{"id":23149,"date":"2023-08-25T19:07:15","date_gmt":"2023-08-25T19:07:15","guid":{"rendered":"https:\/\/legalblog.ie\/?p=23149"},"modified":"2023-08-27T16:00:38","modified_gmt":"2023-08-27T16:00:38","slug":"23149-2","status":"publish","type":"post","link":"https:\/\/legalblog.ie\/23149-2\/","title":{"rendered":"Civil Decision [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\/23149-2\/#Public_judgement\" title=\"Public judgement\">Public judgement<\/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\/23149-2\/#Pronounced_in_Public\" title=\"Pronounced in Public\">Pronounced in Public<\/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\/23149-2\/#Alternative_Publicity\" title=\"Alternative Publicity\">Alternative Publicity<\/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\/23149-2\/#Sample_Breaches\" title=\"Sample Breaches\">Sample Breaches<\/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\/23149-2\/#Within_Reasonable_Time\" title=\"Within Reasonable Time\">Within Reasonable Time<\/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\/23149-2\/#Reasoned_Decision\" title=\"Reasoned Decision\">Reasoned Decision<\/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\/23149-2\/#Extent_of_Reasons\" title=\"Extent of Reasons\">Extent of Reasons<\/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\/23149-2\/#Refusing_Leave_Dismiss_Appeal\" title=\"Refusing Leave \/ Dismiss Appeal\">Refusing Leave \/ Dismiss Appeal<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-9\" href=\"https:\/\/legalblog.ie\/23149-2\/#Departure_from_Precedent\" title=\"Departure from Precedent\">Departure from Precedent<\/a><\/li><\/ul><\/nav><\/div>\n<h3><span class=\"ez-toc-section\" id=\"Public_judgement\"><\/span>Public judgement<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>The judgement in a civil and criminal matter should be pronounced in public. This implies that it be made available and not necessarily that it be made in open court or read out.<\/p>\n<p>Judgements may be redacted or withheld to the same extent that parties may be excluded from proceedings in cases such as child protection interests of juvenile\u2019s private life or where other special considerations apply. However even in these cases parties with an interest should with the consent of court if necessary be able to obtain copies of the judgement or have access to the orders.<\/p>\n<p>In Raza v Bulgaria it was stated that even in undisputable national security cases such as those relating to terrorist activities, some states have opted to classify only those parts of the judicial decision whose disclosure would compromise national security or the safety of others, thus illustrating that there existed techniques which could accommodate legitimate security concerns without fully negating fundamental procedural guarantees such as the publicity of judicial decisions<\/p>\n<p>The public character of proceedings before judicial bodies protects litigants against the administration of justice in secret with no public scrutiny and constitutes a basic safeguard against arbitrariness (Fazliyski v. Bulgaria, 2013, \u00a7 69, concerning a case classified secret \u2013 violation). It is also a means of maintaining confidence in the courts (Pretto and Others v. Italy, 1983, \u00a7 21).<\/p>\n<p>Even in indisputable national-security cases, such as those relating to terrorist activities, some States have opted to classify only those parts of the judicial decisions whose disclosure would compromise national security or the safety of others, thus illustrating that there exist techniques which could accommodate legitimate security concerns without fully negating fundamental procedural guarantees such as the publicity of judicial decisions (Fazliyski v. Bulgaria, 2013, \u00a7 69).<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Pronounced_in_Public\"><\/span>Pronounced in Public<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Article 6 \u00a7 1 states \u201cJudgment shall be pronounced publicly\u201d, which would seem to suggest that reading out in open court is required. The Court has found, however, that \u201cother means of rendering a judgment public\u201d may also be compatible with Article 6 \u00a7 1 (Straume v. Latvia, 2022, \u00a7 126; Moser v. Austria, 2006, \u00a7 101).<\/p>\n<p>In order to determine whether the forms of publicity provided for under domestic law are compatible with the requirement for judgments to be pronounced publicly within the meaning of Article 6 \u00a7 1, \u201cin each case the form of publicity to be given to the judgment under the domestic law &#8230; must be assessed in the light of the special features of the proceedings in question and by reference to the object and purpose of Article 6 \u00a7 1\u201d (Pretto and Others v. Italy, 1983, \u00a7 26; Axen v. Germany, 1983, \u00a7 31). The object pursued by Article 6 \u00a7 1 in this context \u2013 namely, to ensure scrutiny of the judiciary by the public with a view to safeguarding the right to a fair trial \u2013 must have been achieved during the course of the proceedings, which must be taken as a whole (ibid., \u00a7 32, and Straume v. Latvia, 2022, \u00a7 133; see also, mutatis mutandis, in relation to expulsion and national security, Razav. Bulgaria, 2010, \u00a7 53).<\/p>\n<p>Where only the operative part of the judgment is read out in public: it must be ascertained whether the public had access by other means to the reasoned judgment which was not read out and, if so, the forms of publicity used must be examined in order to subject the judgment to public scrutiny (Ryakib Biryukov v. Russia, 2008, \u00a7\u00a7 38-46 and case-law references cited in \u00a7\u00a7 33-36). As the reasons which would have made it possible to understand why the applicant\u2019s claims had been rejected were inaccessible to the public, the object pursued by Article 6 \u00a7 1 was not achieved (ibid., \u00a7 45; see also Straume v. Latvia, 2022, \u00a7\u00a7 130-133).<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Alternative_Publicity\"><\/span>Alternative Publicity<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Where judgment is not pronounced publicly it must be ascertained whether sufficient publicity was achieved by other means.\u00a0In the following examples sufficient publicity was achieved by means other than public pronouncement:<\/p>\n<ul>\n<li>higher courts which did not publicly pronounce decisions rejecting appeals on points of law: in order to determine whether the manner in which a Court of Cassation delivered its judgment met the requirements of Article 6 \u00a7 1, account must be taken of the entirety of the proceedings conducted in the domestic legal order and of the role of that court therein (Pretto and Others v. Italy, 1983, \u00a7 27).In finding no violation of Article 6 \u00a7 1 the Court paid particular attention to the stage of the procedure and to the scrutiny effected by these courts \u2013 which was limited to points of law \u2013 and to the judgments they delivered, upholding the decisions of the lower courts without any change to the consequences for the applicants. In the light of these considerations it found that the requirement for public pronouncement had been complied with where, by being deposited in the court registry, the full text of the judgment had been made available to everyone (ibid., \u00a7\u00a7 27-28) in addition to its publication in the Official Gazette (Straume v. Latvia, 2022, \u00a7 131 ; Ernst and Others v. Belgium, 2003, \u00a7\u00a7 69-70), or where a judgmentupholding that of a lower court which itself had been pronounced publicly had been given without a hearing (Axen v. Germany, 1983, \u00a7 32).<\/li>\n<li>Trial court: the Court found no violation in a case where an appellate court publicly delivered a judgment summarising and upholding the decision of a first-instance court which had held a hearing but had not delivered its judgment in public (Lamanna v. Austria, 2001, \u00a7\u00a7 33-34).<\/li>\n<li>ases concerning the residence of children: while the domestic authorities are justified in conducting these proceedings in chambers in order to protect the privacy of the children and the parties and to avoid prejudicing the interests of justice, and to pronounce the judgment in public would, to a large extent, frustrate these aims, the requirement under Article 6 \u00a7 1 concerning the public pronouncement of judgments is satisfied where anyone who can establish an interest may consult or obtain a copy of the full text of the decisions, those of special interest being routinely published, thereby enabling the public to study the manner in which the courts generally approach such cases and the principles applied in deciding them (B. and P. v. the United Kingdom, 2001, \u00a7 47).<\/li>\n<\/ul>\n<h3><span class=\"ez-toc-section\" id=\"Sample_Breaches\"><\/span>Sample Breaches<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>In the following cases, failure to pronounce the judgment publicly led to the finding of a violation:<\/p>\n<ul>\n<li>In a child residence case between a parent and a public institution: giving persons who established a legal interest in the case access to the file and publishing decisions of special interest (mostly of the appellate courts or the Supreme Court) did not suffice to comply with the requirements of Article 6 \u00a7 1 concerning publicity (Moser v. Austria, 2006, \u00a7\u00a7 102-03).<\/li>\n<li>When courts of first and second instance examined in chambers a request for compensation for detention without their decisions being pronounced publicly or publicity being sufficiently ensured by other means (Werner v. Austria, 1997, \u00a7\u00a7 56-60).<\/li>\n<li>Where a claim for damages was examined with the public excluded and the judgments were made available to the parties after a certain period of time without being made accessible to the public in some form \u2013 notification of the parties to the proceedings alone not being sufficient (Vasil Vasilev v. Bulgaria, 2021, \u00a7\u00a7 116-117).<\/li>\n<li>Where the first-instance judgment was not pronounced publicly, only the operative part of the appellate court\u2019s judgment was read out in public and no public hearing was held, with the result that the proceedings had not been subject to sufficient public scrutiny \u2013 even if it was possible to ask for an anonymised copy of the judgment to be provided at the court\u2019s discretion (Straume v. Latvia, 2022, \u00a7\u00a7 130-133, and case-law references cited).<\/li>\n<\/ul>\n<h3><span class=\"ez-toc-section\" id=\"Within_Reasonable_Time\"><\/span>Within Reasonable Time<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Judgement must be given within a reasonable time. In Frydlender v France, the court reiterated that the reasonableness of the length of proceedings must be assessed in the light of the circumstances of the case and with reference to the following criteria.<\/p>\n<ul>\n<li>the complexity of the case<\/li>\n<li>the conduct of the applicant and of the relevant authorities and<\/li>\n<li>what was at stake for the applicant in the dispute.<\/li>\n<\/ul>\n<p>The court reiterated that it is for the states to organise their legal systems in such a way that the courts can guarantee everyone the right to a final decision within a reasonable time in the determination of civil rights and obligations. For this purpose, time is measured from the commencement of proceedings whether in civil or in criminal matters. It runs until the determination of the matter including appeals and post-hearing determinations.<\/p>\n<p>In Scordino v Italy, the court indicated that national courts should adopt steps to deal with delays in judicial proceedings. States should take systematic steps including expedition of proceedings and compensation for delays. The court indicated that it was not necessary to have both compensation and provision for expedition.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Reasoned_Decision\"><\/span>Reasoned Decision<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Presumptively Article 6.1 requires a reasoned decision on the evidence. This is an important part of the fair hearing. It allows the person concerned to consider the reasons on which the decision was made and whether the court has taken proper account of critical matters. It may be essential to an appeal.<\/p>\n<p>In Tazquet v Belgium, the European court confirmed that juries are not required to give detailed reasons for their decision. What is required that it is possible to understand the verdict given. The judge should give directions to the jury as to the matters which they decide.<\/p>\n<p>Garou v Greece confirmed that the nature and extent of the reasons required is dependent on the nature of the court and national practice.<\/p>\n<p>The guarantees enshrined in Article 6 \u00a7 1 include the obligation for courts to give sufficient reasons for their decisions (H. v. Belgium, 1987, \u00a7 53, and for a summary of the principles, Zayidov<br \/>\nv. Azerbaijan (no. 2), 2022, \u00a7 91). A reasoned decision shows the parties that their case has truly been heard, and thus contributes to a greater acceptance of the decision (Magnin v. France (dec.), 2012,\u00a7 29).<\/p>\n<p>Although a domestic court has a certain margin of appreciation when choosing arguments and admitting evidence, it is obliged to justify its activities by giving reasons for its decisions (Suominen v. Finland, 2003, \u00a7 36; Carmel Saliba v. Malta, 2016, \u00a7\u00a7 73 and 79).<\/p>\n<p>The reasons given must be such as to enable the parties to make effective use of any existing right of appeal (Hirvisaari v. Finland, 2001, \u00a7 30 in fine).<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Extent_of_Reasons\"><\/span>Extent of Reasons<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Article 6 \u00a7 1 obliges courts to give reasons for their decisions, but cannot be understood as requiring a detailed answer to every argument (Garc\u00eda Ruiz v. Spain [GC], 1999, \u00a7 26; Perez v. France [GC], 2004, \u00a7 81; Van de Hurk v. the Netherlands, 1994, \u00a7 61; Jahnke and Lenoble v. France (dec.), 2000).<\/p>\n<p>The extent to which this duty to give reasons applies may vary according to the nature of the decision (Ruiz Torija v. Spain, 1994, \u00a7 29; Hiro Balani v. Spain, 1994, \u00a7 27) and can only be determined in the light of the circumstances of the case: it is necessary to take into account, inter alia, the diversity of the submissions that a litigant may bring before the courts and the differences existing in the Contracting States with regard to statutory provisions, customary rules, legal opinion and the presentation and drafting of judgments (Ruiz Torija v. Spain, 1994, \u00a7 29; Hiro Balani v. Spain, 1994,\u00a7 27).<\/p>\n<p>As to whether the Court of Cassation did not examine a ground of appeal raised by the applicant, or whether it assessed the relevance of the ground of appeal before deciding to reject it by means of brief reasoning, see Tourisme d\u2019affaires v. France, 2012, \u00a7\u00a7 28 et seq.; and also Higgins and Others v. France, 1998, \u00a7 43. In a case where a court had not explicitly examined the applicant\u2019s complaint, the Court was able to accept that their silence on that complaint could reasonably be construed as an implicit rejection in the circumstances of the case (\u010civinskait\u0117 v. Lithuania, 2020, \u00a7\u00a7 142-144). Where the case concerns national security, the secret nature of the documents concerned may limit the scope of the obligation to give reasons for judicial decisions (compare Regner v. the Czech Republic [GC], 2017, \u00a7 158 in fine, and, mutatis mutandis, \u0160eks v. Croatia, 2022, \u00a7 71).<\/p>\n<p>However, where a party\u2019s submission is decisive for the outcome of the proceedings, it requires a specific and express reply (Ruiz Torija v. Spain, 1994, \u00a7 30; Hiro Balani v. Spain, 1994, \u00a7 28; and compare Petrovi\u0107 and Others v. Montenegro, 2018, \u00a7 43).<\/p>\n<p>The courts are therefore required to examine:<\/p>\n<ul>\n<li>he litigants\u2019 main arguments (Buzescu v. Romania, 2005, \u00a7 67; Donadze v. Georgia, 2006,\u00a7 35); specific, pertinent and important points (Mont Blanc Trading Ltd and Antares Titanium Trading Ltd v. Ukraine, 2021, \u00a7\u00a7 82 and 84).<\/li>\n<li>pleas concerning the rights and freedoms guaranteed by the Convention and its Protocols: the national courts are required to examine these with particular rigour and care (Fabris v. France [GC], 2013, \u00a7 72 in fine; Wagner and J.M.W.L. v. Luxembourg, 2007, \u00a7 96). This is a consequence of the subsidiarity principle.<\/li>\n<\/ul>\n<h3><span class=\"ez-toc-section\" id=\"Refusing_Leave_Dismiss_Appeal\"><\/span>Refusing Leave \/ Dismiss Appeal<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Article 6 \u00a7 1 does not require a supreme court to give more detailed reasoning when it simply applies a specific legal provision to dismiss an appeal on points of law as having no prospects of success, without further explanation (Gorou v. Greece (no. 2) [GC], 2009, \u00a7 41; Burg and Others v. France (dec.), 2003).<\/p>\n<p>Similarly, in the case of an application for leave to appeal, which is the precondition for a hearing of the claims by the superior court and the eventual issuing of a judgment, Article 6 \u00a7 1 cannot beinterpreted as requiring that the rejection of leave be itself subject to a requirement to give detailed reasons (Bufferne v. France (dec.), 2002; Kukkonen v. Finland (no. 2), 2009, \u00a7 24). Compare Gorou v. Greece (no. 4), 2007, \u00a7 22.<\/p>\n<p>Furthermore, in dismissing an appeal, an appellate court may, in principle, simply endorse the reasons for the lower court\u2019s decision (Garc\u00eda Ruiz v. Spain [GC], 1999, \u00a7 26; contrast Tatishvili v. Russia, 2007, \u00a7 62). However, the notion of a fair procedure requires that a national court which has given sparse reasons for its decisions, whether by incorporating the reasons of a lower court or otherwise, did in fact address the essential issues which were submitted to its jurisdiction and did not merely endorse without further ado the findings reached by a lower court (Helle v. Finland, 1997, \u00a7 60). This requirement is all the more important where a litigant has not been able to present his case orally in the domestic proceedings (ibid.).<\/p>\n<p>However, appellate courts (at second instance) with responsibility for filtering out unfounded appeals and with jurisdiction to deal with questions of fact and law in civil proceedings are required to give reasons for their refusal to accept an appeal for adjudication (Hansen v. Norway, 2014, \u00a7\u00a7 77- 83). In the case cited, the Court of Appeal had refused to consider an appeal by the applicant against a decision by the first-instance court in civil proceedings, holding that it was \u201cclear that the appeal will not succeed\u201d and in doing so simply reproducing the wording of the Code of Civil Procedure.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Departure_from_Precedent\"><\/span>Departure from Precedent<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Furthermore, a constitutional court that has departed from one of its previous judgments simply by expressing its \u201cdisagreement\u201d with its earlier position has not provided sufficient reasons (Grz\u0119da v. Poland [GC], \u00a7 315). Furthermore, the Court found no violation in a case where no specific response had been given to an argument relating to an inconsequential aspect of the case \u2013 namely the absence of a signature and a stamp, which was a flaw of a formal rather than substantive nature and had been promptly rectified (Mugo\u0161a v. Montenegro, 2016, \u00a7 63).<\/p>\n<p>However, the Court has emphasised the importance of sufficient reasons being provided by the court, for example in civil liability proceedings relating to a criminal act (see Carmel Saliba v. Malta, 2016, \u00a7 78, and the link with safeguards in \u201ccriminal\u201d matters). Lastly, it has held that a deficiency in the provision of reasons may result in a \u201cdenial of justice\u201d (Ball\u0131kta\u015f Bing\u00f6ll\u00fc v. Turkey, 2021, \u00a7 77, and see under \u201cFourth instance\u201d above<\/p>\n<!--themify_builder_content-->\n<div id=\"themify_builder_content-23149\" data-postid=\"23149\" class=\"themify_builder_content themify_builder_content-23149 themify_builder tf_clear\">\n    <\/div>\n<!--\/themify_builder_content-->\n","protected":false},"excerpt":{"rendered":"<p>Public judgement The judgement in a civil and criminal matter should be pronounced in public. This implies that it be made available and not necessarily that it be made in open court or read out. Judgements may be redacted or withheld to the same extent that parties may be excluded from proceedings in cases such [&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":[345],"tags":[],"_links":{"self":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts\/23149"}],"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=23149"}],"version-history":[{"count":9,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts\/23149\/revisions"}],"predecessor-version":[{"id":23530,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts\/23149\/revisions\/23530"}],"wp:attachment":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/media?parent=23149"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/categories?post=23149"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/tags?post=23149"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}