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THE HIGH COURT [2026] IEHC 202 [2024/6852P] BETWEEN PATRICK McGREAL PLAINTIFF AND BRIDIN CONCANNON AND MARIA BROWNE DEFENDANTS ___________________________________________________________________________ THE HIGH COURT [2024/6645P] BETWEEN PATRICK McGREAL PLAINTIFF AND SAM (COURTS SERVICES STAFF), COLIN (COURTS SERVICES STAFF), KIM DUFFY (COURTS SERVICES MANAGER), GARDA A, GARDA SHEEHAN, GARDA C, JAIL GARDA SERGEANT, COMMISSIONER OF AN GARDA SIOCHANA, CHIEF EXECUTIVE OFFICER OF THE COURTS SERVICES DEFENDANTS Judgment (No. 2) of Mr. Justice Cregan delivered on 11th day of March, 2026 Introduction 1. This is the second judgment which I have delivered in these two sets of proceedings. The first judgment, delivered on 7th July 2025, dealt with the question of whether court fees 2 were payable in respect of the two sets of proceedings which had been issued by Mr. McGreal. That judgment also set out the history of the proceedings up to that time and the various abuses of process committed by Mr. McGreal. This judgment deals with (i) challenges by Mr. McGreal to appearances entered on behalf of the defendants and (ii) applications to strike out his proceedings as an abuse of process. 2. The first set of proceedings is McGreal v. Concannon and Browne (record number 2024/6852P) which I will refer to as "the first set of proceedings" or the “Concannon proceedings”. 3. The second set of proceedings is Mr. McGreal's proceedings against various members of the Courts Service, the Garda Commissioner and various gardai (Record no. 2024/6645P) – which I will refer to as “the second set of proceedings” or "the Courts Service proceedings". 4. The background to this dispute is that when Mr. McGreal went to issue his first set of proceedings, the Central Office officials informed him that he would have to pay stamp duty on the plenary summons, and that they would not issue the plenary summons without payment of such stamp duty. In response, Mr. McGreal went on social media to complain about this and on 14th October 2024, Mr. McGreal and about 25-30 of his supporters attempted to gain access to the Central Office. Because of the risk which this group posed to the Courts Services staff, members of the gardaí attended and the group was not permitted entry to the Central Office. As a result, Mr. McGreal then issued his second set of proceedings, against various members of the Courts Service and individual gardai, alleging breach of duty and various criminal offences against members of the Courts Service, and false imprisonment and unlawful detention by members of An Garda Siochana. Again, the Central Office refused to issue the plenary summons in the second set of proceedings until he paid the stamp duty. 3 5. Mr. McGreal then applied to this court, on an ex parte basis, for leave to issue the plenary summons in both sets of proceedings without stamp duty, on the basis that no stamp duty was payable. I made an order, on an ex parte basis, in October 2024 that both sets of proceedings could be issued without stamp duty being paid - subject to the rights of the defendants to argue at a later stage that stamp duty was payable. This issue was argued at a later stage, and I held, in my first judgment, that stamp duty was payable in respect of the first set of proceedings but stamp duty was not payable in respect of the second set of proceedings because it involved allegations of false imprisonment which were exempt from the stamp duty under the relevant statutory instrument. 6. Mr. McGreal then issued his plenary summons in each set of proceedings. The defendants then entered appearances and Mr. McGreal then sought to challenge those appearances. Current applications before this court 7. The current applications before the court are Mr. McGreal’s challenges to the appearances entered by the defendants in both sets of proceedings. These are contained in his motions dated 26th March 2025 and 4th February 2025. 8. Mr. McGreal brought a motion made returnable before this Court on 26th March 2025 in the first set of proceedings in which he sought the following orders: "An order removing the state-funded legal representation currently provided to the first and second defendants on the following grounds: (i) that their alleged actions fall outside the scope of their statutory duties and therefore are not entitled state-funded defence; (ii) that the provision of state funds for their defence has no legal basis under article 11 of the Constitution which governs the allocation of public monies; 4 (ii) an order declaring that public funds should not be used to finance the legal defence of individuals accused of acting outside the statutory functions. (iii) An order directing the Chief State Solicitor's Office – which is a designated legal service assigned to the office of the Attorney General for civil litigation exclusively on behalf of the government and its departments – to cease representing the first and second defendants as they are private individuals defending allegations of personal misconduct. (iv) Such further and other relief as the court seems just and convenient.” (Emphasis added.) 9. Mr. McGreal also brought a similar motion in the second set of proceedings which was also made returnable before this Court on 26th March 2025. 10. In Mr. McGreal’s notice of motion in the second set of proceedings he sought the following orders: "(i) An order removing the state-sponsored legal representation provided to the first second and third named defendants on the basis that their alleged actions fall outside the scope of their statutory duties; (ii) The state has no legal basis under article 11 of the Constitution to fund their defence; (iii) An order declaring the public funds shall not be used to defend individuals accused of acting outside their statutory functions; (iv) An order directing that Mason Hayes and Curran LLP cease representing the first, second and third named defendants as they are private individuals defending allegations of personal wrongdoing; (v) An order affirming that the ninth named defendant, as Commissioner of An Garda Siochana, and the tenth named defendant, as chief executive officer of the 5 Courts Service, are entitled to state funded legal representation under vicarious liability principles, as their liability arises from their role as head of the institution rather than personal wrongdoing.” (Emphasis added.) 11. The plaintiff is a litigant in person, and, in both sets of proceedings, he has brought numerous motions before the court. He has brought ex parte applications for leave to issue various motions, most of which I have granted. Usually, he has subsequently issued those motions in terms of the ex parte docket; however, on some occasions, he has abandoned these motions; on yet other occasions he has issued motions that contain some amendments from the original ex parte dockets. This, of course, has given rise to enormous confusion and difficulty both for the court and for the various defendants to these proceedings to ensure that they are responding properly to the applications which the plaintiff has brought before the court. The plaintiff's application on 4th February in relation to appearances in both sets of proceedings 12. The plaintiff’s motion of 4th February 2025 also included an application to strike out the appearances entered by the defendants in the first set of proceedings on the basis that they had no lawful right to have appearances entered on their behalf by the Chief State Solicitors Office (“the CSSO”). This related to the plaintiff's submission that he had sued Ms. Concannon and Ms. Browne in their personal capacity and they were not entitled to use state funded solicitors to represent them and/or to enter appearances on their behalf. 13. The plaintiff also complained that Mason Hayes and Curran, a firm of solicitors, could not file an appearance for the defendants they represented in the second set of proceedings, because it was an LLP, not an individual solicitor. He maintained that only a named solicitor – not a law firm or an LLP or the CSSO – could enter an appearance under order 12 rule 6 of the Rules of the Superior Courts. 6 14. As I said at paragraph 29 of my first judgment, "As such, he said the defendants were not properly represented and had not entered valid appearances. This issue has still to be considered by me." 15. I am, therefore, in this judgment also considering similar complaints made by the plaintiff in earlier motions before the court that the appearances entered by the defendants were somehow unlawful. 16. This is of relevance because the plaintiff in the hearing of the motions on 26th March 2025 complained that the defendants were relying on affidavits filed in earlier motions before the court and that this was somehow improper. I reject this submission. It is entirely reasonable for the defendants to rely on affidavits which they have filed in previous motions brought by the plaintiff (i.e. 4th February 2025) in which the plaintiff has sought reliefs similar to, if not identical with, the applications which he has sought in the motions before the court on 26th March 2025 (which motions are also the subject of this judgment). 17. At paragraph 74 of my first judgment, I stated that I would first consider the issue about whether court fees were payable and, after that matter had been heard and determined, that I would then consider in this second judgment, Mr. McGreal's applications about the unlawfulness of the appearances. Facts in relation to entering of the appearances 18. Before I deal with the arguments raised by Mr. McGreal, I will set out the actual facts in relation to the appearances entered on behalf of the defendants. (i) The first set of proceedings 19. The plaintiff issued his plenary summons in the first set of proceedings against Ms. Concannon and Ms. Browne on 22nd November 2024. The plaintiff served the plenary summons on the first defendant on 26th November 2024; the plaintiff served the plenary summons on the second defendant on 20th December 2024. 7 20. An appearance was entered on behalf of the second defendant on 3rd January 2025 by Ms. Maria Browne, of the Chief State Solicitor’s Office. 21. On 4th February 2025, counsel for both defendants sought an extension of time for the late filing of appearances, which order was made by me. 22. An appearance was then entered for, and on behalf of the first named defendant in the first set of proceedings, on 5th February 2025, by the Chief State Solicitor's Office. (ii) The second set of proceedings 23. In respect of the second set of proceedings, the plaintiff issued his plenary summons on 13th November 2024. The plenary summons was served on the Courts Service defendants on 13th November 2024 and on the Garda Commissioner on 14th November 2024. 24. An appearance was entered on 18th December 2024, for the Courts Service defendants by Mason Hayes and Curran LLP and a copy of this appearance was sent to the plaintiff on 18th December 2024. 25. An appearance was also entered on behalf of the Garda Commissioner (the ninth defendant) on 13th January 2025. 26. The plaintiff has, since 4th February 2025, on numerous occasions, sought to challenge the validity of these appearances. The affidavit evidence 27. Mr. McGreal's application of 26th March 2025, was grounded upon an affidavit sworn by him on 24th March 2025. However, this affidavit is, in substance, a legal submission and therefore I will have regard to the points raised by Mr. McGreal at a later stage in this judgment. There were also other affidavits sworn by Mr. McGreal before this to which I have had regard. 8 28. Mr. John Hiney, a solicitor with the Chief State Solicitor's Office, swore an affidavit on behalf of the defendants in the first set of proceedings. I have set out the substance of this affidavit in my first judgement. 29. Ms. Lauren McCausland, a solicitor with Mason Hayes and Curran, swore an affidavit on behalf of the first, second, third and tenth defendants (i.e. the Courts Service defendants) in the second set of proceedings. 30. At paragraph 7 of her affidavit, she states as follows: “I understand that the plaintiff attended at the Central Office on 9th October 2024 and 11th October 2024 and disputed that fees were required to be paid pursuant to S.I. 492/2014 in respect of proceedings [he wished] wish to file. Owing to disturbances that arose as a result of this issue, I am instructed that the plaintiff was escorted from the Central Office on both dates by an An Garda Siochana. I am instructed that on 14th October 2024, the plaintiff attended at the Central Office in the company of 25 – 30 people and attempted to gain access to the office. Owing to the risk this group presented to the Courts Service staff, the group was not permitted to gain entry and members of An Garda Siochana again attended. For the avoidance of doubt the Courts Service denies any and all wrongdoing alleged by the plaintiff". (Emphasis added.) 31. At paragraph 8, she states: “As a consequence of these disturbances the third defendant wrote to the plaintiff on 14th October 2024 advising him that to protect the welfare and safety of employees of the Courts Service and other users of the Central Office, going forward, the Courts Service would receive documentation from the plaintiff by post or by leaving same in the dropbox outside of the Central Office only”. 32. At paragraph 8, she says: “An Appearance was entered on behalf of the Courts Service in these proceedings on 18th December 2024.… notwithstanding the entry of this appearance and the fact that same was provided to the plaintiff, the plaintiff brought a motion seeking to set the proceedings down for trial on 4th February, 2025. On this date an 9 application for an extension of time was sought on behalf of the Courts Service and acceded to in circumstances where an appearance had been entered on behalf of the Courts Service on 18th December 2024." 33. At paragraph 10, she states: “On 25th February, 2025, my office wrote to the plaintiff stating that it was satisfied that the appropriate defendant in respect of any claim that was being made against the Courts Service, was the Courts Service. This correspondence called upon the plaintiff to discontinue his proceedings against the first, second, third and tenth defendants and indicated that the Courts Service would consent to the substitution of the Courts Service as the appropriate defendant.….The plaintiff persists in his claim against the first second third and tenth named defendants ". (Emphasis added.) 34. As Ms. McCausland states in her affidavit “It is not a matter for the plaintiff to seek to undermine the legal representation of another party to the proceedings.” 35. At paragraph 14 of her affidavit, Ms. McCausland states follows: "By email dated 28 March 2025, the plaintiff made a number of very serious allegations against Mason Hayes and Curran LLP in respect of the filing of the respondents’ notice in response to his appeal against an order of this Honourable Court extending the time within which the Appearance was to be entered. The plaintiff contended by this correspondence that it was impermissible for my office to act on behalf of the instructions it had received from the Courts Service and that in so doing it had acted in a manner contrary to criminal law. By further email dated 31st March 2025 the plaintiff wrote again to this office amongst others alleging breaches of a variety of legislative provisions arising from, inter alia the entry of an appearance by my office in these proceedings. The plaintiff threatened to institute both civil and criminal proceedings against this office amongst others in this email.” 10 36. The plaintiff has persisted in his allegations of misconduct against Mason Hayes and Curran in their representation of the Courts Service defendants. Ms. McCausland stated at paragraphs 17 and 18 of her affidavit that: “17. it was clearly stated that the Courts Service does not accept that there has been any misconduct by its employees. In relation to the perceived procedures pursuant to which my office came to be acting in these proceedings, the plaintiff was informed that my office had been appointed to the legal panel for the Courts Service and as such were entitled to provide legal services to the Courts Service at this request. 18. Notwithstanding this exchange of correspondence the plaintiff has determined to proceed with this motion." 37. At paragraph 19, she states: “Further it is relevant to note that in addition to this motion, the plaintiff has deemed it appropriate to institute a private criminal prosecution against the firm in which I am employed on the basis of an allegation that the LLP has acted unlawfully by entering the appearance in the within proceedings. A copy of the documentation which the plaintiff has furnished to this office and which he contends is a valid criminal summons is contained at tab eight of the booklet. I say that the criminal matters are next listed before the District Court on 30th October 2025.” Applicable legal principles 38. The issues surrounding the entry of appearances are, in general, uncontroversial. Whilst there might be disputes from time to time between parties about whether appearances have been entered correctly, or in time, and whilst there might be applications to extend the time for the entry of an appearance, all such disputes are within the normal bounds of procedural disputes in litigation. However, what has happened in this case goes well beyond the normal course of a dispute between parties over the entry of appearances. 39. Order 12 of the Rules of the Superior Courts sets out the rules governing appearances. 11 40. Order 12 rule 1 provides as follows: "Appearances shall be entered in the Central Office, Four Courts Dublin except in the case of minor matters when the appearance shall be entered in the office of Wards of Court or except as otherwise provided in these rules.” 41. Order 12 rule 2 (1) also provides that: "Save as otherwise provided for in rule 2 (3), an appearance to any plenary summons or summary summons shall be entered within eight days after the service of the summons (exclusive of the day of service, unless the court shall otherwise order.)” (Emphasis added.) 42. Order 12 rule 3 provides: "A defendant shall enter his appearance to an originating summons by delivering to the proper officer a memorandum in writing dated on the day of its delivery and containing the name of the defendant's solicitor or stating that the defendant defends in person.” (Emphasis added.) 43. It is clear from the rules that an appearance can be entered by the defendant’s solicitor and that, if so, the appearance must contain the name of the defendant's solicitor. 44. Order 12 rule 6 puts the matter beyond doubt when it states: "The solicitor of a defendant shall state in the memorandum of appearance: his registered place of business, or where the defendant solicitor consents to the receipt of documents in the proceedings by electronic mail, his or her electronic mail address (in lieu of his or her registered place of business) to which documents may be sent in electronic form.” 45. Order 12 rule 9 provides that: "The memorandum of appearance shall be in the form number 1 in appendix A part 2.” 12 46. Order 12 rule 10 provides: "Upon receipt of a memorandum of appearance entered by any party or person pursuant to the provisions of this order, the proper officer shall forthwith enter the appearance in the appropriate cause book.” 47. As Delany and McGrath state in Civil Procedure (5th edition) at paragraph 4.01: "The entry of an appearance, which is dealt with in order 12 of the Rules of the Superior Courts, is a very important step in proceedings because it constitutes an acknowledgement by the defendant of their existence and generally indicates an intention to defend." Arguments of the plaintiff 48. I will deal in this judgement with the main arguments put forward by Mr. McGreal and set out why, in my view, all of his arguments are unstateable and/or misconceived. It is not necessary to address all of the unstateable and irrelevant arguments which Mr. McGreal has put forward in these applications. Many of these arguments fall away or do not need to be considered as his main arguments are misconceived. (1.) The plaintiff’s issues with the appearances filed in the first set of proceedings – Defendants not acting within scope of their employment 49. Mr. McGreal’s main argument was that (i) the defendants in the first set of proceedings were not acting within the scope of their employment when carrying out the alleged wrongdoing; (ii) that the Chief State Solicitor's Office had no power to enter appearances on behalf of the defendants when their alleged actions fall outside the scope of their statutory duties; and (iii) therefore they are not entitled to a state-funded defence. This argument is manifestly wrong. 50. In order to assess whether the plaintiff's allegations against the first and second defendants, Ms. Concannon and Ms. Browne, relate to actions outside the scope of their 13 statutory duties, it is important to look at the plaintiff's plenary summons in the first set of proceedings. 51. I have set out in some detail in my first judgment, the nature of the plaintiff's plenary summons in the first set of proceedings and I will not repeat this here. In summary, the plaintiff’s claim in the first set of proceedings against the first defendant is that Mr. McGreal brought a notice of motion for judgment in default of appearance in Westmeath Circuit Court in his election petition case [Patrick McGreal plaintiff v. Westmeath County Council, Returning Officer for the local election Westmeath, the Minister for Housing local government and Heritage, the Minister for the Environment and the Attorney General defendants, (Circuit Court Record Number 129/2024)] and Ms. Concannon, the County Registrar, "unlawfully struck out his motion” and failed to follow proper procedural rules. He also alleges that Ms. Concannon, while acting as County Registrar failed to disclose a conflict of interest, in breach of natural justice and the principle of nemo udex in causa sua. 52. At paragraph 2 of the plaintiff's plenary summons against the two defendants in the first set of proceedings, Mr. McGreal makes clear that his grievance in relation to Ms. Concannon arises from her conduct "while acting as a County Registrar." 53. First of all, it is abundantly clear, even on the plaintiff's own pleaded case, that the actions of Ms. Concannon, as County Registrar, in striking out the plaintiff’s notice of motion (for judgment in default of appearance in the Circuit Court case), were manifestly within the scope of her duties. If the plaintiff is of the view that Ms. Concannon's actions were wrong as a matter of law, then his proper course of action was to appeal any order she made to the Circuit Court Judge and, if he is unhappy with that decision, to appeal that decision, of the Circuit Court Judge to the High Court. 54. The plaintiff's claim against Ms. Browne appears to arise from the fact that she acted in her capacity as a solicitor with the Chief State Solicitor's Office in representing the various 14 state parties in those Circuit Court proceedings which Mr. McGreal brought. In those circumstances, it is absolutely clear that her actions occurred in the course of her employment and were not of a personal nature. Ms. Browne is a solicitor with the Chief State Solicitor's Office, and in her capacity as a solicitor with the Chief State Solicitor's Office, she entered an appearance on behalf of the third, fourth, and fifth named defendants (i.e. the Minister for Housing, the Minister of the Environment and the Attorney General).Therefore, the plaintiff's allegations of "personal misconduct" are manifestly wrong. 55. It is abundantly clear that the actions of Ms. Concannon and Ms. Browne were well within the scope of their employment as County Registrar and as solicitor with the Chief State Solicitor's Office, respectively. It follows therefore, that Ms. Concannon is being sued in her capacity as County Registrar (not in her personal capacity) and that she is being sued for actions which she took in her capacity as County Registrar. It is also clear, that Ms. Browne is being sued in her capacity as a solicitor and for the actions she took in the course of her employment as a solicitor with the Chief State Solicitor's Office. 56. In the circumstances, any allegations that the alleged actions of the first and second defendants in these proceedings fell outside the scope of their statutory duties are simply wrong. 57. It is also clear, that the Courts Service would be vicariously liable for the actions of Ms. Concannon in her capacity as County Registrar and that the Chief State Solicitor's Office would be vicariously liable for any actions of Ms. Browne in her capacity as a solicitor with the Chief State Solicitor's Office. 58. The plaintiff also pleads that Ms. Concannon and Ms. Browne acted unlawfully in breaching multiple sections of the Criminal Justice (Corruption Offences) Act 2018 and the Criminal Justice (Theft and Fraud Offences) Act 2001. However, these wild allegations are 15 not backed up by any particulars in the plenary summons and are, quite simply, ridiculous. Striking out a motion or entering an appearance are not, per se, criminal or corrupt acts. 59. I am therefore of the view that the defendants are clearly entitled to be represented by the Chief State Solicitor's Office. 60. In the circumstances, the application by Mr. McGreal for an order declaring that public funds should not be used to finance the legal defence of the two defendants in the first set of proceedings is unstateable and will be refused. 61. Likewise, Mr. McGreal's application for an order directing the Chief State Solicitor's Office to cease representing the first and second named defendants is unstateable and will be refused. The second set of proceedings – scope of employment. (i) The Court Service defendants 62. In the plaintiff's notice of motion in the second set of proceedings, Mr. McGreal actually seeks an order affirming that the ninth defendant (the Commissioner of An Garda Siochana) and the tenth defendant (Chief Executive Officer of the Courts Services) are entitled to state-funded legal representation under vicarious liability principles as their liability arises from their role as head of the institution rather than personal wrongdoing. 63. As the plaintiff has sought this order in his notice of motion and as the defendants agree with this, I have no difficulty in making an order in those terms confirming that the ninth defendant (the Commissioner of An Garda Siochana) and the tenth defendant (Chief Executive Officer of the Courts Service) are entitled to state funded legal representation under vicarious liability principles. 64. However, the very fact that the plaintiff concedes this point is fatal to his argument in respect of all of the other defendants in the second set of proceedings. 16 65. Because the plaintiff accepts, as he must, that the Commissioner of An Garda Siochana and the Chief Executive Officer of the Courts Service are entitled to state funded legal representation under vicarious liability principles, then it must follow, as night follows day, that the first, second and third defendants (i.e. Sam – a member of the Courts Services staff), Colin – (another member of the Courts Services staff) and Ms. Kim Duffy (Courts Services manager) must also be entitled to state funded legal representation under vicarious liability principles (i.e. they are entitled to legal representation from the Chief State Solicitor's Office and/or any other firm appointed by the Courts Service), if the actions alleged against them were within the scope of their employment. 66. It is clear from the affidavit evidence before the court, that the plaintiff's allegations against “Sam”, “Colin” and Ms. Duffy arise solely and exclusively from their actions taken in the course of their working day, and in the normal course of their everyday employment. The plaintiff's allegations against the Courts Service defendants are that they committed multiple breaches of his constitutional rights, including denial of access to the courts, unlawful obstruction of justice and obstruction of his attempts to file an affidavit. It is clear, that all of these overblown and exaggerated allegations relate to the plaintiff's dispute with various members of staff in the Central Office over their refusal to accept his plenary summons and/or affidavits without payment of the correct stamp duty. These tasks are the essence of the work which officials who work in the Central Office do on an everyday basis. Any suggestion that the work which the first, second and third defendants did in the second set of proceedings is outside their normal work duties is simply wrong. 67. I would also remark in passing, that it is clear that the plaintiff’s attempts to sue Sam (Courts Services staff) as the first defendant, Colin (Courts Service staff) as the second defendant, Kim Duffy (Courts Services manager) as the third defendant and the Chief Executive Officer of the Courts Service as the tenth defendants are manifestly inappropriate. 17 It is clear that all of these defendants were acting in the course of their employment during their working day and that the appropriate defendant is the Courts Service. 68. Indeed, the Courts Service has stated, clearly and unequivocally in open correspondence, that it is vicariously liable for the actions of these defendants and has indicated that the Courts Service can be substituted for these defendants. This again is an indication by the Courts Service that the actions of these first three defendants were clearly within the course of their employment, and that, even if a court were to find that such actions were somehow unlawful, the Courts Service would accept responsibility, as a matter of law, for these actions under the doctrine of vicarious liability. 69. It must follow, therefore, that the first three defendants, who are employees of the Courts Service, are also entitled to state funded legal representation – whether that be by the Chief State Solicitor's Office or by an outside firm of solicitors (such as Mason Hayes and Curran) which has been appointed by the Courts Service to act on their behalf in certain litigation. 70. In the circumstances, I would reject as unstateable the plaintiff's argument that the first three defendants are not entitled to state funded legal representation and/or that Mason Hayes and Curran are not entitled to represent them. (ii) The Garda defendants 71. It is also clear from the affidavit evidence filed on behalf of the defendants in the second set of proceedings, that the plaintiff summoned a posse of his supporters to invade the Central Office and to intimidate and harass officials in the Central Office in his overly- zealous campaign not to pay stamp duty on certain documents. As a result, the Courts Service summoned members of An Garda Siochana to the Central Office to protect the employees of the Central Office. It appears that Mr. McGreal was escorted from the Central Office by members of An Garda Siochana, that he was detained in the Bridewell Garda Station for a 18 number of hours and that he was subsequently released later in the day. It is these actions which he claims give rise to his cause of action in the second set of proceedings against the various gardai who are named defendants in the second set of proceedings (i.e. Garda A (the fourth named defendant), Garda Sheehan (the fifth named defendant), Garda C (the sixth named defendant), Jail Garda Sgt (the seventh named defendant) and the Commissioner of An Garda Siochana (the eighth named defendant).) 72. However, again it is impossible to see how any of the actions of these gardai amount to actions outside the course of their employment. 73. Mr. McGreal has pleaded that these gardai defendants engaged in a false arrest, false imprisonment, assault, inhuman and degrading treatment and breach of his personal integrity. He seeks various declarations in respect of these matters and also damages. 74. However, based on the affidavit evidence before this court, it is clear that these gardai were acting in the normal course of their duties. It is clear also, that the Garda Commissioner is liable on the principles of vicarious liability for any alleged wrongdoing of the various Garda defendants named (or not named) in the second set of proceedings. 75. It is clear that the Garda Commissioner (or the State) is vicariously liable for the actions of all of the Garda defendants named in the second set of proceedings. However, counsel for the Garda Commissioner has submitted that no issue was taken with the name of the Commissioner of an Garda Siochana as a defendant and it is clear that the plaintiff was not taking any issue with the Commissioner being entitled to state funded legal representation. 76. It is also clear that the plaintiff has sued the wrong defendants in the second set of proceedings. The only defendants who should be sued in the second set of proceedings are the Courts Service and the Garda Commissioner. All the other named defendants are employees of the Court Service and/or gardai, and the Court Service and the Garda 19 Commissioner have accepted that they are vicariously liable for the actions of their employees and members. 77. However, even when the truth of the situation is pointed out to Mr. McGreal, he refuses to accept the position. Even on the plaintiff's own case, it is clear that his case against the defendants in the second set of proceedings all relate to actions which occurred within the course of their employment. The allegations by the plaintiff that their actions were outside the terms of employment are manifestly not supported by the pleadings and/or affidavits filed in both sets of proceedings. 78. I am also of the view that the plaintiff’s convoluted and unclear legal argument about the Ministers and Secretaries Act 1924 is not relevant to any of the matters which I have to decide and therefore I do not propose to consider this matter any further. 79. In the circumstances, it is clear that all the garda defendants and the Garda Commissioner are entitled to state funded legal representation – whether that be by the Chief State Solicitor's Office or by an outside firm of solicitors such as Mason Hayes and Curran. (iii) The plaintiff's argument Mason Hayes and Curran cannot enter an appearance because it is an L.L.P. rather than an individual solicitor 80. The plaintiff further submits that the defendants’ solicitors in the second set of proceedings – Mason Hayes and Curran LLP, who act for the Courts Service – cannot enter an appearance because the name of an individual solicitor must appear on the appearance. Mr. McGreal’s argument on this point is also unstateable. The defendants’ solicitor can be a single solicitor in private practice, a firm of solicitors (i.e. a partnership of solicitors) or an LLP. There is no reason in principle why an LLP cannot sign an appearance and enter an appearance on behalf of defendants whom they represent in litigation. It is equally the case that there is no reason why the person entering the appearance on behalf of a firm would not enter the proper name of the firm of solicitors in the appearance. 20 81. The first, second, third and tenth defendants, in the second set of proceedings, submitted that the reference to the defendant's solicitor in order 12 rule 3 clearly included a situation where a number of solicitors are engaged on behalf of the defendant and operate as a firm of solicitors. They submitted that to read the order in any other way was to create a nonsense of the order. I agree with that submission. It is clear, as a matter of proper interpretation of order 12 rule 3, that the phrase "containing the name of the defendant's solicitor" means, and must be interpreted to mean, the name of the defendant solicitor’s firm. 82. Secondly, order 125 of the Rules of the Superior Courts expressly provides that words importing the singular shall be construed as importing the plural. 83. Thirdly, the first, second, third and tenth defendants also rely on section 18(a) of the Interpretation Act 2005 which provides that a word importing the singular shall be read as also importing the plural. Thus, it is clear that a reference to a solicitor in order 12 rule 3 includes solicitors (plural). I agree with this submission. 84. Fourthly, the Solicitors Act 1954 as amended provides, at section 3 (which was substituted by section 3 (1)(a) of the Solicitors (Amendment) Act 1994): “‘solicitor’ means a person who has been admitted as a solicitor and whose name is on the roll; and a reference to a solicitor includes a reference to a firm of solicitors unless the context otherwise requires and includes a former solicitor or a deceased solicitor unless the context otherwise requires." (Emphasis added.) 85. In Killeen v. Higgins [2025] IEHC 582, Simons J. dealt with the issue of whether an appearance is lawfully entered if it is entered by a firm of solicitors, as opposed to an individual solicitor. The court held that, by operation of order 125 of the Rules of the Superior Courts, words used in the Rules of the Superior Courts that import the singular shall be construed as importing the plural and vice versa. Simons J. also held that where the 21 defendants are a firm of solicitors, then it is appropriate to describe a partnership of solicitors by reference to the title of the firm rather than to set out the name of each individual partner. 86. As Simons J. stated in Killeen v. Higgins [2025] IEHC 582: “(1). Memorandum of Appearance 19. The first technical objection is that the memorandum of appearance, which has been filed on behalf of the defendant, is invalid because it has been signed in the name of a firm of solicitors rather than the name of an individual solicitor within the firm. 20. The procedure for entering an appearance is prescribed under Order 12 of the Rules of the Superior Courts (“RSC”). Order 12, rule 3 provides, in relevant part, that a defendant shall enter his appearance to an originating summons by delivering to the proper officer a memorandum in writing dated on the day of its delivery and containing the name of the defendant’s solicitor or stating that the defendant defends in person. Order 12, rule 6 provides that the solicitor of a defendant shall state in the memorandum of appearance: (i) his registered place of business, or (ii) where the defendant’s solicitor consents to the receipt of documents in the proceedings by electronic mail, his or her electronic mail address (in lieu of his or her registered place of business) to which documents may be sent in electronic form. Order 12, rule 9 provides that the memorandum of appearance shall be in the Form No 1 in Appendix A, Part II of the RSC. 21. The objection to the form of the memorandum in the present proceedings is predicated on the use of the singular form of the word “solicitor” under Order 12 and Appendix A of the RSC. The logic of the objection is that this mandates that the name of an individual solicitor, rather than the name of a firm or partnership, be endorsed on the memorandum of appearance. With respect, this objection overlooks that the 22 interpretation section under Order 125 RSC expressly provides that words importing the singular shall be construed as importing the plural and vice versa. It follows that where a defendant is represented by a firm of solicitors, rather than a sole practitioner, then it is the name and registered place of business of the firm of the solicitors which should be recorded in the memorandum of appearance. The firm of solicitors—namely, Regan McEntee & Partners Solicitors—constitute the defendants’ solicitors (plural) within the meaning of Order 12. It is appropriate to describe a partnership of solicitors by reference to the title of the firm rather than to set out the name of each individual partner. This is especially so where the partnership is registered as a limited liability partnership (“LLP”) with the Legal Services Regulatory Authority. Regan McEntee Partners has been registered as an LLP since 21 August 2023. (…) 24. For the foregoing reasons, the proper interpretation of Order 12 is that in cases where a defendant is represented by a firm of solicitors (rather than a sole practitioner), it is permissible to endorse the registered name of the firm on the memorandum of appearance. There is no requirement that same be signed by an individual solicitor within the firm.” (Emphasis added.) 87. I agree with the views expressed by Simons J. In the circumstances, I am of the view that Mr. McGreal’s objections to Mason Hayes and Curran LLP entering an appearance are wrong as a matter of law. The application to strike out the plaintiff's first set of proceedings as being an abuse of process. 88. The next issue to consider is whether the plaintiff’s first set of proceedings should be struck out on the grounds of (i) lack of jurisdiction and/or (ii) abuse of process. 23 89. In the course of argument over the numerous applications brought by the plaintiff in the first set of proceedings, it became clear that there was an issue raised by the defendants as to whether the High Court even had any jurisdiction to hear this case because the plaintiff had not followed the correct procedure in the first set of proceeding. In the alternative, it was argued that the first set of proceedings amounted to a collateral attack on an order made by County Registrar in the Circuit Court proceedings and should be struck out as an abuse of process. 90. In the circumstances, counsel for the defendants in the first proceedings made an application to strike out these proceedings on the grounds of lack of jurisdiction and/or as being an abuse of process. The plaintiff was fully on notice of this issue and engaged with it when it was raised. (i) Lack of jurisdiction. 91. As set out in my first judgment, it is clear that what happened in this case, was that Mr. McGreal issued a local election petition by means of an Election Civil Bill in the Circuit Court (in the Midland Circuit, County of Westmeath) on 20th June 2024. These proceedings were given a record number of 129/2024. The proceedings were entitled: The Circuit Court Midland Circuit County of Westmeath Elections Bill In the Matter of the Local Elections (Petitions and Disqualification) Act 1974 Between Patrick McGreal Plaintiff and Westmeath County Council 24 Returning Officer for the local elections Westmeath The Minister for Housing and Local Government and Heritage The Minister for the Environment and the Attorney General 92. On 1st July 2024, the Chief State Solicitor (Ms. Browne) entered an appearance on behalf of the third, fourth and fifth named defendants to the Civil Bill. 93. On 4th July 2024, Mr. McGreal brought a notice of motion for judgement "by default of appearance" against all defendants. 94. It is clear from other documents exhibited by the plaintiff (which I refer to at paragraph 108 of my first judgment) that his motion for judgment in default of appearance in the Circuit Court proceedings came on before the County Registrar of the Midland circuit (County of Westmeath/Mullingar), Ms. Bridin Concannon, on 9th September 2024. The County Registrar struck out the plaintiff's motion as against Westmeath County Council, the Minister for Housing, the Minister for the Environment and the Attorney General. However, the plaintiff's application against the second defendant (i.e. the Returning Officer – Ms. Concannon) was not struck out by Ms. Concannon but was instead transferred to the Judge’s List on 12th November 2024. As I stated in paragraph 109 of my first judgment: "I do not know on what basis this was transferred but it was possible that Ms Concannon was aware that she could not deal with it as she was a named defendant. In any event, it is difficult to see on what basis the plaintiff is attacking Ms Concannon's function as being contrary to the rule - nemo iudex in causa sua - when she did not deal with the motion herself." 95. As I stated in paragraph 110 of my first judgment: 25 "It is also noteworthy that the plaintiff did not appeal the County Registrar’s decision to the Circuit Court judge, as he should have done, but instead issued these High Court proceedings." 96. Despite Mr. McGreal’s vociferous and repeated complaints that the defendants have not followed the correct procedures, it is, in fact, he who has failed to follow the proper procedural rules. His proper course of action was to appeal the order of the County Registrar to the Circuit Court. He has not done so. Instead, he has issued these High Court proceedings against Ms. Concannon and Ms. Browne. I am of the view that the plaintiff’s first set of proceedings are – in substance – an appeal against the Order of the County Registrar. 97. It is clear, that the correct procedure in the first proceedings was for Mr. McGreal to appeal the decision of the County Registrar to the Circuit Court. As was stated by Simons J. in Promontoria (Field) DAC v. Brendan Mahon [2019] IEHC 218, the High Court does not have jurisdiction to consider what is, in substance, an appeal from the County Registrar to the Circuit Judge. In the circumstances, I am of the view, like Simons J., that the High Court does not have jurisdiction to consider what is, in substance, an appeal from the County Registrar, dressed up as new plenary proceedings. In that case, Simons J. struck out the proceedings on the grounds the court did not have jurisdiction to deal with the matter. Likewise, in the present case, I will strike out the first set of proceedings against Ms. Concannon and Ms. Browne on the grounds that the court does not have jurisdiction to deal with it. (ii) Abuse of process. 98. I am also of the view that the first set of High Court proceedings amount to a collateral attack on the order of the County Registrar and, as such, they are an abuse of process and should be struck out on that basis also. 26 Second set of proceedings: abuse of process 99. The next issue to consider is whether the plaintiff’s second set of proceedings should also be struck out, on the grounds of abuse of process. 100. Ms. Kim Duffy, Principal Registrar of the High Court, swore a replying affidavit on behalf of the Courts Service defendants in the second set of proceedings. 39. Ms. Duffy states at paragraph 8 of her affidavit: “Insofar as these proceedings concern the Courts Service, I understand that the plaintiff’s complaint concerns a dispute as to the requirement for court fees to be paid pursuant to S.I. 492/2014. In that connection, the plaintiff attended at the Central Office on 9th October, 2024 and 11th October, 2024 and disputed that fees were required to be paid pursuant to S.I. 492/2014 in respect of proceedings he wished to file. Owing to disturbances that arose as a result of this issue the plaintiff was escorted from the Central Office on both dates by An Garda Siochana. On 14th October, 2024, the plaintiff attended at the Central Office in the company of 25 to 30 people and attempted to gain access to the office. Owing to the risk this group presented to the Court Services staff, the group was not permitted to gain entry and members of An Garda Siochana again attended. For the avoidance of doubt the Courts Service denies any and all wrongdoing alleged by the plaintiff.” (Emphasis added.) 101. She states at paragraph 9: “As a consequence of these disturbances I was obliged to write to the plaintiff on 14th October, 2024 advising him that to protect the safety and welfare of employees of the Court Services and other users of the Central Office, going forward, the Court Service would receive documentation from the plaintiff by post or by leaving same in the drop box outside the Central Office only.” (Emphasis added.) 27 102. In her letter of 14th October to Mr. McGreal, Ms. Duffy states as follows: “Dear Mr. McGreal, I am writing to you regarding recent attendances at the Central Office of the High Court and in particular your behaviour and the manner in which you conducted your business. Members of staff working in this office frequently meet with challenging situations but there is a level of behaviour by users which is totally unacceptable. Your recording of members of staff without their consent and posting of these images and videos on social media platforms amount to such conduct. On 11th October, 2024 you posted on your social media platforms material ahead of your attendance at the High Court on 14th October, 2024 that you intended to arrest named individuals and escort them into custody. Following your recent posts online as to how you intended to conduct yourself it was necessary to request An Garda Siochana to maintain a presence in or around the Central Office for the safety of all users. As well as being a service provider the Courts Service is an employer. As such it owes the duty of care both to at common law and statute to all of its employees. As a consequence of its obligations it cannot permit staff who provide the service to be put in peril by any service user. I do not consider that I can ask or expect any member of staff of the public Central Office to deal with you in person. Your behaviour and the manner in which you continue to conduct yourself and your business in person in the Central Office is quite simply unacceptable. It is putting the safety and welfare of staff and other users at substantial risk”. (Emphasis added.) 103. Mr. Hiney, a solicitor with the CSSO, also states in his affidavit: 28 “Owing to disturbances that arose as a result of this issue the plaintiff was escorted from the Central Office on both dates by members of An Garda Siochana. On 14th October, 2024, the plaintiff attended at the Central Office in the company of approximately 30 people and attempted to gain access to the office. Owing to the risk this group presented to the Courts Service staff, the group was not permitted to gain entry and members of An Garda Siochana again attended.” 104. Mr. Hiney in his affidavit, sworn on 17th February 2025, at paragraph 14, states as follows: “I say further that in a post on the social media site known as X, published at 10.12 pm later that same evening [i.e. on 4th February 2025] the plaintiff (whose name and photograph appear above the post) described as ‘corruption’ the proceedings of that morning before this honourable court criticising the second defendant for the entry of her appearance ‘where she is personally accused of criminal wrongdoing’ and further criticising the second defendant for having entered an appearance on behalf of the Commissioner of An Garda Siochana in the aforementioned proceedings bearing record number 2024/6654.” 105. In this post on X, Mr. McGreal states: “Today the sheer level of corruption on display in the High Court would make you sick. The court allowed Maria Brown, Chief State Solicitor to enter an appearance on behalf of herself in a case where she is a person accused of criminal wrongdoing. Not only that, Mason Hayes and Curran LLP – a limited liability Partnership – was permitted to enter an appearance for four of the other defendants despite no identifiable solicitor being named on record.” 106. On 11th February 2025, Mr. McGreal sent an email to the Central Office for the attention of the Chancery registrars stating as follows: 29 “Dear Chancery, I write to formally notify you that I will engage directly with the judge pursuant to Article 34.1, Article 35.2, Article 40.1 and Article 40.3 of the Constitution of Ireland. As of this correspondence, I will no longer exchange any information or details with your office and will be disengaging from further communications. Should the judge fail to adhere to the rules today, I will formally request that a member of An Garda Siochana place him under arrest for violations of statutory law. Yours sincerely, Patrick McGreal.” 107. As I said at paragraphs 59 and 60 of my first judgment: “59. I should add that, in my view, the threat by Mr. McGreal to put a serving judge of the High Court under arrest simply because he disagrees with such a judge's interpretation of procedural law, in circumstances where he has recourse to the Court of Appeal and the Supreme Court, and indeed where he has filed appeals to the Court of Appeal and Supreme Court, is nothing short of disgraceful. It is not only a gross over-reaction to the procedural issues at stake in the proceedings, it is a clear attempt to intimidate a sitting High Court judge hearing his case. It is manifestly an abuse of process. 60. I should also add that Mr. McGreal has form in this regard. It appears that he attempted to arrest the District Court judge in Mullingar on 26th November, 2024 and as a result, he himself was arrested by the Gardaí and put into prison for a few hours. I am aware of this because Mr. McGreal made a separate ex parte application to me on 27th March 2025, in the matter of intended proceedings between Mr. McGreal and the Garda Commissioner, for an order that his intended proceedings were proceedings under Article 40.4 and therefore exempt from court fees. Having 30 considered the draft plenary summons in those proceedings, I acceded to that application on 27th March, 2025.” 108. It is clear, that there was a difference of opinion between the plaintiff and employees of the Court Service in the Central Office as to whether stamp duty was payable or not. However, the resolution of that question was not for the plaintiff to go on to social media and summon a posse of supporters in order to invade the Central Office and to intimidate the employees of the Central Office. It was, instead, to come before the Court on an ex parte basis and seek a resolution of that issue as Mr. McGreal belatedly did on 14th October 2024. 109. The courts will not tolerate any attempt by a litigant in person, or any person, to verbally abuse and/or to physically intimidate or harass or threaten members of the Central Office, while they are engaged in their lawful duties in assisting members of the public. It is an absolutely scandalous abuse of process that Mr. McGreal believes that he could go on social media and summon a crowd of his supporters to invade the Central Office and to threaten and physically intimidate or harass members of the Central Office who are engaged in their lawful duties and threaten to arrest them. On this ground, and in view of all of the other grounds that I have set out in this judgment, and in my first judgment, I am of the view that Mr. McGreal has engaged in a deliberate and sustained abuse of process throughout these proceedings. In the circumstances, I intend to strike out Mr. McGreal's proceedings against the Courts Service and the Garda Commissioner and all of the named parties in those proceedings as an abuse of process. 110. It is also a significant interference with the administration of justice in that it is simply unacceptable that the plaintiff would seek to so intimidate employees working in the Central Office to such an extent that they will no longer accept papers from him and that they have to close the Central Office – and that the gardai have to be called – on each and every occasion when he appears. 31 111. I am also satisfied that Mr. McGreal’s proceedings against named gardaí and the Garda Commissioner are not bona fide proceedings. Indeed, in separate proceedings before this court, the plaintiff issued no less than seven plenary summonses against gardai – all of which related to separate events of allegations of false imprisonment. These seven plenary summonses have now been struck out, on consent. This shows a pattern of the plaintiff seeking to create issues in the Central Office which require gardai to be called, and then seeking to foment litigation arising out of each issue so that he can issue proceedings against the Gardaí. It is, from start to finish, an abuse of the processes of the court. 112. In both sets of proceedings, Mr. McGreal, has, in reality, engaged in a form of “lawfare” against the various defendants. He has sought to attack not only the defendants personally but also their legal representatives in the filing of appearances. He has threatened to arrest members of the Courts Service carrying out their daily work; he has accused, without any grounds, all of the defendants of perjury and all sorts of illegalities; he has accused the defendants’ solicitors, Mason Hayes and Curran, of engaging in criminal offences. None of this is normal behaviour. These are manifestly abuses of process by Mr. McGreal. 113. In the circumstances, I am satisfied that the plaintiff’s second set of proceedings should also be struck out as an abuse of process. Mr. McGreal’s pattern of threatening to arrest, and attempting to arrest 114. It is now clear that Mr. McGreal has engaged in a pattern of threatening to arrest, or actually attempting to arrest (i) officials in the Central Office; (ii) solicitors going about their lawful duties; and (iii) judges, without any reasonable cause. These actions also amount to a manifest abuse of process and/or interference with the administration of justice. I set out below details of these matters. 32 (i) Threats to arrest officials in the Central Office 115. I have set out above the evidence of the defendants in their various affidavits about Mr. McGreal’s threats to arrest Courts Service officials. 116. In his oral submissions before the court during the hearing of these applications, on Wednesday, 22nd October 2025, Mr. McGreal submitted that he did not make any threats against anyone on his social media but that he simply "posted what I felt was a wrong that was done to me. I phoned the Bridewell Garda station that weekend. I told them I was going to be up and I was going to commission an arrest without warrant on Monday morning 14th October.” "Now what provides me with the authority to commission an arrest without one? The affidavit has cited at least 40 indictable offences committed by three court staff, two of them still remain unidentified and five guards. Some guards I have identified; others I haven't and I put the vicarious liability in the Commissioner of An Garda Siochana and the chief executive officer [of the court service].” "So what entitles me to commission an arrest without warrant? Well I can't just arrest somebody without notice. I gave notice to The Central Office. I phoned the Bridewell Garda station and I told them exactly what I was doing and, subject to section 4 of the Criminal Law Act 1997 an arrest without warrant "subject to subsections (4) and (5), any person may arrest without warrant anyone whom he or she with reasonable cause suspects to be in the act of committing an arrestable offence" 117. Sections 2 and 4 of the Criminal Law Act 1997 provide: "2. Subject to subsections (4) and (5), where an arrestable offence has been committed, any person may arrest without warrant anyone who is or whom he or she with reasonable cause, suspects to be guilty of the offence." 33 “4.—(1) Subject to subsections (4) and (5), any person may arrest without warrant anyone who is or whom he or she, with reasonable cause, suspects to be in the act of committing an arrestable offence. (2) Subject to subsections (4) and (5), where an arrestable offence has been committed, any person may arrest without warrant anyone who is or whom he or she, with reasonable cause, suspects to be guilty of the offence. (3) Where a member of the Garda Síochána, with reasonable cause, suspects that an arrestable offence has been committed, he or she may arrest without warrant anyone whom the member, with reasonable cause, suspects to be guilty of the offence. (4) An arrest other than by a member of the Garda Síochána may only be effected by a person under subsection (1) or (2) where he or she, with reasonable cause, suspects that the person to be arrested by him or her would otherwise attempt to avoid, or is avoiding, arrest by a member of the Garda Síochána. (5) A person who is arrested pursuant to this section by a person other than a member of the Garda Síochána shall be transferred into the custody of the Garda Síochána as soon as practicable. (6) This section shall not affect the operation of any enactment restricting the institution of proceedings for an offence or prejudice any power of arrest conferred by law apart from this section.” (Emphasis added.) 118. Referring to the events of 14th October 2024, Mr. McGreal said "I entered the Four Courts complex from the public entrance there. I was on my own. I was met with about 15 members of an Garda Siochana at the back. One of them wore red lapels, he was quite 34 senior. He told me stop. He said: ‘look it don't be doing any of that today, we were looking at your social media at the weekend’." 119. Mr. McGreal sought to submit that his actions in phoning the Bridewell Garda station on Monday morning, on 14th October 2024 meant that he was acting in good faith. 120. This, of course, is nonsense. Mr. McGreal was not acting in good faith. He was in fact acting in bad faith, seeking to foment a confrontation with Courts Service staff and/or gardaí to further his political agenda (i.e. that stamp duty should not be paid on court documents.) His attempts to arrest Central Office officials were indefensible. (ii) Threatening to arrest, or attempting to arrest judges 121. Mr. McGreal has also, on a separate occasion, attempted to arrest a judge carrying out his lawful duties. 122. As I said at paragraph 60 of my first judgment: “60. I should also add that Mr. McGreal has form in this regard. It appears that he attempted to arrest the District Court judge in Mullingar on 26th November, 2024 and as a result, he himself was arrested by the Gardaí and put into prison for a few hours. I am aware of this because Mr. McGreal made a separate ex parte application to me on 27th March 2025, in the matter of intended proceedings between Mr. McGreal and the Garda Commissioner, for an order that his intended proceedings were proceedings under Article 40.4 and therefore exempt from court fees. Having considered the draft plenary summons in those proceedings, I acceded to that application on 27th March, 2025.” (iii) Attempted arrest of solicitor 123. I was also informed by Mr. McGreal – in yet another case which was brought by him and which came before me – that he attempted to arrest a solicitor in the Court of Appeal, during a directions hearing, on or about 5th December 2025. As Mr. McGreal indicated to me 35 in his remarks, he was pepper-sprayed by two members of An Gardaí and then arrested and brought to the Bridewell. 124. Again, however, it is clear that Mr. McGreal’s threats to arrest can escalate into actual physical attempts to arrest certain persons without any, or any reasonable, cause. Interference with the administration of justice. 125. All these actions by Mr. McGreal amount to significant attempts to interfere with the administration of justice. They are attempts to physically intimidate or harass persons who are engaged in the administration of justice – whether they be officials in the Central Office, solicitors acting for parties, or judges. It is deliberate and intentional. It seems that Mr. McGreal is engaged in a wholly unjustified crusade against the legal system and its personnel, or else is seeking attention for himself and some of his political campaigns. Mr. McGreal is of course free to campaign for all of his political beliefs – including the abolition of stamp duty on court documents – but he is not allowed to interfere with the administration of justice and/or to threaten court officials, solicitors, or judges. 126. I am, therefore, considering making an order restraining Mr. McGreal from threatening to arrest, or attempting to arrest, any officials in the Courts Service, or any solicitors, who are engaged in their usual activities. I would therefore request the Courts Service to make such an application. I will hear Mr. McGreal before I do so. In the alternative, Mr. McGreal can consider giving undertakings to the court in this regard. 127. I would emphasise that this will not prevent Mr. McGreal from reporting what he regards as unlawful acts committed by Courts Service officials or solicitors or judges to the gardaí. He of course always retains that right but he will not be allowed to take the law into his own hands, as he appears to have been doing over the last two years. 36 Isaac Wunder order 128. Given the numerous and repetitive cases and applications being brought by Mr. McGreal, I intend to consider making an “Isaac Wunder” order against Mr. McGreal. This would restrict Mr. McGreal from instituting any further proceedings against the Courts Service and/or the Gardaí without the liberty of the President of the High Court or another judge nominated by him. I will also request the Courts Service to prepare such an application and to set out on affidavit all cases which Mr. McGreal has instituted over the last three years so that this matter can be properly considered. Mr. McGreal’s role as “a Justice Facilitator” 129. Mr. McGreal also swore a number of affidavits in which he describes himself as a “Justice Facilitator” – whatever that means. It is clear to me however that he is purporting to advise certain persons who wish to bring cases before the High Court. He appears to be providing legal advice as a legal advisor without being a solicitor or barrister. I have noticed a number of persons bringing applications in the Chancery List similar to those brought by Mr. McGreal. I will therefore request the registrar to contact the LSRA and ask it to appear before this court in two weeks time to consider this issue further and to consider whether it should be joined as a notice party. Private prosecutions 130. I am also very concerned about Mr. McGreal’s abuse of this apparent power of a citizen’s arrest and about his attempts, on a number of occasions, to arrest certain persons. He attempted to arrest a District Court Judge in Mullingar, an official in the Central Office and a solicitor with the CSSO in the Court of Appeal. He has apparently set up a company called “Private Prosecutions Ltd”. He appears to be intent on taking the law into his own hands. I will therefore request the Registrar to ask the DPP to also appear before this court in two weeks to consider this issue further. 37 Conclusion 131. I would therefore conclude as follows: (1) in the first set of proceedings, both defendants were acting within the scope of their employment; (2) in the circumstances, both defendants are entitled to be represented by the Chief State Solicitor's Office; (3) therefore the appearance entered on their behalf by the Chief State Solicitor's Office is a lawful appearance. 132. In the second set of proceedings, (1) the various Courts Service defendants were also acting within the course of their employment; (2) therefore these Courts Service employees are entitled to legal representation whether by the Chief State Solicitor's Office or by an outside firm of solicitors such as Mason Hayes and Curran; (3) therefore the appearance entered on their behalf by Mason Hayes and Curran is lawful; (4) the actions of the gardai are clearly within the course of their employment; (5) the garda defendants and the Garda Commissioner are clearly entitled to legal representation whether by the Chief State Solicitor's Office or by an outside firm such as Mason Hayes and Curran; (6) Mason Hayes and Curran can enter an appearance as an LLP; the plaintiff's arguments on this are simply misconceived. 133. (1) The plaintiff’s first set of proceedings will be struck out on the grounds that they are, in substance, an appeal from the order of the County Registrar; as 38 such the proper course of action was for the plaintiff to appeal the order of the County Registrar to a Circuit Court Judge; (2) the High Court does not have jurisdiction to hear an appeal directly from the County Registrar; (3) the first set of proceedings will therefore be struck out on the grounds of lack of jurisdiction; (4) the plaintiff’s first set of proceedings will also be struck out as an abuse of process as they are, in substance, a collateral attack on the decision of the County Registrar. 134. (1) The plaintiff's second set of proceedings as against the various Court Service defendants are to be struck out as a blatant abuse of process; (2) the plaintiff's case as against the Garda Commissioner and various members of the gardai will also be struck out as an abuse of process. 135. The court is also considering making an order against Mr. McGreal to restrain him from arresting, or threatening to arrest, any person working for the Courts Service, and/or any solicitor engaged in their professional duties. The court would request the Courts Service to bring an application in respect of this matter. 136. This court is also considering making an Isaac Wunder order (or litigation restriction order) against Mr McGreal; the Courts Service should bring such an application also and provide an affidavit setting out the number of cases which Mr McGreal has brought against all parties over the last three years. 137. The court is also concerned about Mr McGreal's activities as a “justice facilitator”; it appears that he might be providing legal advice and/or legal services without being a practising solicitor and/or barrister. In the circumstances, the court would request the LSRA to appear before the court in two weeks’ time to consider this matter further. 39 138. The court is also concerned about Mr McGreal's activities as a so-called "private prosecutor" and that he runs a company called "Private Prosecutions Ltd.". This would appear to be an attempt to take the law into his own hands. In the circumstances, the court would request the DPP to appear before the court in two weeks’ time to consider this matter further. 139. I will adjourn this matter for two weeks to allow these various steps to take place. The proceedings will not be actually struck out until these matters have been resolved and final orders on costs have been made.