On 23 September 1976 President Cearbhall Ó Dálaigh consulted with the Council of State for four hours on whether to refer the Emergency Powers Bill 1976 to the Supreme Court to rule on whether it was constitutional or not. Attorney General Declan Costello & the President (himself 
a former AG & Chief Justice) debated points of law in great detail. When the court ruled that the bill was constitutional, he signed the bill into law on 16 October 1976. On the same day, an IRA bomb in Mountmellick killed Michael Clerkin, a member of the Garda Síochána & four
Gardaí badly wounded. The incident was one of the few occasions during The Troubles when Gardai were deliberately targeted. On the following day, Minister for Defence Paddy Donegan, visiting a barracks in Mullingar to open a canteen, attacked the President for sending the bill
to the Supreme Court, calling him a "thundering disgrace"(though it is suggested more colourful language was used), this precipitating the resignation of the President when Taoiseach Liam Cosgrave did not seek the Minister's resignation.
