Of all the restrictions on the press in Ireland the most restrictive, in practice, is the law on defamation. This is when someone sues someone else (the someone else is usually a media outlet) for damaging his or her good name.

This is usually a rich man's game, with high costs and potentially high awards when the plaintiff is successful.

Millions of pounds a year are paid out in damages and costs, more often behind closed doors than in court, and the vast majority of these are cases when the media has been sued.

The burden of proof is such that the defendant in a case has to prove that the allegations are true or are fair comment based on established facts.

"We effectively have to have the equivalent of High Court judicial proof for anything seriously contentious which might damage someone's reputation," says Frank McDonald, the Irish Times Environment Correspondent. He says that in one year in the 1990s, the paper paid more than £1 million in costs and damages.

This contrasts with the US, where a public figure has to prove actual malice on the part of the writer.

Corruption stories here rarely see the light of day: "Even if someone were to tell us that he had paid someone, we couldn't use it," McDonald says.

This has had a massive restriction on what the press could report. Tribunal revelations about planning and paid politicians, for example, came as little surprise to frustrated journalists.

"At any given time in the last 10 years of Dublin County Council, I could have named at least 12 members who were irredeemably corrupt," McDonald says. The same applied to officials.

Journalists have to resorting to make stories vague so the people involved are not identified. Certain figures have been "hiding in plain sight" like this for years.

This is unsatisfactory, because as well as greatly limiting the force of stories, vague reportage such as this tarnishes reputation of those who are not corrupt and lowers the public's expectations of politicians and civil servants. "People will say `Ah, sure, they're all at it,' " says McDonald. This, in itself, undermines democracy.

While there is a strong case to be made for altering Irish law, there is a contradiction: by and large, from the point of view of Irish journalists, the only aspect of the US media that is envied is its freedom. It is frequently held to be intrusive and superficial, often precisely because it can afford to be so. Would Irish papers, especially tabloids, be any different if the laws changed?

Another option would be the Scandinavian system, whereby the courts only offer small sums in damages. Here most people prefer to go to a press ombudsman, which is free and goes a long way to restoring a person's good name. If someone resorts to this, they cannot then go to the courts. A system such as this has been suggested for Ireland many times, but as yet no real response has been forthcoming. Politicians have resisted changing the laws since 1991, when the Law Reform Commission published its recommendations for change. They included switching the burden of proof from the defendant to the plaintiff, as is the case in other areas of law.

Nothing has changed - except that the awards against the media have increased.