
Introduction
In Kirwan – v – Connors & Ors [2025] IESC 21, the Supreme Court delivered a landmark decision on delay in legal proceedings. The Supreme Court introduced a more structured framework for addressing delay. This has reformulated the Primor principles. The personal injuries guidelines are in place since 2021 and were overdue for review under the terms of the Judicial Council Act 2019 following a recommendation 16.7% by the judicial council. The Government decided not to implement this recommendation and issues arising from than continue to develop in practice.
Learning Outcomes
Attendees will learn about:
✔︎ The new test – Kirwan – v – Connors & Ors [2025] IESC 21
✔︎ Order 122 Rule 11 of the RSC
✔︎ Inherent jurisdiction in the superior courts
✔︎ The old test – Primor v Stokes Kennedy Crowley [1996] 2 IR 459
✔︎ Court Proceedings (Delays) Act 2024
✔︎ Review of the Personal Injuries Guidelines
✔︎ Somers v The Commissioner of An Garda Síochána [2025] IEHC 388
✔︎ Lynch v Reynolds [2025] IEHC 527
✔︎ Treatment of psychiatric injuries in personal injuries cases
✔︎ Uplift in personal injuries cases including McHugh v Ferol [2023] IEHC 132
Speakers

Sharon Brooks BL
Sharon is a barrister practising in the area of civil law generally, with a focus on Personal Injuries, Probate and Employment. She qualified as an Attorney in New York State in 2011 and was also called to the Bar of England and Wales in 2019.

Roddy McConnell BL
Roddy is a practising barrister who trained as a physiotherapist who specialises in personal injuries law. He has particular expertise in the overlap between physiotherapy and personal injuries law.



