protect X's identity, was named in 2002 as Sean O'Brien (b.1949/50). In 1994 he was tried and convicted of defilement of a girl under 15 and sentenced to 14 years in prison, reduced on appeal to four years. He was released in 1997 and obtained a taxi driver's licence. In 2002 he was tried and convicted for the 1999 sexual assault and false imprisonment of a 15-year-old girl in his taxi; his three-and-a-half-year sentence was handed down the day before another abortion referendum. Constitutional amendments In late 1983 the eighth amendment had passed, to ensure that abortion would not be introduced by the judiciary, in a similar manner to the US case of Roe v. Wade. The X case resulted in three proposed amendments to the Irish constitution on the issue of abortion, which were submitted to three referendums all held on 25 November 1992. These were the Twelfth Amendment – on the so-called substantive issue. This proposed that the prohibition on abortions would apply even in cases where the pregnant woman was suicidal. Thirteenth Amendment – specified that the prohibition on abortion would not limit the freedom of pregnant women to travel out of the state Fourteenth Amendment – specified that the prohibition of abortion would not limit the right to distribute information about abortion services in foreign countries. The thirteenth and fourteenth amendments were ratified but the twelfth was rejected. In 2002 an attempt to overturn the suicide grounds was again defeated, in the Twenty-fifth Amendment. In 2018 the Thirty-sixth Amendment of the Constitution of Ireland provided a clear result, allowing abortions to be performed in Ireland, with the X Case frequently cited before the vote as a reason for amending the Constitution. European law Ireland joined the EEC in 1973 (now the European Union), and an express provision in the relevant treaties was and is the principle of free movement of people within the EU. As far back as 1964 the Costa v ENEL case had established that European law had primacy over national laws. The 1992 Maastricht Treaty allowed Ireland an exemption in respect of its laws on abortion. At the time of the Maastricht negotiations, it was thought that this exemption meant that the EU could never impose abortion laws upon Ireland. The X case showed that the Irish government understood that its laws against abortion extended much further, even to a denial of the