High Court refuses newspaper reporter access to private custody hearing, balancing public interest against privacy rights.
Legislator-Zusammenfassung
KI-generiertTimes Newspapers Limited applied to the High Court for permission to have a reporter attend a private motion regarding child custody. The father, litigant in person, sought to strike out a previous order while the newspaper argued for transparency. The court refused the application, holding that the specific proceedings involved private family matters where the public interest in reporting did not outweigh the need for privacy and the protection of the children's welfare.
Legislator-Regeste
KI-generiertArticles 17 ust. 1 k.r.s.; Article 6(1) ECHR: Courts must make judgments public unless it constitutes a denial of justice, but no discretion exists to permit reporters to attend private hearings where the public interest in reporting is outweighed by the need for privacy in family law matters.
Schlagwörter
KI-generiertZitierte Gesetzesbestimmungen
KI-generiertZitierte Rechtsprechung
KI-generiertVerwandte Entscheide
KI-generiertVolltext
Neutral Citation: [2013] IEHC 578
T HE HIGH COURT
FAMILY LAW
[2012 No. 97 and No. 98 CAF]
IN T HE MAT T ER OF T HE JUDICIAL SEPARAT ION AND FAMILY LAW REFORM ACT 1989 AND IN T HE
MAT T ER OF T HE FAMILY LAW ACT 1995
BET WEEN
A.B.
APPLICANT /RESPONDENT
AND
C.D.
RESPONDENT /APPELLANT
JUDGMENT of Mr. Justice Keane delivered on the 9th December 2013
Background
1. This is an application brought by Times Newspapers Limited ("Times Newspapers") to be permitted to
have a reporter attend the hearing of a motion in these proceedings for the purpose of reporting upon it,
subject to the imposition of whatever conditions on such reporting the Court may deem necessary or
appropriate.
2. The underlying proceedings have been brought under the Judicial Separation and Family Law Reform Act
1989 and the Family Law Act 1995. The parties have been in litigation for over a decade. They are now
divorced and the remaining issues between them centre on the custody and care of their minor children.
3. In the motion the hearing of which Times Newspapers wishes to report, the respondent/appellant (“the
father”), as a litigant in person, seeks an Order "striking out and/or setting aside" an Order made by Abbott
J. in this Court on the 28th February 2013. That Order addresses a number of custody and access issues
concerning two minor children of the parties. For completeness, it should be noted that, on the 21st July
2010, Abbot J. had made an Order addressing broadly the same issues on the facts as they then stood. The
provisions of that Order were overtaken by subsequent events. Those events precipitated a number of
applications to the Circuit Court. The resulting Circuit Court orders were then appealed to this Court,
culminating in the making of the Order the father now seeks to impugn.
4. The father seeks to have that Order struck out or set aside by reference to a particular matter addressed
in the judgment of Abbot J. delivered on the 1ih July 2013. At paragraph 7 of that judgment, Abbot J.
states:
"I asked [the mother] if, after the making of the High Court order [of the 21st July 2010]
but before the furnishing of reasons [in a judgment delivered on the 26th July 2011],
she asked a Dail Deputy to make enquiries for her in relation to the matter from the
judge, and that the Dail Deputy sought the services of a Circuit Court judge to ask me
was it a fact that [one of the parties' minor children] had been sent away to the primary
care of the father. She agreed that she had made that approach to the Dail Deputy and
apologised on the basis that it was at a time when she was unrepresented. I informed
the court that on being asked the question by the Circuit Court Judge (quite improperly),
I replied that a judgment would issue on the web in due course in relation to the
matter."
5. At paragraph 10 of that part of the same judgment, headed "Findings", Abbot J. concluded (on the
relevant point):
"I indicated to the parties that notwithstanding the entirely improper interference of
mother via political representative and judge, that I did not propose to disqualify myself
such as other judges might have done in the circumstances and the parties proceeded to
authorise me to speak to [the minor child concerned] on the P.OD v. SJN principle, which
would indicate consensus of the parties that I should continue to act, notwithstanding
this impropriety by mother and her fellow actors."
T he present application
6. The proceedings in which the motion before the Court has been brought are proceedings under the
Judicial Separation and Family Law Reform Act 1989 ("the 1989 Act") and the Family Law Act 1995 ("the
1995 Act").
7. Section 34 of the 1989 Act provides that “Proceedings under this Act shall be heard otherwise than in
public.” Section 38(6) of the 1995 Act provides that the provisions, inter alia, of s. 34 of the 1989 Act "shall
apply to proceedings under this Act in the High Court."
8. Times Newspapers applies to be permitted to report on the hearing of the present motion in reliance on
two arguments. The first is that the father's application to "strike out or set aside" the impugned Order
must properly be viewed as a separate proceeding that does not attract the application of the in camera
rule that applies to proceedings brought pursuant to each of the statutes under which the present
proceedings have been instituted and maintained. The second, or alternative, argument is that, even if the
father's application is not a separate proceeding, this Court retains a discretion to permit it to be heard in
public, subject to the imposition by the Court of whatever conditions are deemed necessary to properly
balance the privacy and family rights of the parties and their minor children, on the one hand, with the
freedom of expression rights of the media and general public, on the other.
9. The applicant/respondent (“the mother”) opposes that application. Having sought to elicit the views of
the father, bearing in mind his status as a litigant in person, I believe it is fair to say that he neither
supports nor opposes the application, as long as any reporting that might be permitted - should it succeed
- contains nothing that would tend to identify either of the parties or any of their children.
T he first argument
10. It was submitted on behalf of Times Newspapers that the father's application to "strike out or set
aside" the impugned Order should not be viewed as part of the family law proceedings in which that Order
was made but (with due regard to the father's status as a litigant in person) should be seen instead as,
say, something in the nature of an application for an Order of Certiorari quashing it by way of Judicial
Review.
11. That submission cannot succeed for two reasons. First, there is clear and incontrovertible authority that
Judicial Review cannot lie against an Order of the High Court. In T he People (D.P.P.) v. Quilligan (No. 2)
[1989] 1 I.R. 46, the Supreme Court (per Henchy J. at 57) pointed out that:
"The High Court.. .is not an inferior court subject to corrective orders such as
mandamus. The Constitution has identified it as a court invested with a full original
jurisdiction in and power to determine all matters and questions of law or fact, civil or
criminal."
In Blackall v. Grehan [1995] 3 I.R. 208, the Supreme Court (per Egan J., Hamilton C.J. and O'Flaherty J.
concurring) again re-emphasised that there is no entitlement to judicial review in respect of an order of the
High Court (at 211).
12. Second, if any relevant jurisdiction does exist that would permit this Court to strike out or set aside an
earlier Order of the High Court on the grounds advanced by the father (which question remains to be
determined), it seems to me that the invocation of that jurisdiction (if it exists) can only occur in the
context of an interlocutory application in the present proceedings, which are proceedings brought squarely
under the 1989 and 1995 Acts. I am strengthened in that view by the following dictum of Murphy J. in R.M
v. D.M [2000] 3 I.R. 372 (at 387):
"Proceedings are what goes on in relation to litigation. It covers all pleadings, evidence,
whether oral or on affidavit and all orders and judgment in relation to that litigation."
T he second argument
13. In asserting that there is a discretion vested in the Court to permit the reporting of proceedings
covered by s. 34 of the 1989 Act and s. 38 of the 1995 Act, Times Newspapers cites a number of
authorities.
14. The starting point for its argument is Art. 34.1 of the Constitution of Ireland, which provides that:
"Justice shall be administered in courts established by law by judges appointed in the
manner provided by this Constitution and, save in such special and limited cases as may
be prescribed by law, shall be administered in public."
15. It goes on to point out that s. 45, sub-s. 1 of the Courts (Supplemental Provisions) Act 1961 ("the 1961
Act") provides:
"Justice may be administered otherwise than in public in any of the following cases:
…
(b) matrimonial causes and matters,
(c) lunacy and minor matters
…”
16. Counsel for Times Newspapers referred the Court to the exegesis of s. 45, sub s. 1 of the 1961 Act, set
out in the judgment of W alsh J. in the Supreme Court decision in the case of I n re R. Ltd. [1989] I.R. 126.
Particular reliance was placed on the following passage from that judgment (at 136):
"W hat is to be noted in s. 45 of the act of 1961 is that the cases set out in sub-s. 1 do
not impose any requirement for a hearing otherwise than in a public court but leave it to
the discretion of the judge in question, but naturally the discretion must be conditioned
by the necessary qualification that the doing of justice remains the paramount
consideration. Some of the legislative provisions enacted after the coming into force of
the Constitution purported to require mandatory privacy, and in others it remains a
discretionary matter. These statutory provisions also display a varied and unexplained
choice of words to describe hearings other than in public, such words as 'in camera', "in
private", and "in chambers". Example of the discretionary power of the court are to be
found in the Married W omen's Status Act 1957, (s. 12, sub-s. 4), the Marriages Act 1972
(s. 1, sub-s. 3), and the Companies Act 1963 (s. 205, sub-s. 7) and the provisions of s.
14, sub-s. 2 of the Family Law (Protection of Spouses and Children) Act 1981. This latter
provision which refers to proceedings in the Circuit Court, and in the High Court on
appeal from the Circuit Court, stands in odd contrast to the provisions of sub-s. 1 of s.
14 which appears to be mandatory. There are several statutory provisions requiring
hearings other than in public which are phrased in mandatory terms but it is not
necessary for the purpose of this case to consider the interpretation which should be
given to any such mandatory provision."
17. The provision at issue in this case, s. 34 of the 1989 Act, as applied both in its own right and under s.
38, sub-s. 6 of the 1995 Act, is couched in mandatory, rather than directory, terms.
18. The principal authority on which Times Newspapers relies in support of its application is the decision of
Abbott. J. in M.R. & Anor v. An tArd Chlaraitheoir & Ors [2013] IEHC 91. In that case, the provision at issue
was s. 36, sub-s. 4 of the Status of Children Act 1987 ("the 1987 Act") which provides:
"On the hearing of an application under section 35 of this Act the Court may direct that
the whole or any part of the proceedings shall be heard otherwise than in public and an
application for a direction under this sub-section shall be so heard unless the Court
otherwise directs."
19. In that case, the Court was persuaded that the discretion conferred under that section permitted the
Court to hear the case in private, so that members of the public did not have a right to attend, while
allowing a limited reporting of the case in the public interest. In the exercise of its discretion under s. 36 of
the 1987 Act, and of its discretion under s. 45, sub-s. 1 of the 1961 Act, the Court directed that the
proceedings be heard otherwise than in public but went on to direct and permit certain newspapers to
attend at and report on the proceedings subject, amongst others, to the following conditions:
(1) That each newspaper shall designate a reporter who shall attend at and report upon
the proceedings.
(2) That the identity of the applicant shall not be disclosed and that no matter which
would tend to so identify him or her shall be disclosed.
(3) That the evidence of certain parties shall be given in private and shall not be
disclosed.
(4) That the newspapers concerned and the designated reporters comply with such
further directions as may be made from time to time by the Court in regard to the
reporting of the case.
(5) That no contemporaneous social media reporting e.g. by Twitter shall be carried out
by the designated reporters.
20. In reaching that decision, the Court relied on the persuasive authority of the English Court of Appeal
decision in the case of I ndependent New s and Media Ltd & Drs v. A [2010] 1 W LR 2262, which affirmed the
decision of Hedley J. in the English High Court in that case; [2009] EW HC 2858. The decision of Hedley J.
concerned the question of the proper application of the provisions concerning hearings in private in the
Court of Protection for England and W ales under the relevant Rules of Court made pursuant to Part 2 of the
UK Mental Capacity Act 2005. The UK Court of Protection Rules 2007 create a general rule that a hearing in
the Court of Protection is to be in private, but go on confer an express power on the court to make an order
for a hearing to be held in public "where it appears to the court that there is good reason for making the
order." In that case, Hedley J. concluded that the exercise of the undoubted discretion conferred by the
relevant Rules of Court required the court to balance the competing rights under Article 8 and Article 10 of
the European Convention on Human Rights that were at stake in that case.
21. Times Newspapers submits that the same approach should be adopted in this case. However, this case
is significantly different. Section 34 of the 1989 Act requires that proceedings "shall be heard otherwise
than in public". The use of the word "shall" is usually understood as imposing a mandatory requirement
rather than as conferring a discretion. In M.P. v. A.P. [1996] 1 I.R. 144, the High Court (Laffoy J.) so held in
the following terms:
"Section 34 of the Act of 1989 is mandatory and, in accordance with that provision these
proceedings, including the defendant's motion for attachment and committal, being
proceedings under the Act of 1989, have been held otherwise than in public."
22. R.D. v District Judge McGuinness [1999] 2 I.R. 411, was a case that concerned the proper interpretation
of s. 16, sub-s. 1 of the Domestic Violence Act 1996, which provides that: "Civil proceedings under this Act
shall be heard otherwise than in public." Macken J. referred to the "clear mandatory words of that section",
in finding that, save possibly in exceptional circumstances, the entitlement to be accompanied by a
"McKenzie Friend" could not extend to "cases of a matrimonial nature".
23. Again, in R.M v. D.M. [2000] 3 I.R. 373, Murphy J. noted:
"Laffoy J. in MP. v. A.P. [supra] refers to s. 34 as mandatory. To that extent the
interests of resolution of family disputes in private outweighs the public right that
justice be administered in public."
24. In DX v. District Judge Buttimer [2012] IEHC 175, Hogan J. considered the constitutional background to
the in camera rule under the 1989 Act, noting:
"5. Article 34.1 of the Constitution provides that justice is to be administered in public,
save "in such special and limited cases as may be prescribed by law." ... It is true,
however, that s. 34 of the Act of 1989 provides that judicial separation proceedings
"shall be heard otherwise than in public" and this section must be taken to constitute
such a special and limited case for the purpose of Article 34.1.
6. The language of Article 34.1 nevertheless reflects the Constitution's preference for
the open administration of justice and derogations from that rule must truly be confined
to "special and limited cases prescribed by law" in the relatively narrow sense of that
term. In the present case, the exception prescribed by s. 34 of the Act of 1989 must be
taken as reflecting a desire by the Oireachtas to protect other constitutional values in
the context of family law proceedings such as the right to privacy (Article 40.3.1), the
authority of the family (Article 41) and the protection of the constitutional rights of
children (Article 42.5). It is in that context that s. 34 of the Act of 1989 falls to be
interpreted."
25. It seems to me that, in enacting s. 34 of the 1989 Act, the Oireachtas chose to conduct the necessary
rights balancing exercise itself, concluding that, in the limited sphere of proceedings under the Acts of 1989
and 1995, constitutional values of the kind identified by Hogan J. are sufficient to prevail over the
competing constitutional interests that otherwise mandate the administration of justice in public.
26. In my view, legislation such as the 1989 Act, which attempts to balance a number of constitutional
rights, is entitled to be treated with heightened deference by the courts. In T uohy v Courtney [1994] 3 I.R.
1, a case concerned with a constitutional challenge to a provision of the Statute of Limitations 1957, as
amended, Finlay C.J. stated as follows (at 47):
"[T]he Oireachtas in legislating for time limits on the bringing of actions is essentially
engaged in a balancing of constitutional rights and duties. W hat has to be balanced is
the constitutional right of the plaintiff to litigate against two other contesting rights or
duties, firstly, the constitutional right of the defendant in his property to be protected
against unjust or burdensome claims and, secondly, the interest of the public
constituting an interest or requirement of the common good which is involved in the
avoidance of stale or delayed claims.
The Court is satisfied that in a challenge to the constitutional validity of any statute in
the enactment of which the Oireachtas has been engaged in such a balancing function,
the role of the courts is not to impose their view of the correct or desirable balance in
substitution for the view of the legislature as displayed in their legislation but rather to
determine from an objective stance whether the balmice contained in the impugned
legislation is so contrary to reason and fairness as to constitute an unjust attack on
some individual's constitutional rights."
27. The balance of constitutional rights at issue in the present application was recalibrated by the
Oireachtas through the enactment of s. 40 of the Civil Liability and Courts Act 2004 ("the 2004 Act"). The
position in law whereby s. 34 of the 1989 Act operated to deprive a litigant in proceedings under that Act of
the strict entitlement to be accompanied by a "McKenzie Friend", as found by Macken J. in R.D., was
reversed by s. 40, sub-s. 5, which expressly recognises that entitlement.
28. Similarly, s. 40, sub-ss. 6 and 7 of the 2004 Act provide for the disclosure of documents prepared for,
and information or evidence provided in, proceedings heard in camera under, inter alia, the 1989 and 1995
Acts.
29. Most significantly in the context of the present application, s. 40, sub-s. 3 of the 2004 Act expressly
exempts from, inter alia, the general in camera requirement under s. 34 of the 1989 Act, any report of
proceedings prepared by a barrister, solicitor or member of any class of persons specified in regulations
made by the Minister for Justice, as well as the publication of any such report, provided it is done in
accordance with the applicable rules of court and does not identify the parties. The subsection goes on to
provide that the person concerned may attend the relevant proceedings for that purpose, subject to the
direction of the court.
30. There is nothing in that subsection (or in the rules made under it by the Minister) that includes a bona
fide representative of the press as a person or member of a class of person thereby exempted from the
operation of the in camera rule created under s. 34 of the 1989 Act.
31. Accordingly, even if this Court were persuaded that the competing constitutional and Convention rights
at stake in this case should be balanced in the same way as they were by Abbott J. in M.R. in the exercise
of his discretion under s. 36 of the 1987 Act and s. 45, sub-s. 1 of the 1961 Act, or as they were by Hedley
J. in I ndependent New s and Media Ltd in the exercise of the undoubted discretion conferred on the Court of
Protection for England and W ales by the UK Court of Protection Rules 2007, it does not seem to me right
that the Court should seek to impose its own view of the correct or desirable balance in substitution for the
view of the Oireachtas as expressed in the specific legislative provisions now at issue.
32. Before concluding on this point, there is one significant countervailing authority that requires to be
considered. Health Service Executive v. McAnaspie [2012] 1 I.R. 548 was a consultative case stated in
which the High Court had to consider, inter alia, the proper construction of s. 29, sub-s. 1 of the Child Care
Act 1991 ("the 1991 Act"), whereby proceedings under identified parts of that Act "shall be heard otherwise
than in public".
Birmingham J. noted that "[o]n its face, the requirement that proceedings should be heard otherwise than
in public might be thought to afford a considerable measure of discretion as to how the proceedings should
be conducted." Even though the wording of the in camera rule under s. 29 of the 1991 Act is identical to
that of the equivalent rule under s. 34, the court in McAnaspie concluded that "the [District Court] has
jurisdiction to permit the media to attend and report on [a District Court application for the disclosure to a
deceased child's next-of-kin of guardian ad litem reports prepared in the context of child care proceedings
concerning that child]."
33. Significantly, in reaching that conclusion, Birmingham J. expressly acknowledged (at 567):
"However, a different approach was taken by Murphy J. in R.M v. D.M (Practice: in
camera) [2000] 3 I.R. 373. Murphy J. reconciled the diverging case law by taking the
view that the cases of Eastern Health Board v. Fitness to Practise Committee [1998] 3
I.R. 399 and A County Council v. W (Disclosure) [1997] 1 F.L.R. 574 related to the in
camera rule in relation to minors, and that the decision of Laffoy J. in MP. v. A.P.
(Practice: in camera) [1996] 1 I.R. 144, relating to judicial separation, applied to the
case with which he was concerned. Insofar as Eastern Health Board v. Fitness to
Practice Committee was distinguished as a case involving minors by Murphy J., it would
appear to follow that R.M v. D.M (Practice: in camera) is itself to be distinguished from
the present case."
34. As already noted, while the present case involves minor children, the proceedings are brought under the
Judicial Separation and Family Law Reform Act 1989 and the Family Law Act 1995, and family life and
privacy interests are plainly directly engaged, beyond the obvious privacy interests of the minor children
affected. Accordingly, in my view the present application is more properly governed by the approach
adopted by Laffoy J. in MP. v. A.P. and reflected in the decisions of Murphy J. in R.M v. D.M and Macken J. in
R.D. v. B.D., than by that adopted by Birmingham J. in McAnaspie.
Conclusion
35. It is important to bear in mind that the application of the mandatory in camera rule contained in s. 34
of the 1989 Act is itself subject to two broad qualifications. The first comprises those exemptions in
relation to the reporting of the relevant proceedings, and the subsequent use of reports, information and
evidence associated therewith, created under s. 40 of the 2004 Act, which exemptions have already been
addressed above. In that context, it is useful to note that family mediators, persons engaged in family law
research, and persons engaged by the Courts Service to prepare court reports are each currently a class of
person specified by the Minister for the purposes of s. 40, sub-s. 3 of the 2004 Act, under the 2005
Regulations (S.I. No. 337 of 2005) made pursuant to that Act, whereas bona fide representatives of the
press are not.
36. The second qualification is that confirmed under s. 40, sub-s. 3(b) of the 2004 Act whereby nothing in
s. 34 prohibits the publication of the decision of the court in proceedings governed by that section. It
seems to me that s. 40, sub-s. 3(b) is no more than a restatement of the existing law in that regard, since
s. 34 expressly requires no more than that the proceedings to which it applies "shall be heard otherwise
than in public."
37. In Dow se v. An Bord Uchtála [2006] 21.R. 507, MacMenamin J. set out the relevant underlying principles
in the following way (at 536):
"It is a fundamental principle of Irish law that justice should be administered in public
and that the administration of justice in public is an essential feature of a truly
democratic society.
As a constitutional and legal principle, even if cases are heard in private there may be
issues which are of public concern and where the interest of justice requires that after
the hearing in private the judgment made therein should so far as possible be made
public.
This is clear from the judgment of W alsh J. in the case of I n re R. Ltd. [1989] I.R. 126.
At p. 134 of the judgment W alsh J. observed:
'If part or whole of the proceedings were to be heard other than in public I am
of the opinion that so much of the judgment as does not disclose the
particular information which had been held from publication to be pronounced
in public.'
Thus it seems to me this court must concern itself with those portions of the judgment
that deal with the relevant facts and general legal principles on the one hand; and on
the other to specific areas, which for a number of reasons should remain private. It is
also necessary in carrying out this balancing exercise to have regard to particular issues
to which reference will be made, and also, I am satisfied, to the doctrine of
proportionality.
The court must also have regard to the provisions of article 6(1) of the European
Convention for the Protection of Human Rights and Fundamental Freedoms 1950 which
deals with this issue. As a general principle of Convention Rights, as well as under the
Constitution, courts must make their judgments public unless such a course of action
would constitute a denial of justice. Even if a court concludes that the publication of
certain matters in the judgment would constitute such a denial, then it must
nevertheless publish as much of the judgment as is possible without bringing about
such a denial of justice. These issues have been dealt with by English authority Pelling
v. Bruce-Williams [2004] EW CA Civ 845 [2004] Pam. 155.
I should also have regard to the precedent in relation to the decision in I n re a Ward of
Court (withholding medical treatment)(No. 1) [1996] 2 I.R. 73 where the judgment of
both the High Court and Supreme Court were delivered in public because of the
importance of the principles involved, although the evidence at first instance was heard
in private."
38. I am satisfied that those are the principles that must apply to the decision of the Court on the motion
now before it. However, for the reasons set out above, this Court has no discretion to permit Times
Newspapers to have a reporter attend the hearing of the motion for the purpose of reporting upon that
hearing. Accordingly, the application of Times Newspapers must be refused.