The Poor Law Valuation (PLV), more commonly known as Griffith’s Valuation, was carried out between 1846–64 under the directorship of Sir Richard Griffith. The survey was used to determine the amount of tax payable towards the support of the poor within poor law unions. The criteria employed for the valuation included a commodity price index, proximity to rail and canal transportation, and proximity to market towns. The resulting survey was arranged by barony and civil parish, and is often utilised as a census substitute for records lost in the destruction of the Public Record Office in 1922. The commodity price index used in the valuation quickly became outdated and inaccurate. However, there was no functioning appeal system, meaning that the valuations remained unaltered for well over a century until the PLV case in the early 1980s.

Growing disquiet concerning the use of the PLV system for setting tax liability and eligibility for grants emerged in the 1960s and 70s. The system was actively being employed and expanded to determine rates on agricultural land, health contributions (Health Contributions Act 1978), education grants (Local Authorities Higher Education Grants Acts 1968 and 1978), liability for income tax, widow’s pension and social welfare benefits. Several farmers’ groups throughout the country began to form in opposition to this situation, with legal opinions being sought in Cork, Leitrim and Wexford. The various groups met and decided to jointly support one test case to be undertaken in Wexford. In November 1980 plenary summonses were served on Wexford County Council and the Attorney General to challenge the constitutionality of the PLV system. The PLV Action Committee was also established under the auspices of Wexford Irish Farmers’ Association (IFA) to collect money and supervise a fund to support the five named plaintiffs on the summons (Michael Brennan, Rory Brown, Dermot Clancy, Bernard Deveraux, Nicholas Fitzhenry). Subscriptions to the PLV Action Fund were collected from around the country. The case was a representative action in which the named plaintiffs represented all those who subscribed, with summonses eventually being served on all county councils in which there were active subscribers.

Judgement in the court case was delivered on 23 July 1982, when Justice Barrington declared the PLV system unconstitutional, with an order that all legal costs be recoverable from the State. An unsuccessful appeal to the Supreme Court was taken against the ruling by the State. Also, a relisting of the case was undertaken in 1984 in order to seek clarification on how the Supreme Court Order was intended to affect specific issues such as liability for rates payment; assessment for health contributions; income tax payment; and qualification for dole, welfare benefits, medical cards and education grants. 

Archival History

Deposited by Thomas Doyle, Secretary of the PLV Action Committee, in February 2007. Additional material deposited by Rory Brown in February 2008.