the spokesman for the Youth Against Divorce campaign. In later years, Barrett himself sought a divorce in 2016. Result The '± Yes 1986' column shows the percentage point change in the Yes vote compared to the Tenth Amendment of the Constitution Bill on a similar proposal rejected in a referendum in 1986. Court challenge During the referendum, government funds were used to advertise in favour of a 'Yes' vote. One week before the referendum, Patricia McKenna, a Green Party MEP, successfully lodged a complaint against the government with the Supreme Court, and the advertising stopped. This Supreme Court decision led to legislation that would establish a Referendum Commission for each referendum, commencing with the Eighteenth Amendment in 1998. The returning officer submitted a provisional certificate of the result of the referendum in the High Court as required by the Referendum Act 1994. According to The Irish Times, "the polls taken at the time showed that, if anything, the end of the advertising campaign coincided with a halt in the slide of support for divorce". Because of the use of Government funds for one side of the campaign, a petition against the result was lodged by Des Hanafin, a Fianna Fáil Senator and chairman of the Pro Life Campaign, which was dismissed by the High Court on 9 February 1996. Hanafin appealed to the Supreme Court, which in June upheld the High Court decision. The High Court then endorsed the provisional certificate on 14 June 1996. President Mary Robinson signed the amendment bill into law three days later. Subsequent legislation Before the referendum, a draft Family Law (Divorce) Bill was published to illustrate how the Constitutional provisions would be implemented if the amendment were passed. Once the Constitutional amendment came into force, the divorce bill was introduced in the Oireachtas on 27 June 1996 and signed into law on 27 November 1996. This gave effect in primary legislation to the new Constitutional provisions. Although this act, the Family Law (Divorce) Act, 1996, specified its own commencement date as 27 February 1997, the first divorce was granted on 17 January 1997, based solely on the constitutional amendment, to a dying man who wanted urgently to marry his new partner. The Thirty-eighth Amendment of the Constitution of Ireland was approved in a referendum held in May 2019, and removed the constitutional requirement for parties to be living apart before a divorce. It also