Mr. Ciarán Breen:

Yes. If one fails to disclose something, as a matter of law one has to concede liability that there was a failure. By the way, that is a concession we make on behalf of the HSE having regard to our delegated function. I will make one point about why women have to go to court, as opposed to being dragged into it, the phrase the media sometimes use. There are very good reasons a lawyer acting on behalf of any of the cervical cancer women would want to commence pleadings in court. Sometimes there are child dependents who, in some cases, may ultimately need to be made wards of court or in respect of whom the courts may have to ensure they will be looked after by way of certain orders. There is another factor, that the lawyers must protect themselves against the Statute of Limitations. An additional factor is that serving pleadings allows someone to set out their case in the best way possible for the defendant to meet.