It might be very useful to record some of the recent milestones in the area of defamation law. The key milestone in the process towards reform can be said to date from 1991, with the publication of the Report of the Law Reform Commission on the Civil Law of Defamation. In May 1994, the National Newspapers of Ireland published a draft defamation Bill. Their Bill was largely based upon the recommendations contained in the Law Reform Commission's report. The main differences were that the newspapers wanted the complete abolition of juries in defamation actions; that the making or offering of an apology should be taken into account in awarding damages; and that defamation actions should be commenced within one year of publication. The Progressive Democrats published a defamation Bill in 1995, which dealt with three separate areas, civil defamation, criminal defamation and contempt of court. That Bill was not voted down on its Second Reading, but was effectively parked by the then Government.