Dr. Joanne Blennerhassett:

Each of the legal systems of the member states are so different and in terms of harmonisation, it is difficult to have a one-size-fits-all approach. That is where the European Commission has tried to legislate. By giving guidelines, it has tried to create a blueprint. Each jurisdiction has its own nuances that it needs to deal with and its own political forces.

We can learn a lot by looking at the United Kingdom - the use of the group litigation order in England and Wales - and also from the safeguards that the European Commission recommended prohibiting contingency fees and protecting against abuse so that Ireland will not become a jurisdiction, like the United States, where there is ambulance chasing and there are incentivised class actions. We can learn lessons from the United Kingdom and other common law jurisdiction so that we are comparing like with like.