Over the longer haul, the significance of Murray J’s majority judgment in Tomás Heneghan v Minister for Housing will likely be more for what it says about how judges are to approach the interpretation of the Irish Constitution than for the changes it demanded would be made to the electoral franchise in respect of the six “University seats” in the Seanad. Murray J emphasises the fundamental importance of “context” and “purpose” in constitutional interpretation. The wording of this or that provision may on the face of it appear to be unambiguous, and to have crystal clear implications. (Say a provision having to do with the composition of a particular institution, or a provision comprising words denoting numbers, places or identified persons). But there is “no case,” says Murray J, “and no provision – no matter how clear it may be – in which it is other than appropriate to understand and have regard to the overall context in which that provision was adopted.” And he prefers the “harmonious” and, we suggest, “spirit-based” approach to constitutional interpretation – as Henchy J had in his dissenting judgment in People (DPP) v O’Shea (i.e. where O’Higgins CJ, in a majority judgment in that case, had insisted that “plain words…must be given their plain meaning…”). Indeed, Murray J could hardly have been more emphatic on the point: “…I do not believe that Henchy J’s analysis can or should now be seriously questioned as the authoritative explanation of how a court should view any issue of interpretation by any Article of the Constitution.”