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TRIBUNAL OF INQUIRY
 
(Payments to Messrs Charles Haughey and Michael Lowry) Appointed by instrument of An Taoiseach dated the 26th day of September 1997 
Sole Member:The Honourable Mr. Justice Michael Moriarty
 
SUBMISSIONS ON BEHALF MICHAEL LOWRY T.D.
 APPLICATION IN RESPECT OF MR. MICHAEL ANDERSEN’SNON-AVAILABILITY AS A WITNESS
Kelly Noone & Co.SolicitorsTaney HallEglinton TerraceDundrumDublin 14.
 
 
 PRELIMINARY
 1. By letter dated 3
rd
August 2005, Mr. Michael Heneghan, Solicitor to the Tribunal,wrote to Messrs Kelly Noone & Co. solicitors for Mr. Michael Lowry T.D., indicatingthat the Tribunal intended to resume its hearings into the circumstances surroundingthe grant of the second GSM licence to ESAT Digifone Limited on Tuesday, 20
th
September 2005. 2. Mr. Heneghan’s letter included the statement that, insofar as Mr. Michael Andersenwas concerned, “…
the Tribunal is now proceeding on the basis that for all practical  purposes, Mr. Andersen’s evidence will not be available
.” 3. The history of the Tribunal’s efforts to arrange for the attendance of Mr. Andersen togive evidence to the Tribunal in Dublin (or indeed to travel to Denmark to arrange for the taking of his evidence there) has been documented fully in enclosures suppliedwith a further letter of Mr. Heneghan of 22
nd
August 2005. That letter, like itspredecessor, indicated that there would be an opportunity for parties to address theTribunal by way of submission on Tuesday, 13
th
September as to the consequencesof the non-availability of Mr. Andersen. Both letters also requested thatcomprehensive written submissions
be received by the Tribunal by 7
th
September 2005 in the event that it was wished to make an oral submission on behalf of Mr.Lowry on this matter. 4. It is in this context, at the specific behest of the Tribunal, that the following writtensubmission is made on behalf of Mr. Lowry. In short it is submitted that the GSMmodule should cease forthwith on the basis: (a)
 
That Mr. Lowry’s constitutional rights have been irretrievably breached by theTribunal in the manner in which it has conducted the GSM module to date; 
 
(b)
 
That the Tribunal has uncovered no relevant evidence, after 131 days of hearings on the awarding of the GSM licence, that could cause it to report in amanner relevant to its Terms of Reference; (c)
 
That, as a matter of practicality, the Tribunal is unable to complete the GSMmodule and make any relevant findings of fact in the absence of Mr. Andersen; (d)
 
That, as regards the constitutional requirement for fair procedures, the absenceof Mr. Andersen fatally compromises the
In re Haughey 
rights of Mr. Lowry giventhe manner in which Mr. Andersen has been relied upon by the Tribunal atdifferent stages of the GSM process notwithstanding that he will not now giveevidence; (e)
 
That there are very clear inferences to be drawn from correspondence from theSecretary General of the Government and from transcripts of recent Dáil Debatesthat the Tribunal is losing the support of both the Government and the Oireachtasfor its work and that this is a powerful consideration in favour of the submissionmade on behalf of Mr. Lowry. 
THE GSM INQUIRY AND THE TERMS OF REFERENCE OF THE TRIBUNAL
 5. The Terms of Reference of the Tribunal were approved by Dáil Éireann on the 11thday of September, 1997 and by Seanad Éireann on the 18th day of September,1997. An instrument establishing the Tribunal was effected on 26
th
September 1997,almost exactly eight years ago. The Terms of Reference of the Tribunal, are, inrelevant part, as follows:- 
“WHEREAS a Resolution in the following terms was passed by Dáil Éireann on the 11thday of September, 1997 and by Seanad Éireann on the 18th day of September, 1997."Bearing in mind serious public concern arising from the Report of the Tribunal of Inquiry(Dunnes Payments) published on 25 August, 1997, which established that irregular payments were made to and benefits conferred on certain persons who were members of the Houses of the Oireachtas between 1 January, 1986, and 31 December, 1996.
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