The statutory changes effected by the 1990 Act were not reflected in the Constitution. Without a constitutional prohibition, the Oireachtas could have reintroduced the death penalty by statute in circumstances allowed for in Protocol No. 6, for example, in time of war. The Government could also have invoked the procedure under Article 28.3.3o of the Constitution to proclaim a public emergency and use the emergency provision to provide cover for the utilisation of the death penalty. The last Government submitted the Twenty-first Amendment of the Constitution Bill to the people in 2001. It was approved by the people in a referendum as a result of which there is now full constitutional protection for the right to life and protection against the death penalty written into the Constitution. The death penalty cannot be reintroduced at any stage because the public emergency clause in our constitutional arrangement was also amended.