{"id":22834,"date":"2023-08-22T20:22:32","date_gmt":"2023-08-22T20:22:32","guid":{"rendered":"https:\/\/legalblog.ie\/?p=22834"},"modified":"2023-08-27T16:14:24","modified_gmt":"2023-08-27T16:14:24","slug":"surrogacy","status":"publish","type":"post","link":"https:\/\/legalblog.ie\/surrogacy\/","title":{"rendered":"Surrogacy [ECHR]"},"content":{"rendered":"<div id=\"ez-toc-container\" class=\"ez-toc-v2_0_63 counter-hierarchy ez-toc-counter ez-toc-grey ez-toc-container-direction\">\n<div class=\"ez-toc-title-container\">\n<p class=\"ez-toc-title \" >Table of Contents<\/p>\n<span class=\"ez-toc-title-toggle\"><a href=\"#\" class=\"ez-toc-pull-right ez-toc-btn ez-toc-btn-xs ez-toc-btn-default ez-toc-toggle\" aria-label=\"Toggle Table of Content\"><span class=\"ez-toc-js-icon-con\"><span class=\"\"><span class=\"eztoc-hide\" style=\"display:none;\">Toggle<\/span><span class=\"ez-toc-icon-toggle-span\"><svg style=\"fill: #999;color:#999\" xmlns=\"http:\/\/www.w3.org\/2000\/svg\" class=\"list-377408\" width=\"20px\" height=\"20px\" viewBox=\"0 0 24 24\" fill=\"none\"><path d=\"M6 6H4v2h2V6zm14 0H8v2h12V6zM4 11h2v2H4v-2zm16 0H8v2h12v-2zM4 16h2v2H4v-2zm16 0H8v2h12v-2z\" fill=\"currentColor\"><\/path><\/svg><svg style=\"fill: #999;color:#999\" class=\"arrow-unsorted-368013\" xmlns=\"http:\/\/www.w3.org\/2000\/svg\" width=\"10px\" height=\"10px\" viewBox=\"0 0 24 24\" version=\"1.2\" baseProfile=\"tiny\"><path d=\"M18.2 9.3l-6.2-6.3-6.2 6.3c-.2.2-.3.4-.3.7s.1.5.3.7c.2.2.4.3.7.3h11c.3 0 .5-.1.7-.3.2-.2.3-.5.3-.7s-.1-.5-.3-.7zM5.8 14.7l6.2 6.3 6.2-6.3c.2-.2.3-.5.3-.7s-.1-.5-.3-.7c-.2-.2-.4-.3-.7-.3h-11c-.3 0-.5.1-.7.3-.2.2-.3.5-.3.7s.1.5.3.7z\"\/><\/svg><\/span><\/span><\/span><\/a><\/span><\/div>\n<nav><ul class='ez-toc-list ez-toc-list-level-1 ' ><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-1\" href=\"https:\/\/legalblog.ie\/surrogacy\/#Embryo_Donation\" title=\"Embryo Donation\">Embryo Donation<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-2\" href=\"https:\/\/legalblog.ie\/surrogacy\/#Surrogacy\" title=\"Surrogacy\">Surrogacy<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-3\" href=\"https:\/\/legalblog.ie\/surrogacy\/#Registration_of_Births\" title=\"Registration of Births\">Registration of Births<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-4\" href=\"https:\/\/legalblog.ie\/surrogacy\/#Parental_Link\" title=\"Parental Link\">Parental Link<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-5\" href=\"https:\/\/legalblog.ie\/surrogacy\/#Gestational_Contracts_I\" title=\"Gestational Contracts I\">Gestational Contracts I<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-6\" href=\"https:\/\/legalblog.ie\/surrogacy\/#Gestational_Contracts_II\" title=\"Gestational Contracts II\">Gestational Contracts II<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-7\" href=\"https:\/\/legalblog.ie\/surrogacy\/#Gestational_Contracts_II-2\" title=\"Gestational Contracts II\">Gestational Contracts II<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-8\" href=\"https:\/\/legalblog.ie\/surrogacy\/#Recognition_of_Link\" title=\"Recognition of Link\">Recognition of Link<\/a><\/li><\/ul><\/nav><\/div>\n<h3><span class=\"ez-toc-section\" id=\"Embryo_Donation\"><\/span>Embryo Donation<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Parrillo v. Italy 2015 (Grand Chamber) \u00a0concerned a ban under Italian Law no. 40\/2004, preventing the applicant from donating to scientific research embryos obtained from an in vitro fertilisation which were not destined for a pregnancy. The Court, which was called upon for the first time to rule on this issue, held that Article 8 (right to respect for private and family life) of the Convention was applicable in this case under its \u201cprivate life\u201d aspect, as the embryos in question contained the applicant\u2019s genetic material and accordingly represented a constituent part of her identity. The Court considered at the outset that Italy was to be given considerable room for manoeuvre (\u201cwide margin of appreciation\u201d) on this sensitive question,.<\/p>\n<p>Nedescu v. Romania The applicants, a married couple, alleged that they had not been able to recover embryos that had been seized by the prosecuting authorities in 2009 and that they had been prevented from having another child. In this case the Court held that there had been a violation of Article 8 (right to respect for private and family life) of the Convention, finding in particular that preventing the applicants from retrieving their embryos as ordered by the High Court of Cassation had constituted an interference with their right to respect for their private life which was not provided for by law.<\/p>\n<p>Petithory Lanzmann v. France concerned the applicant\u2019s request to have her deceased son\u2019s sperm transferred to an establishment capable of arranging medically assisted reproduction or gestational surrogacy. The applicant complained in particular that it was impossible to have access to her deceased son\u2019s sperm with a view to arranging, in accordance with his last wishes, medically assisted reproduction via a donation to an infertile couple or gestational surrogacy, procedures which would be authorised in Israel or the United States.<\/p>\n<p>The Court observed that the applicant\u2019s complaint actually comprised two distinct parts. In the first part she claimed to be an indirect victim, on behalf of her late son, while in the second she claimed to be a direct victim since she had been deprived of the possibility of becoming a grandparent. The Court declared both parts of the application inadmissible, noting in particular that the right for an individual to decide how and when to become a parent was a non-transferable right and that Article 8 (right to respect for private and family life) of the Convention did not guarantee a right to become a grandparent.<\/p>\n<p>Lia v. Malta The applicants were husband and wife. The case concerned the authorities\u2019 refusal in 2015 to carry out, at their expense, Intracytoplasmic Sperm Injection \u2013 a procedure to assist procreation \u2013 on the second applicant\u2019s ova owing to her having reached the age of 43. They had previously availed of the procedure, paid for by the State, in 2014.<\/p>\n<p>The Court held that there had been a violation of Article 8 (right to respect for private and family life) of the Convention, finding that the interference suffered by the applicants had not been in accordance with a law of sufficient quality.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Surrogacy\"><\/span>Surrogacy<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Mennesson and Others v. France and Labassee v. France concerned the refusal to grant legal recognition in France to parent-child relationships that had been legally established in the United States between children born as a result of surrogacy treatment and the couples who had had the treatment. In both cases the Court held that there had been no violation of Article 8 (right to respect for private and family life) of the Convention concerning the applicants\u2019 right to respect for their family life. It considered that this contradiction undermined the children\u2019s identity within French society. The Court further noted that the case-law completely precluded the establishment of a legal relationship between children born as a result of \u2013 lawful \u2013 surrogacy treatment abroad and their biological father. This overstepped the wide margin of appreciation left to States in the sphere of decisions relating to surrogacy.<\/p>\n<p>D. and Others v. Belgium concerned the Belgian authorities\u2019 initial refusal to authorise the arrival on its national territory of a child who had been born in Ukraine from a surrogate pregnancy, as resorted to by the applicants, two Belgian nationals.<\/p>\n<p>While the authorities\u2019 refusal, maintained until the applicants had submitted sufficient evidence to permit confirmation of a family relationship with the child, had resulted in the child effectively being separated from the applicants, and amounted to interference in their right to respect for their family life, nonetheless, Belgium had acted within its broad discretion (\u201cwide margin of appreciation\u201d) to decide on such matters. The Court also considered that there was no reason to conclude that the child had been subjected to treatment contrary to Article 3 of the Convention during the period of his separation from the applicants.<\/p>\n<p>Paradiso and Campanelli v. Italy concerned the placement in social-service care of a nine-month-old child who had been born in Russia following a gestational surrogacy contract entered into with a Russian woman by an Italian couple (the applicants); it subsequently transpired that they had no biological relationship with the child. The Grand Chamber found, by eleven votes to six, that there had been no violation of Article 8 (right to respect for private and family life) of the Convention in the applicants\u2019 case. Having regard to the absence of any biological tie between the child and the applicants, the short duration of their relationship with the child and the uncertainty of the ties between them from a legal perspective, and in spite of the existence of a parental project and the quality of the emotional bonds, the Grand Chamber held that a family life did not exist between the applicants and the child. It found, however, that the contested measures fell within the scope of the applicants\u2019 private life.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Registration_of_Births\"><\/span>Registration of Births<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>C and E v. France \u00a0case concerned the French authorities\u2019 refusal to enter in the French register of births, marriages and deaths the full details of the birth certificates of children born abroad through a gestational surrogacy arrangement and conceived using the gametes of the intended father and a third-party donor, in so far as the birth certificates designated the intended mother as the legal mother.<\/p>\n<p>The Court considered in particular that the refusal of the French authorities was not disproportionate, as domestic law afforded a possibility of recognising the parent-child relationship between the applicant children and their intended mother by means of\u00a0adoption of the other spouse\u2019s child. The Court also noted that the average waiting time for a decision was only 4.1 months in the case of full adoption and 4.7 months in the case of simple adoption.<\/p>\n<p>D v. France concerned the refusal to record in the French register of births, marriages and deaths the details of the birth certificate of a child born abroad through a gestational surrogacy arrangement in so far as the certificate designated the intended mother, who was also the child\u2019s genetic mother, as the mother. The Court held that there had been no violation of Article 8 (right to respect for family life) of the Convention, finding that, in refusing to record the details of the third applicant\u2019s Ukrainian birth certificate in the French register of births in so far as it designated the first applicant as the child\u2019s mother, France had not overstepped its margin of appreciation in the circumstances of the present case.<\/p>\n<p>D v. France concerned the refusal to record in the French register of births, marriages and deaths the details of the birth certificate of a child born abroad through a gestational surrogacy arrangement in so far as the certificate designated the intended mother, who was also the child\u2019s genetic mother, as the mother. The Court held that there had been no violation of Article 8 (right to respect for family life) of the Convention, finding that, in refusing to record the details of the third applicant\u2019s Ukrainian birth certificate in the French register of births in so far as it designated the first applicant as the child\u2019s mother, France had not overstepped its margin of appreciation in the circumstances of the present case. It also held that there had been no violation of Article 14 (prohibition of discrimination) of the Convention read in conjunction with Article 8, accepting that the difference in treatment of which the applicants complained with regard to the means of recognition of the legal relationship between such children and their genetic mother had an objective and reasonable justification.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Parental_Link\"><\/span>Parental Link<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Vald\u00eds Fj\u00f6lnisd\u00f3ttir and Others v. Iceland concerned the non-recognition of a parental link between the first two applicants and the third applicant, who was born to them via a surrogate mother in the United States. The first and second applicants were the third applicant\u2019s intended parents, but neither of them was biologically related to him. They had not been recognised as the child\u2019s parents in Iceland, where surrogacy is illegal..<\/p>\n<p>The Court held that there had been no violation of Article 8 (right to respect for family life) of the Convention. It considered, in particular, that despite the lack of a biological link between the applicants, there had been \u201cfamily life\u201d in the applicants\u2019 relationship.<\/p>\n<p>A.L. v. France \u00a0 concerned the compatibility with the right to respect for private life of the domestic courts\u2019 refusal to legally establish the applicant\u2019s paternity vis-\u00e0-vis his biological son \u2013 who had been born in the framework of a gestational surrogacy contract<\/p>\n<p>The Court held that there had been a violation of Article 8 (right to respect for private and family life) of the Convention, on account of the French State\u2019s failure to honour its duty of exceptional diligence in the particular circumstances of the case. In balancing the applicant\u2019s right to respect for his private life, on the one hand, with his son\u2019s right to respect for his private and family life, which required compliance with the principle of prioritising the child\u2019s best interests, the Court considered that the grounds set out by the domestic courts to justify the impugned interference had been relevant and sufficient for the purposes of Article 8 \u00a7 2 of the Convention.<\/p>\n<p>Nevertheless, the Court noted that the proceedings had taken a total of six years and about one month, which was incompatible with the requisite duty of exceptional diligence. In cases involving a relationship between a person and his or her child, the lapse of a considerable amount of time could lead to the legal issue being determined on the basis of a fait accompli.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Gestational_Contracts_I\"><\/span>Gestational Contracts I<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>D.B. and Others v. Switzerland \u00a0case concerned a same-sex couple who were registered partners and had entered into a gestational surrogacy contract in the United States under which the third applicant had been born. The Court held that there had been a violation of Article 8 (right to respect for private life) of the Convention in respect of the applicant child and no violation of Article 8 (right to respect for family life) in respect of the intended father and the genetic father.. Adoption had been open to married couples only, to the exclusion of those in registered partnerships.<\/p>\n<p>K.K. and Others v. Denmark concerned the refusal to allow the first applicant to adopt the two other applicants, who were twins, as a \u201cstepmother\u201d in Denmark. The twins were born to a surrogate mother in Ukraine who had been paid for her service under a contract concluded with the first applicant and her partner, the biological father of the children. Under Danish law, adoption was not permitted in cases where payment had been made to the person who had to consent to the adoption.<\/p>\n<p>The Court held that in the present case there had been no violation of Article 8 (right to respect for family life) of the Convention, finding that there had been no damage to the family life of the applicants, who lived together with the children\u2019s father unproblematically. It also held that there had been no violation of Article 8 (right to respect for private life) of the Convention as regards the mother\u2019s right to respect for her private life as the domestic authorities had been correct in ruling so, in order to protect the public interest in controlling paid surrogacy, over the first applicant\u2019s right to respect for private life.<\/p>\n<p>The Court held, however, that there had been a violation of Article 8 as regards the right to respect for the private lives of the two applicant children, finding that the Danish authorities had failed to strike a balance between their interests and the societal interests in limiting the negative effects of commercial surrogacy, in particular as regards their legal situation and legal relationship to the first applicant.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Gestational_Contracts_II\"><\/span>Gestational Contracts II<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Paradiso and Campanelli v. Italy 2017 (Grand Chamber) concerned the placement in social-service care of a nine-month-old child who had been born in Russia following a gestational surrogacy contract entered into with a Russian woman by an Italian couple (the applicants); it subsequently transpired that they had no biological relationship with the child. The applicants complained, in particular, about the child\u2019s removal from them, and about the refusal to acknowledge the parent-child relationship established abroad by registering the child\u2019s birth certificate in Italy.<\/p>\n<p>The Grand Chamber found, by eleven votes to six, that there had been no violation of Article 8 (right to respect for private and family life) of the Convention in the applicants\u2019 case. Having regard to the absence of any biological tie between the child and the applicants, the short duration of their relationship with the child and the uncertainty of the ties between them from a legal perspective, and in spite of the existence of a parental project and the quality of the emotional bonds, the Grand Chamber held that a family life did not exist between the applicants and the child. It found, however, that the contested measures fell within the scope of the applicants\u2019 private life.<\/p>\n<p>The Grand Chamber further considered that the contested measures had pursued the legitimate aims of preventing disorder and protecting the rights and freedoms of others. On this last point, it regarded as legitimate the Italian authorities\u2019 wish to reaffirm the State\u2019s exclusive competence to recognise a legal parent-child relationship \u2013 and this solely in the case of a biological tie or lawful adoption \u2013 with a view to protecting children. The Grand Chamber also accepted that the Italian courts, having concluded in particular that the child would not suffer grave or irreparable harm as a result of the separation, had struck a fair balance between the different interests at stake, while remaining within the room for manoeuvre (\u201cmargin of appreciation\u201d) available to them.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Gestational_Contracts_II-2\"><\/span>Gestational Contracts II<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>D.B. and Others v. Switzerland concerned a same-sex couple who were registered partners and had entered into a gestational surrogacy contract in the United States under which the third applicant had been born. The applicants complained in particular that the Swiss authorities had refused to recognise the parent child relationship established by a US court between the intended father (the first applicant) and the child born through surrogacy (the third applicant). The Swiss authorities had recognised the parent child relationship between the genetic father (the second applicant) and the child.<\/p>\n<p>The Court held that there had been a violation of Article 8 (right to respect for private life) of the Convention in respect of the applicant child and no violation of Article 8 (right to respect for family life) in respect of the intended father and the genetic father. Regarding the child, it noted in particular that, at the time he was born, domestic law had afforded the applicants no possibility of recognition of the parent-child relationship between the intended parent and the child. Adoption had been open to married couples only, to the exclusion of those in registered partnerships. Not until 1 January 2018 had it become possible to adopt the child of a registered partner. Thus, for nearly seven years and eight months, the applicants had had no possibility of securing definitive recognition of the parent child relationship.<\/p>\n<p>The Court therefore held that for the Swiss authorities to withhold recognition of the lawfully issued foreign birth certificate in so far as it concerned the parent-child relationship between the intended father and the child born through surrogacy in the United States, without providing for alternative means of recognising that relationship, had not been in the best interests of the child. In other words the general and absolute impossibility, for a significant period of time, of obtaining recognition of the relationship between the child and the first applicant had amounted to a disproportionate interference with the third applicant\u2019s right to respect for private life. Switzerland had therefore overstepped its margin of appreciation by not making timely legislative provision for such a possibility<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Recognition_of_Link\"><\/span>Recognition of Link<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Mennesson and Others v. France and Labassee v. France\u00a0 concerned the refusal to grant legal recognition in France to parent-child relationships that had been legally established in the United States between children born as a result of surrogacy treatment and the couples who had had the treatment. The applicants complained in particular of the fact that, to the detriment of the children\u2019s best interests, they were unable to obtain recognition in France of parent-child relationships that had been legally established abroad. It further held in both cases that there had been a violation of Article 8 concerning the children\u2019s right to respect for their private life.<\/p>\n<p>The Court further noted that the case-law completely precluded the establishment of a legal relationship between children born as a result of \u2013 lawful \u2013 surrogacy treatment abroad and their biological father. This overstepped the wide margin of appreciation left to States in the sphere of decisions relating to surrogacy.<\/p>\n<p>Vald\u00eds Fj\u00f6lnisd\u00f3ttir and Others v. Iceland concerned the non-recognition of a parental link between the first two applicants and the third applicant, who was born to them via a surrogate mother in the United States. The first and second applicants were the third applicant\u2019s intended parents, but neither of them was biologically related to him. They had not been recognised as the child\u2019s parents in Iceland, where surrogacy is illegal. The Court held that there had been no violation of Article 8 (right to respect for family life) of the Convention. It considered, in particular, that despite the lack of a biological link between the applicants, there had been \u201cfamily life\u201d in the applicants\u2019 relationship. However, the Court found that the decision not to recognise the first two applicants as the child\u2019s parents had had a sufficient basis in domestic law and, taking note of the efforts on the parts of the authorities to maintain that \u201cfamily life\u201d, ultimately adjudged that Iceland had acted within its discretion in the present case.<\/p>\n<p>A.L. v. France concerned the compatibility with the right to respect for private life of the domestic courts\u2019 refusal to legally establish the applicant\u2019s paternity vis-\u00e0-vis his biological son \u2013 who had been born in the framework of a gestational surrogacy contract in France \u2013 after the surrogate mother had entrusted the child to a third couple. The applicant submitted that the dismissal of his application to establish his paternity in respect of his biological son amounted to a disproportionate interference with his right to respect for his private life, lacking any legal basis.<\/p>\n<p>The Court held that there had been a violation of Article 8 (right to respect for private and family life) of the Convention, on account of the French State\u2019s failure to honour its duty of exceptional diligence in the particular circumstances of the case. In balancing the applicant\u2019s right to respect for his private life, on the one hand, with his son\u2019s right to respect for his private and family life, which required compliance with the principle of prioritising the child\u2019s best interests, the Court considered that the grounds set out by the domestic courts to justify the impugned interference had been relevant and sufficient for the purposes of Article 8 \u00a7 2 of the Convention. Nevertheless, the Court noted that the proceedings had taken a total of six years and about one month, which was incompatible with the requisite duty of exceptional diligence. The child had been about four months old when the case had gone to court, and six-and-a-half years old when the domestic proceedings had ended. In cases involving a relationship between a person and his or her child, the lapse of a considerable amount of time could lead to the legal issue being determined on the basis of a fait accompli.<\/p>\n<p>K.K. and Others v. Denmark concerned the refusal to allow the first applicant to adopt the two other applicants, who were twins, as a \u201cstepmother\u201d in Denmark. The twins were born to a surrogate mother in Ukraine who had been paid for her service under a contract concluded with the first applicant and her partner, the biological father of the children. Under Danish law, adoption was not permitted in cases where payment had been made to the person who had to consent to the adoption.<\/p>\n<p>The Court held that in the present case there had been no violation of Article 8 (right to respect for family life) of the Convention, finding that there had been no damage to the family life of the applicants, who lived together with the children\u2019s father unproblematically. It also held that there had been no violation of Article 8 (right to respect for private life) of the Convention as regards the mother\u2019s right to respect for her private life as the domestic authorities had been correct in ruling so, in order to protect the public interest in controlling paid surrogacy, over the first applicant\u2019s right to respect for private life.<\/p>\n<p>The Court held, however, that there had been a violation of Article 8 as regards the right to respect for the private lives of the two applicant children, finding that the Danish authorities had failed to strike a balance between their interests and the societal interests in limiting the negative effects of commercial surrogacy, in particular as regards their legal situation and legal relationship to the first applicant.<\/p>\n<!--themify_builder_content-->\n<div id=\"themify_builder_content-22834\" data-postid=\"22834\" class=\"themify_builder_content themify_builder_content-22834 themify_builder tf_clear\">\n    <\/div>\n<!--\/themify_builder_content-->\n","protected":false},"excerpt":{"rendered":"<p>Embryo Donation Parrillo v. Italy 2015 (Grand Chamber) \u00a0concerned a ban under Italian Law no. 40\/2004, preventing the applicant from donating to scientific research embryos obtained from an in vitro fertilisation which were not destined for a pregnancy. The Court, which was called upon for the first time to rule on this issue, held that [&hellip;]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_exactmetrics_skip_tracking":false,"_exactmetrics_sitenote_active":false,"_exactmetrics_sitenote_note":"","_exactmetrics_sitenote_category":0,"footnotes":""},"categories":[346],"tags":[],"_links":{"self":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts\/22834"}],"collection":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/comments?post=22834"}],"version-history":[{"count":2,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts\/22834\/revisions"}],"predecessor-version":[{"id":23555,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts\/22834\/revisions\/23555"}],"wp:attachment":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/media?parent=22834"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/categories?post=22834"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/tags?post=22834"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}