I move: "That the Bill be now read a Second Time."
Civil Liability (Schools) Bill 2023: Second Stage
Prior to calling Senator Mullen, I remind Members that the opening speech of the proposer and seconder should not exceed 16 minutes and all other Senators will have six minutes. The Minister of State has 15 minutes and the proposer has five minutes to reply. I welcome the Minister of State, Deputy Madigan. I also welcome friends of Senators Mullen and Wilson, Eugene Flood from County Monaghan, and some French and Irish visitors to the House, Jerome and Agnes Wasser, and Fiona Carolan. They are all very welcome. I bid them a céad, míle fáilte to the House.
I would be grateful if I could share my time with Senator McDowell. We will have three minutes each.
Is that agreed? Agreed? Is Senator McDowell seconding the proposal?
Yes.
Cuirim fáilte roimh an Aire Stáit. As I have said here before, education should never be measured just in terms of grades or CAO points, nor should it be geared towards preparing young people to be economic units, ready for employment by multinationals, at least not primarily. Education should be about allowing children to become fully rounded human beings. A vital part of that is allowing children to socialise with their peers and to have adequate time for sport and recreation. Our happiest memories from school are not of books or exams, but of the bonds we made with friends. All schools are required to deliver physical education as part of the curriculum, but that is only part of the story. Children should have as much fresh air and physical activity as they want and need, in between class time. I do not need to recite the trends in Ireland and further afield in relation to childhood obesity. It is a serious problem, and encouraging activity during school hours is one way of addressing it.
There has been a trend over the last decade or more for playground activities and ad hoc sports to be restricted in various ways by school management, due to the fear of litigation arising from small accidents and minor injuries. Ball games are often curtailed or prohibited. Some schools have even implemented a so-called "no-running policy". There is something particularly Kafkaesque and utterly joyless about telling children not to run in a schoolyard, yet we hear anecdotal evidence at least of that going on. Aside from the fear of litigation, there is a more general trend in recent years, perhaps on the part of some parents, State bodies, and policymakers to wrap children in cotton wool and shield them from any kind of negative experiences. That is not a real world approach because cuts and bruises, falls and knocks are and should always be a part of most children's lives.
The Bill I sponsor today recognises that reality, by protecting schools from unjustified liability for everyday schoolyard accidents, and allowing them to facilitate increased activity for children. The Bill does not seek to bring any radical change to the law. On the whole, the courts have been very sensible in this area, but I hope it will bring some additional comfort to schools by codifying in legislation what has largely, although not always, been the view taken by the Judiciary where disputes have arisen.
The restriction of schoolyard activities is on the record of these Houses. The Joint Oireachtas Committee on Children and Youth Affairs conducted ten days of hearings into childhood obesity in 2018 and received a number of oral and written submissions, including from Departments. The committee's report of November 2018 stated that it:
... has heard evidence, albeit of an anecdotal nature, that children in some schools are being prevented from partaking in physical activity during break times due to restrictions being imposed by the schools. This ... is as a result of schools being concerned about possible liabilities arising on behalf of the school where a child is injured while playing on the premises.
The Teachers Union of Ireland, TUI, submission stated:
Many schools are concerned about a litigious culture ... Logical but regrettable responses...include schools being so concerned ... that some have instigated limitations on students' physical activities, such as running in the schoolyard.
The INTO referenced similar "anecdotal evidence of "no running policies" in school yards. We are ... unfortunately, in a culture of litigation and boards of management are very exposed".
Part of the problem here is that it is based on anecdotal evidence. We all know a problem exists, but we have little tangible proof of it that we can point to. I will come to the reasons for that. The Oireachtas joint committee proposed a means of turning that anecdotal evidence into something more concrete. It recommended that the Government would: "survey schools so as to identify the scale of the issues". Curiously, it did not seem to consider whether more than just "encouragement" of schools was needed, or that perhaps new legislation would also help. In January 2021, the Minister for Education, Deputy Foley, in response to a written parliamentary question in the Dáil about the actions her Department had taken on foot of the report, gave no indication that she had surveyed schools in line with recommendation 13. I am not aware of this having been done in the meantime. Apologies if I ought to be aware, but I would be very interested to know whether there has been such a survey.
A number of cases have come before the courts in recent years where schools have been sued by parents on foot of schoolyard or sporting injuries. These include: an injured knee during high-jump practice; a slip and fall during a hockey match; a broken arm during a game of chase; a child being struck in the eye with a chocolate bar by another child; and a child being hit in the eye by a pencil thrown by another child. I think we can all agree that these are not the sorts of things that should normally end up in the Circuit Court or High Court, and yet they have. Thankfully, the Judiciary has largely taken a commonsense approach, treating minor injuries as just that. In two recent High Court cases - Dunne v. St. Paul's School, in 2019, and Cole v. Sisters of Joseph of Cluny, Killiney in 2016, the court ruled in favour of the schools in both cases, saying:
Accidents can happen, and a school is not automatically to blame, and that sport and playtime is an important part of the school experience and no indoor or outdoor sport could be conducted if schools were held responsible for all injuries.
A court dismissed another claim in 2017 for a broken arm as "an old fashioned accident, pure and simple". Significantly, the court also said in that particular case that "no prudent, responsible and reasonable parent would have prohibited the game of chase that had been taking place in the school yard on the day." The concept of a "prudent parent" is central to my Bill, and runs through many of the cases taken against schools. For example, in Maher v. Presentation Junior School, Mullingar in 2004, the court said: "The school is expected to be no more and no less vigilant of those in its care than a prudent parent would be in his or her own home".
Also in 2004, the Supreme Court gave its view on the issue in Murphy v. Wexford VEC. It stressed the importance of schools having adequate and reasonable supervision in place, relative to factors including the age of pupils, the number of students, the locations they congregate, and any other characteristics of which schools are aware, for example, any particularly troublesome students. The court said that no school could possibly supervise all students, all the time, but that once adequate supervision is in place, a school should not then be held accountable for everyday accidents. We should note the phrase "once adequate supervision is in place". I think we would all agree with that position, and that is what this Bill today seeks to ensure.
Why is legislation needed if the courts are generally standing on the side of schools in the great majority of cases? Clearly, despite the courts being onside, schools are still apprehensive. Why else would they be imposing no-running policies and so on? There are a couple of possible reasons that I said I would come to.
First, as we know, when it comes to insurance claims, there is an iceberg effect whereby the only legal claims we see are those which are before the courts. Insurance companies are often willing to settle rather than fight claims which they are confident of winning. This is not due to laziness or incompetence on their part but a simple cost-benefit analysis. The cost of fighting a case, particularly the prospect of not being able to recover legal costs if the schools win the case, will often lead insurers to go for a quick settlement. This has the effect of adding to premiums for the school and all schools, and adds to the anxieties of school management about minor accidents. I am not saying that a direct result will be an increased premium in individual cases but over time all schools will be affected.
Second, teachers and school management are human beings who operate in a high-stress environment and with limited budgets. The prospect of dealing with a phalanx of solicitors and barristers over schoolyard accidents is obviously far less preferable than the easier option of curtailing sports or implementing so-called “no running” policies. I was also concerned to find, quite by accident, a firm of solicitors in Cork that loudly advertises its work in taking litigation against schools for such injuries. I hope that is an isolated case because if not it would significantly add to this problem.
We know that just because the courts tend to side with schools now is no guarantee that this view will continue to apply in the future in the absence of clear legislative guidance. In the fourth edition of McMahon and Binchy’s book, Law of Torts, which is agreed to be the seminal work on Irish law in this area, and apologies to any rival writers and thinkers who might be in the room and elsewhere, the authors discuss litigation against schools and give the following warning:
the problems of care and control in a school bear some resemblance to those confronting a parent in the home but they are far from identical. It is possible that in a future decision an Irish court will drop the reference to careful parent and stress the fact that it is the standard of the reasonable school teacher or manager which should prevail.
In other words, McMahon and Binchy warn that the standard of care might be changed in future. A higher standard of care might be expected of a teacher who is after all employed by the State than would be expected of a parent, which would then expose schools to significant additional liability. My Bill would preclude that possibility by writing the "prudent parent” test into statute law.
The Bill inserts a new section 51Q into the Civil Liability Act 1961, and its effects are set out in the explanatory memorandum. Section 51Q(1) would protect a school from liability for injury to a student on its premises, provided that it has an adequate system of supervision in place and that the school is in compliance with health and safety standards which are applicable to it under health and safety law, and regulations which the Minister for Education can impose on it. This would effectively codify the judgment of the Supreme Court in Murphy v. Wexford VEC, which found that it is unfeasible to have all children under constant supervision, but a school does have a duty to have reasonable supervision in place depending on the particular circumstances.
Section 51Q(2), (3) and (4) protects a school from liability for any act done in good faith by a teacher, another staff member or a volunteer who intervenes in good faith to aid a child in an emergency but where, for whatever reason, that good faith act ends up causing injury to the child. This mirrors the Good Samaritan provisions which already exist in the 1961 Act.
Section 51Q(5) would enshrine in statute that the standard of care, which applies to teachers and other school staff, shall not be greater than the standard of care that would be expected of a reasonable and prudent parent, which again enshrines recent judicial practice in statute. It is important to note that if schools are absolved from negligence in such cases, parents cannot then seek to sue a teacher who has acted in good faith in the course of his or her employment. Under the law on vicarious liability, only a school could be held accountable for the actions of a teacher in the course of his or her employment. Under common law, a teacher could only be held accountable if he or she acted in bad faith or conducted himself or herself in a grossly negligent manner. Section 51Q(6) provides a standard carve-out recognising this aspect.
I am aware of the fact that there is occupier's liability ar na bacáin, mar a deir siad i gConamara. It does suggest, if you like, lessening the burden on occupiers. It is my view that particular legislation is necessary to give the necessary comfort to schools in this context mirroring the attitude generally taken by the court but mindful that there still appears to be a negative culture around playground recreation and that necessary bolstering of the protections for schools is desirable in legislation. On that basis I commend this Bill to the House. I am delighted that I have left more than two or three minutes for my eminent seconder behind because I know that whatever he has to say will make eminent good sense.
I want to express my complete agreement with the sentiments expressed by Senator Mullen on all fronts. It seems to me that we are here dealing with a problem which, based on some of the case law that has been mentioned, one might think the problem does not exist to the extent that it does. Senator Mullen has put his finger on one very important point and that is the iceberg principle, namely, that the great majority of cases which come to report and are reported are where schools are in fact found not guilty of negligence but it is in those circumstances that the Judiciary has expressed its views on the standard of care. The reality is that any claim for personal injuries for any child injured in any of the circumstances mentioned by Senator Mullen involves significant outlay by insurers, significant application of time and effort by the management of a school which has other things to do and there is always a risk factor. We cannot get away from the fact completely that the more serious the injury, for example, supposing a child fractures his or her skull as a result of a fall, a fall which might otherwise have resulted in a simple sprain of the wrist, some members of the Judiciary will take a more stringent view of the duty of care owed to the child simply because of the extent of the child's injury. Second, because judges are human, and even though we now have personal injuries guidelines, there are judges who are more favourable to plaintiffs than others and that is a fact. An insurance company has to bear in mind who this case is going to be heard before, how serious are the injuries, what the risks are and will eventually compromise, in a lot of cases, in the circumstances adverted to by Senator Mullen.
This legislation is definitively needed. I am glad that Senator Mullen mentioned the upcoming proposal to alter the law concerning civil liability for occupiers because, in my view, that is also overdue. I think that occupier's liability again is an instance where artificially high standards of proof are applied to the homes, lands and premises of strangers, which people do not apply in their own life. We trip over our own garden stones, trip over this, fall down here or drop ladders here and there, for example. Things happen in our own lives. We fall off bicycles and injure ourselves or whatever in our own lives and we do not consider for a moment suing somebody but where we can hang it on the nail of occupier's liability then different standards seem to apply.
Lastly, in the context of the legislation that the Government is proposing or, indeed, if this Bill gets to its next stage, the time has come to look not merely at occupier's liability or school management's liability but also at those people who organise voluntary activities within our communities. I refer to people who organise sports occasions or rural events such as horse shows and the like. We are slowly throttling all of that voluntary activity by insisting that all of these activities are the subject of insurance. The insurance premiums that are payable are driving voluntary activity out of existence right across the board.
I would propose that in the case of certain specified activities of a voluntary kind, the standard should be gross negligence, not merely arguable negligence, on the basis that would be applied in a commercial context. Volunteerism in Ireland is under threat and the time has come to look at civil liability to see whether we can amend the law to make volunteerism more acceptable and less costly for the organisers.
I commend the proposers of this practical and pragmatic Bill which is worthy of debate and support. I will come back to the last comment made by the seconder of the Bill, Senator McDowell, my esteemed colleague, which we spoke about on the Order of Business this morning, namely, volunteerism and how important it is to our society, communities, school life and those who are involved in the heart of society. We have to be concerned at the wane of volunteerism, and the fear of litigation is one of those areas that is really stopping people from becoming involved. Therefore, this Bill is timely.
Senator Mullen outlined clearly the concern around litigation that a lot of schools and boards of management have. Boards of management are bodies of volunteers and they put in incredible work on a year-round basis to try to ensure schools are safe and secure places. They seek to ensure children have a good and supportive education and that this education is as inclusive and empowering as possible. They have a lot to deal with and, on top of that, there is a real fear of litigation, particularly in relation to the schoolyard. It is good to put words around it, speak about it and say we need to do more on it. Like the proposer, I know anecdotally of a number of schools and parents who have spoken about situations where their children are told they cannot run or jump in schoolyards for fear of falling. The vast majority of parents would take no action in the event of a potential mishap and it is just part of growing up, but unfortunately there are always the few who will. That is why we have to put safeguards and legislation in place.
The purpose of this Bill is noteworthy: to offer a level of legislative protection to schools engaged in activities while on school premises. Then we have the wider view, which is important. I honestly believe schools should not just be open from 9 a.m. to 3 p.m. and just be open during term time. I have a strong belief that school facilities should be used by other social, educational and sporting organisations when we see that the new schools that are being built, in particular, are incredible. Their facilities are second to none and they should be made available to the wider community. I acknowledge that the summer provision happens in schools, which is important and is in the Minister of State's area of responsibility, and that is another good use of schools.
I know the Minister of State, the Department and the Minister, Deputy Foley, support the overall positive objective of this Private Members' Bill and that they feel it is important that greater legal certainty would be provided to schools in terms of supporting how this Bill, if enacted, would help. I am also aware, however, that the Office of the Attorney General has advised that the Bill would benefit from some further analysis and consideration to ensure no unintended consequences arise. I have no doubt the proposer and seconder would be amenable to that.
That is what Committee Stage is all about.
Absolutely. I am conscious the Attorney General said there may be some technical issues around the drafting of the Bill that may need further consideration, but I know from what my esteemed colleagues have said that they would be happy to have that considered.
There is no more for me to say and there is no point in me going through the Bill as the proposer has done that eloquently. I wish the Bill well in its progress.
I welcome the Minister of State to the House and thank her for being here for this important debate. I am covering for Senator Dolan, who could not be here today, but I acknowledge her support for what this Bill is trying to do. I thank the Senators for putting this Bill forward, including Senator Mullen, and for outlining quite well what this entails. An awful lot of it is common sense.
In schools in recent years there has been so much pressure on staff and on principals in particular. There have been worries with managing staff, parents and kids and they have had an awful lot on their plates. This is one other element where they would have genuine concerns if something happened. If we are getting to a point, as Senator Mullen said, where kids are being told not to play chase when they are seven, eight or nine years old, then we are getting to the stage of being ridiculous. Senator Mullen said it well when he said this is about prudent parents. I would argue that even the most prudent of parents would agree that supervision of their children would be better in school than it would be in their backyards. If there is an element of trust between parents and principals in schools, then we must recognise that supervision is of high importance for schools but accidents just happen. I broke my hand while playing in school, and I just went straight to hospital and there was no consideration of who was at fault, what we should have done or anything like that. It just happens and that is the nature of being a child.
It is important we discuss this. As Senator O'Loughlin has said, the Attorney General has asked for more time to review this, and that is probably the right thing to do. It is hard to argue with anything that has been said from the opposite side, however. When it comes to normal primary schools, a bit of common sense is all that is needed. People will get hurt, they will fall and they will break arms. Kids will play with each other and hurt each other. Principals are working on other issues well beyond the time schools close, and they should not have to worry about preparing for court cases with parents of children who break their hands. We should not be getting to that stage and it is a waste of time for the courts to be dealing with it. It is good to see that those cases Senator Mullen outlined showed that common-sense approach.
I will pick up on what Senator O'Loughlin said about new schools. We have a new primary school in Cahir, which is one of the biggest in the country. It is a giant school where the boys' and girls' schools have come together to build a new school which is being opened next month by the Taoiseach. It is an incredible school, and the Minister of State will know it because she was helpful in funding it when we had challenges at the start of this term. They have been waiting 16 years for this school to be built. This school is open to the public and for groups to use outside of school hours, which is important. A caretaker could be there and you could have keys to go into the school or the main hall but the rest of the school is closed completely, so it is almost like you are just going into the hall. The way these schools are built now is dramatically different from back in the day. That utilisation Senator O'Loughlin was talking about can be much more, certainly in rural Ireland.
I acknowledge the work Senator Mullen and others have put into the Bill. We certainly should look at the proposals it contains to take some unnecessary pressure off principals and school staff.
I commend the proposer, Senator Mullen, and the seconder, Senator McDowell, on putting forward this Bill. I agree with Senator Ahearn that it contains a lot of common sense. In a previous life back in the 1980s, as a young primary school teacher, I was involved in many extracurricular activities with pupils. I was horrified to note that, in later years, when my children were in primary school in the 2000s and mid-2010s, new rules meant pupils were not allowed to run or explore their environment to the same extent. That limits children's potential. This legislation is to be welcomed and it would be great if the Government could support it.
At the height of the Celtic tiger, I recall reading an article in the Financial Times about primary school principals in London, whose skill sets were compared with those of the chief executive officers of big multinational companies. The study concluded that principals and teachers in primary schools exercise a broader range of skills than do the CEOs of the largest multinational companies. Principals and teachers deal with a large number of stakeholders, including parents, boards of management and agencies. One issue they should not have to deal with is the type of litigation to which Senator Mullen referred, with some legal firms advertising their ability to take on schools over minor scratches, falls, trips, spills and so on.
As I said, I support Senator Mullen's Bill and I hope the Government is in a position to support it.
As Minister of State with responsibility for special education and inclusion, I welcome the positive intention of the measures contained in the Bill put forward by Senator Mullen and supported by Senators McDowell, O'Loughlin, Dolan, Ahearn and Clonan. We all agree that schools are designed to be safe places for children and staff. To protect the school community, schools are required to have a safety statement in place to identify potential hazards, assess the risks to health and safety and put appropriate provision in place to ensure, as far as is reasonably practicable, the safety, health and welfare of all members of the school community. That will not change. The approach set out in the Bill provides a greater legal certainty to schools by providing them with protection against liability for injury to students arising from accidents occurring on school premises, provided an adequate system of teacher supervision is in place and the school has complied with the applicable health and safety regulations. This level of legislative protection for schools engaged in activities, including reactional and physical activities, while on school premises is positive.
The importance of physical activity among all sections of the community, particularly young people, is clearly set out in the programme for Government, which contains a range of commitments to encourage and enable increased levels of physical activity among children. Physical education supports students to develop a disposition towards, motivation in and commitment to lifelong physical activity. There are significant developments across primary and post-primary physical education curriculums. As students experience broad and balanced PE programmes, they learn to become more positively disposed and motivated to commit to lifelong physical activity. The primary curriculum emphasises the importance of play in its many forms in the learning and developmental process. Through play, children learn to move effectively, think, interact socially with others and express feelings. By encouraging children to take part in physical activity and active games, we can help them to develop good habits that will prove invaluable throughout their lives.
Recreation and physical activity are associated with numerous health benefits in children, including effective prevention of a number of lifestyle-related diseases. Research shows outdoor play experiences provide multiple physical and mental benefits for children. These include reduced obesity levels, increased physical activity, improved concentration and enhanced social skills. Opportunities for outdoor play offer many benefits for learning, including an increased ability to focus and concentrate when children return to the formal classroom. Along with physical and cognitive benefits, outdoor play provides rich opportunities for the development of social skills such as communication and collaboration as children negotiate peer interactions and engage in minor conflict resolution. The combination of physical, social and emotional skills is critical to the holistic development of the child. A play break can refresh the mind and prepare the child for formal learning in the classroom.
While the Bill proposes a greater protection to schools than currently exists in easing the duty of care that is applied to and expected of them, I acknowledge this protection will only apply provided an adequate system of teacher supervision is in place and the school has complied with the applicable health and safety regulations. In effect, the protections afforded to schools only apply if the school adheres to current statutory health and safety requirements and Department policy. That is only right and proper. It is a reasonable and practical approach that a school would not be liable in negligence for any act done by a teacher providing assistance, advice or care to a student where the student is in serious and imminent danger of being injured. It is also reasonable that protections should apply to teachers providing advice or care to a student, including the administration of first aid or a student being transported to a hospital to receive medical care. It is reasonable that the standard of care applicable by teachers is that of a prudent, responsible and reasonable parent acting in equivalent circumstances.
As Senator O'Loughlin noted, the Office of the Attorney General has advised that while the purpose of the Bill is positive, it would benefit from further analysis and consideration to ensure there are no unintended consequences for schools. There are also technical issues with the drafting of the Bill that will need further consideration and potential amendment. I fully appreciate the well-meaning intentions of the Senators in bringing forward these provisions. On balance, the approach taken in the Bill is positive. Both the Minister, Deputy Foley, and I look forward to working with the Senators as it progresses. We all agree on the importance of children having the opportunity to enjoy recreational activities and that schools must be empowered, without fear or overbearing caution, to provide such opportunities.
I am grateful to the Minister of State for her reply and for her support and that of the Government for the Bill. She summarised admirably the importance of play. I never realised during my days in the schoolyard how much I was learning about social interactions, dealing with my fears and all those issues. It is all absolutely true. The reference the Minister of State made at the end of her response to "overbearing caution" and the need to avoid it is right on point.
I am very grateful to all colleagues who spoke in this debate. I thank Senator McDowell for seconding the Bill. He stressed the significance of the iceberg principle and reiterated some of the concerns I laid out from the perspective of his long and high level of experience in the courts. I am also grateful to Senators O'Loughlin and Ahearn and to my friend and colleague in the Seanad Independent Group, Senator Clonan, for their support for the Bill.
I apologise for going through my opening speech at pace. I was conscious I had somebody very knowledgeable coming after me to second it and I wanted to cover all the ground. These closing speeches are the YouTube moments in which we can say what we want in a more relaxed way. I am conscious we will be getting out to the schoolyard earlier than I had expected this evening. I might get to address my own risk of obesity, if not childhood obesity, as a result of the relative shortness of the debate. That shortness reflects the consensus in the House in favour of this legislative move.
As I said, the courts have been sensible and are mostly not amenable to unjustified litigation to the disadvantage of schools. Yet, there is still a problem. The iceberg effect leads to cases being settled to avoid hassle and perhaps to avoid the inability to recover costs. All of this means there may be cases we do not know about that are being settled, which is to the disadvantage of the playground experience in schools because it leads to the overbearing caution the Minister of State described.
As I said, this has been stressed at the Oireachtas Joint Committee on Children, Equality, Disability, Integration and Youth. It would be good if that survey that was mentioned and recommended at the committee were to be carried out to assess the extent to which there may continue to be a problem here, notwithstanding that it is proposed to accept this legislation going forward. That kind of information would be useful and important. It is not just about the legislative change that we make to give comfort and reassurance to schools. It is also about creating a culture that is in favour of and that reassures people that the playground experience is important and that reasonable risks can be run, stressing again that what this legislation does is provide a defence for a school where there is an adequate system of supervision in place, as the Minister of State said, where the statutory and departmental requirements are being met, and that it protects the so-called Good Samaritan, namely, the teacher who intervenes to help a child who is injured or ill, perhaps bringing him or her to hospital or some other place until he or she can get the treatment he or she needs or, indeed, administering first aid. It is unconscionable that a school would be liable for something that might happen in that context except, of course, as my Bill lays out, where there is evidence of bad faith or gross negligence. Of course, liability would arise in that situation. There is no need for me to labour the point any further.
I am grateful for the support for this Bill. I might talk to the Government to see whether it would be possible to get some more time to hasten the passage of this Bill through the Seanad, taking on board, which I am delighted to do, the insights and expertise of the Attorney General, his office and others to make sure this Bill does exactly what is required. I thank the Minister of State and my colleagues.
Question put and agreed to.
When is it proposed to take Committee Stage?
Next Tuesday.
Is that agreed? Agreed.
Committee Stage ordered for Tuesday, 25 April 2023.
When is it proposed to sit again?
At 9.30 a.m. tomorrow.
Cuireadh an Seanad ar athló ar 5.42 p.m. go dtí 9.30 a.m., Dé Déardaoin, an 20 Aibreán 2023.
The Seanad adjourned at 5.42 p.m. until 9.30 a.m. on Thursday, 20 April 2023.