Renewal of Personal Injury Summons: “Special Circumstances” Require Necessity and Reasonable Expedition—General COVID/Staffing Difficulties and Liability Admissions Will Not Excuse Multi‑Year Inaction

Case: Drake v South Infirmary Victoria University Hospital CLG & Anor (Approved) [2026] IEHC 367 (Barr J), High Court, 19 June 2026.

1) Introduction

This was an application-stage decision in medical negligence proceedings arising from the prescription and dispensing of methotrexate when the plaintiff was unknowingly pregnant. The plaintiff alleged (i) a miscarriage and (ii) psychiatric injury linked to her child’s serious brain injury, which she contended was caused by methotrexate remaining in her system at the time of a subsequent conception.

The hospital (first defendant) had previously provided a written admission of breach of duty in relation to the prescription episode (in the context of the miscarriage). The pharmacy (second defendant) did not admit liability.

The personal injury summons issued on 27 August 2019 “on a protective basis” (without a liability expert report), expired in August 2020, and was renewed only by order of 9 December 2024. Both defendants moved to set aside that renewal.

Key issue: whether “special circumstances” justified renewal of the summons after an approximate five-year non-service period, assessed under the single-test approach mandated by the Supreme Court.

2) Summary of the Judgment

Barr J set aside the High Court order renewing the personal injury summons. Although the court accepted that obtaining expert evidence on causation of the child’s brain injury was critical (and could justify deferring service in principle), the plaintiff’s solicitor had not shown reasonable expedition over the relevant period.

The court rejected reliance on: (a) COVID-19 disruptions as a blanket explanation for prolonged inactivity; (b) staff maternity leave as an “abnormal or unusual” circumstance; and (c) the hospital’s admission as a basis to avoid the obligation to serve or seek timely renewal.

The court also held that the defendants would suffer prejudice, principally because the case would likely turn on oral evidence about what warnings/advice were given in September 2017—evidence difficult to marshal nearly a decade later.

3) Analysis

3.1 Precedents Cited and Their Role

a) The governing framework: Power v CJSC Indigo Tajikistan & Ors. [2025] IESC 55

The decisive procedural lens was the Supreme Court’s restatement in Power v CJSC Indigo Tajikistan & Ors. [2025] IESC 55. Barr J applied Power for two core propositions:

  • Single integrated test: the court asks whether there are “special circumstances” justifying renewal, taking all circumstances into account, rather than applying a rigid two-step “gateway + interests of justice” structure.
  • Time sensitivity remains central: even within a single test, the length of delay and the adequacy of explanation for that delay are critical.

b) Awaiting expert reports: Maloney v Lacy Building and Civil Engineering Ltd [2010] 4 IR 417; Murphy v HSE [2021] IECA 3; SW v HSE [2025] IEHC 526

These authorities supplied the doctrinal nuance for a common justification advanced in professional negligence litigation: withholding service while seeking expert opinion. The judgment extracts and applies the following propositions:

  • Under Maloney v Lacy Building and Civil Engineering Ltd [2010] 4 IR 417, it may be legitimate to defer service where the awaited expert report is necessary to justify responsibly maintaining the proceedings in the first place (not merely helpful for pleadings or trial preparation).
  • Even if “necessity” is shown, the plaintiff must demonstrate reasonable expedition in trying to obtain the report; delay must be “reasonable in all the circumstances.” This approach was endorsed in Murphy v HSE [2021] IECA 3 and treated as consistent with Power.
  • SW v HSE [2025] IEHC 526 was cited for the same paired requirements: necessity and expedition.

Barr J used these cases both to accept the plaintiff’s proposition that causation evidence about the child’s injury mattered to the mother’s claim, and to reject the plaintiff’s conduct as falling short on expedition.

c) COVID-19 disruption is not a “cover-all”: Brady v Byrne [2021] IEHC 778

The judgment relied on Brady v Byrne [2021] IEHC 778 to emphasise that while COVID-19 was “beyond the ordinary,” the legal system adapted by mid-2020, and courts will not treat COVID-19 as a general excuse for prolonged non-service or inertia. Barr J applied this reasoning to conclude that restrictions and backlogs could not credibly explain a five-year timeline.

3.2 Legal Reasoning

a) What the court accepted: causation of the child’s injury was central to the mother’s pleaded loss

A notable feature of the judgment is its rejection of the defendants’ submission that the child’s causation issues were irrelevant to the plaintiff’s action. Barr J held that the plaintiff’s “primary claim” beyond the miscarriage was psychiatric injury arising from concern about the child’s serious disability. Therefore, if methotrexate did not cause the child’s injury, the plaintiff’s claim would likely shrink materially (to a miscarriage-based claim).

On that footing, the court found that an expert opinion on causation of the child’s brain injury was necessary to “properly institute proceedings,” bringing the case within the Maloney/Murphy/SW principle in theory.

b) Where the plaintiff failed: lack of “reasonable expedition” over the overall period

The decisive finding was not that causation evidence was unnecessary, but that the conduct of the litigation did not display the urgency required to justify renewal:

  • The summons issued in August 2019 with knowledge that causation would be pivotal, yet the key causation report from the foeto-maternal expert was not obtained until May 2025.
  • The court identified “large gaps” where “no effective steps were taken,” which, viewed globally, defeated any claim of reasonable expedition.
  • The judgment contains a clear professional-responsibility theme: once a solicitor takes on “substantial and difficult litigation,” they must devote adequate resources and move it appropriately.

c) COVID-19 and maternity leave: insufficient as pleaded “special circumstances”

Barr J drew two lines:

  • COVID-19: accepted as creating real disruption (especially 2020 into early 2021), but rejected as justifying inactivity over a five-year horizon.
  • Maternity leave: treated as a common business contingency, not an “abnormal or unusual” event capable (without more) of amounting to special circumstances for prolonged delay.

The court also pointed to an internal inconsistency: the plaintiff’s own correspondence suggested service was withheld primarily to await clarification on the child’s causation, which undermined reliance on COVID/staffing difficulties as the operative cause of delay.

d) Liability admissions and estoppel: an admission is not a waiver of procedural rules

The hospital’s admission did not rescue the renewal, for three reasons:

  • The admission related to the initial prescription/miscarriage context, and the hospital was not shown to have appreciated the later pregnancy/child injury issues at the time.
  • The pharmacy made no admission.
  • Critically, the court articulated an important limiting principle: only a representation or conduct inducing delayed service could found an estoppel; a “mere admission of liability without more” cannot.

e) Prejudice and fairness: memory-dependent warnings/advice are hard to litigate a decade later

The court accepted that the central dispute would likely concern what warnings/advice were given about pregnancy risks while taking (or after stopping) methotrexate. The hospital’s internal review did not cover that question. For the pharmacy, the scale of operations (high dispensing volume) made retrieval of reliable recall evidence particularly difficult.

Even absent specific proof of lost documents or unavailable witnesses, the court treated the passage of time itself—given the nature of the disputed facts—as materially prejudicial.

3.3 Impact

  • Reinforces post-Power discipline: although the test is formally “single,” litigants must still provide a compelling, time-anchored narrative showing why renewal is justified at the point sought.
  • “Awaiting a report” remains viable but policed: the judgment validates the principle that causation evidence may be necessary before service, but only where the solicitor can show continuous, reasonable expedition.
  • COVID-19 arguments narrowed: disruption may explain discrete periods, not years of delay.
  • Practice-management message: staffing changes (including maternity leave) will rarely qualify as special circumstances absent exceptional features and demonstrable mitigation steps.
  • Admissions do not suspend procedural obligations: unless the defendant’s conduct induced delay (estoppel), plaintiffs must still serve in time or seek prompt renewal.

4) Complex Concepts Simplified

Renewal of a summons
A summons generally must be served within a defined period after issue. If it expires unserved, the plaintiff must seek a court order renewing it. Renewal is discretionary and requires justification.
“Special circumstances”
Facts that, viewed in context, make it fair to permit renewal despite expiry. After Power v CJSC Indigo Tajikistan & Ors. [2025] IESC 55, the court considers all circumstances together, but the circumstances must still convincingly explain why renewal is justified when sought.
Necessary expert report (as distinct from merely helpful)
Under Maloney v Lacy Building and Civil Engineering Ltd [2010] 4 IR 417, a report can justify delayed service if it is needed to responsibly decide whether the claim is maintainable at all (e.g., to establish a plausible causal link), not simply to perfect pleadings.
Reasonable expedition
The plaintiff must show sustained, practical efforts to obtain the necessary report without avoidable gaps; otherwise, the “awaiting a report” rationale fails.
Prejudice in delay cases
Harm to a defendant’s ability to defend due to the passage of time (e.g., degraded memory, difficulty identifying the person who gave advice, or reconstructing what was said). The court may accept prejudice even without a “smoking gun” like destroyed documents, especially where the dispute is conversation- and recollection-dependent.
Estoppel (in this context)
A defendant may be prevented from objecting to renewal if they induced the plaintiff (by words or conduct) to delay service. The judgment emphasises that an admission of liability, without more, does not create such an estoppel.

5) Conclusion

Drake v South Infirmary Victoria University Hospital CLG & Anor (Approved) [2026] IEHC 367 is a stringent application of the post-Power approach: even where an expert causation opinion is genuinely necessary before service, the party seeking renewal must demonstrate reasonable expedition across the whole period. Generalised reliance on COVID-19 disruption, ordinary staffing contingencies, and even a partial admission of breach will not justify multi-year non-service where the record shows significant inactivity. The decision also highlights the court’s sensitivity to prejudice where the likely battleground is what warnings and advice were given—facts that become increasingly difficult to prove fairly with time.