G.E v The Commissioner of An Garda Siochana (Unapproved)

A second matter arises from the unapproved judgment.� As I have noted, the plaintiff�s name was anonymised in that judgment, as it had been in the High Court.� I infer that the trial Judge adopted this course of action having regard to s. 26 of the International Protection Act 2015.� It provides as follows:

(1) The Minister and the Tribunal and their respective officers shall take all practicable steps to ensure that the identity of applicants is kept confidential.

(2) A person shall not, without the consent of the applicant, publish in a written publication available to the public or broadcast, or cause to be so published or broadcast, information likely to lead members of the public to identify a person as an applicant.

In MARA (Nigeria) v Minister for Justice and Equality [2014] IESC 71 , [2015] 1 IR 561 (� MARA� ) �Charleton J. explained that the effect of s. 19 of the Refugee Act 1996 (the predecessor of s. 26 of the 2015 Act) was as follows:

�[t]he plain and unambiguous result of the wording is, clearly, that once a person has applied for refugee status that they retain anonymity with regard to any litigation relevant thereto in perpetuity. Should there be unrelated litigation, such as a factory accident, that protection remains and, while the tort case may be reported normally, any mention of any prior failed application for refugee status may not be reported publicly.� �