2023] IECA 255 (Blythe) analysed the Norwich Pharmacal jurisdiction in detail.

The High Court (Court) recently considered the Blythe ruling in an application for a Norwich Pharmacal Order (NPO) against the Garda Commissioner (respondent).

In Randall v Garda Commissioner, the applicant instituted proceedings against the respondent to obtain discovery of a Garda investigation into sexual abuse allegedly perpetrated on him as a child in 1979. On foot of his later complaint to the Gardaí, a suspect was identified, and a Garda investigation was carried out. No prosecution could be brought as the suspect had since died. The applicant sought discovery of the Garda investigation file and disclosure of the identity of the deceased suspect (the NPO).