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(LRC – CP14 –1999)






The Law Reform Commission

I.P.C. House, 35–39 Shelbourne Road, Ballsbridge, Dublin 4


© Copyright The Law Reform Commission 1999

First Published July 1999

ISSN 1393 – 3140




The Law Reform Commission is an independent statutory body whose main aim is to keep the law under review and to make practical proposals for its reform. It was established on 20th October, 1975, pursuant to section 3 of the Law Reform Commission Act, 1975.

The Commission's Programme for Law Reform, prepared in consultation with the Attorney General, was approved by the Government and copies were laid before both Houses of the Oireachtas in January, 1977. The Commission also works on matters which are referred to it on occasion by the Office of the Attorney General under the terms of the Act.

To date the Commission has published fifty-eight Reports containing proposals for reform of the law; eleven Working Papers; thirteen Consultation Papers; a number of specialised Papers for limited circulation; and twenty Reports in accordance with Section 6 of the 1975 Act. A full list of publications is contained in an Annex to this Consultation Paper.


The Law Reform Commission consists of a President, one full-time Commissioner and three part-time Commissioners. The Commissioners at present are:

President: The Hon. Mr Justice Vivian Lavan, High Court,

Full-time Commissioner: Mr Arthur F Plunkett, Barrister-at-Law,

Part-time Commissioners: Dr Hilary A Delany, B.L.,

Lecturer in Law, Trinity College, Dublin;

Ms Patricia T Rickard-Clarke, Solicitor,

Partner – McCann FitzGerald Solicitors;

The Right Hon. Dr Turlough O'Donnell, Q.C.

The Secretary to the Commission is John Quirke


Research Staff

Director of Research: (Professor). David Gwynn Morgan, LL.M (Lond.), Ph.D.(N.U.L);

Legal Researchers: Ms Lia O'Hegarty, B.C.L., LL.M. (Michigan), LL.M. (Harvard), Barrister-at-Law;

Ms Róisín Pillay, LL.B., LL.M (Cantab.), Barrister-at-Law;

Ms Leesha O'Driscoll, B.C.L., L.L.M. (European) Barrister-at-Law.

Legal Information Manager: Ms Helen Bradley, B.A., M.Phil., M.L.I.S

Library Assistant: Ms Marina Greer, B.A.

Clerical Staff

Ms Deborah McAdams, Private Secretary to the President;

Ms Lillian Jones.

Research Team on this Project

Ms. Róisín Pillay was the Researcher responsible for this project.

Contact Details

Further information can be obtained from:

The Secretary

The Law Reform Commission

I.P.C. House

35–39 Shelbourne Road


Dublin 4

Telephone: (01) 6377600

Fax No: (01) 6377601



The Commission wishes to record its thanks to the following people who have contributed to drafts of this consultation paper:

Mr Simon O'Leary, former Commissioner;

His Honour Judge John Buckley, former Commissioner;

Ms Rachael Hussey, former researcher;

Ms Cliona Kimber, former researcher.

The Commission would also like to thank the Office of the Parliamentary Draftsman, for their advice and assistance. Full responsibility for this paper lies with the Commission.


Background to the Consultation Paper


In 1976, the Law Reform Commission's First Programme for Law Reform, under the heading of Statute Law, proposed a review of the approach to interpretation of statutes, in the light of the more “flexible” approach adopted to statutory interpretation elsewhere. The Commission also made a separate proposal to examine the style in which legislation is drafted. The appropriate paragraphs from the Programme are worth quoting in full:

“Statute Law

16. For some time there has been an increasing interest in common law countries in the desirability of a more flexible rule for the interpretation and construction of statutes and for a departure from what is at present largely a purely literal interpretation. Since our membership of the European Communities involves us in a very close way in legal and other matters with countries that have a much more flexible approach to statutory interpretation than is the case in this country and since Community instruments and regulations will be interpreted by the standards and methods of the European Communities, it is desirable to re-examine this whole question in the context of our own legal system. It is to be noted that in the United States of America, which is a common law country, there is a much more flexible approach to the interpretation of statutes than exists here. However, “interpretation” covers not merely the general approach to the problem but also the question of what materials (written or other) outside the statute itself may legitimately be used for the purpose of ascertaining the intent of the legislature. Specifically, the Commission will examine the use of travaux preparatories and of commentaries by experts. They will also examine such canons of interpretation as the ejusdem generis rule and the rule (often known as the rule in Heydon's case) under which the court has to consider the law before the enactment of the statute, the defect or mischief in the law and the remedy adopted to cure that defect or mischief. These canons of interpretation will, of course, have to be considered not alone in the context of ordinary statutes but also in the context of codified law and of the International Conventions that become part of Irish law.

17. The Commission proposes to examine ways in which the present method and style of drafting statute law might be improved. It also proposes to examine the form of production and publication of statutes and of amendments to statutes, as well as the question of the consolidation of statute law.”


Two Interconnected Topics


It is difficult to deal with either of these paragraphs in the First Programme independently. The method and style of drafting statutes is, necessarily, influenced by the way statutes are interpreted by the courts. Statutory language cannot be simplified, without addressing the methods of interpretation which are a primary cause of its present complexity. Equally, the courts as interpreters depend on the drafters of legislation to give clear expression to the intentions of the legislature; and, for legislation to be clearly understood by those it affects, there must be predictable and consistent interpretation in the courts. One writer noted that:

“it is important to appreciate the mutual dependence of the drafter and the courts when the latter are engaged in statutory interpretation. It is the courts' duty to give effect to the intention of parliament, but their main source of information on this matter is the wording of the statute; if this is not clear there is obviously a risk that the courts will not be able to do their work properly. On the other hand the drafter will find it difficult to convey the Parliamentary intent to the courts unless he knows that they will attach the same meaning to his words as that in which he employs them.”


Given the close relationship between drafting and interpretation, the Commission has considered the two topics together in this Consultation Paper.

The Importance of Statute Law and Drafting


The provisional recommendations made, both in relation to drafting and to interpretation, have the objective of improving the comprehensibility of legislation and therefore its accessibility to the people it governs. The principle of the Rule of Law presupposes that those who are affected by a law should be able to ascertain its meaning and effect. A system of language and law understood by only a few, where only a few have the ability to make authoritative statements about what is and is not permitted under the law, cedes power to those few. Lord Simon of Glaisdale wrote:

“It is important to remember why our statutes should be framed in such a way as to be clearly comprehensible to those affected by them. It is an aspect of the Rule of Law. People who live under the Rule of Law are entitled to claim that the law should be intelligible. A society whose regulations are incomprehensible lives with the Rule of Lottery, not the Rule of Law.”1

Outline of this Consultation Paper


This paper begins by examining the current approach of the Irish courts to statutory interpretation, and to the use of extrinsic aids to interpretation, such as Dáil debates. Approaches to statutory interpretation in several other jurisdictions are then considered, with particular reference to jurisdictions which have enacted legislation prescribing a particular approach to statutory interpretation.


Lord Simon of Glaisdale, The Renton Report-Ten Years On, 1985 Stat. Law Rev. 133.



Chapter 2 of the paper examines the current form and style of Irish statutes, and considers some of the difficulties with Irish legislative drafting. Chapter 3 examines alternative drafting styles, in particular those advocated by the “plain language” movement.


A series of provisional recommendations for reform are put forward in Chapters 4 and 5. In regard to interpretation, the Commission's central recommendation is that there should be a new Interpretation Act, which would clarify the applicable rules of interpretation. The Act would prescribe a purposive interpretation of statutes, and would allow for the use of extrinsic aids to interpretation in some circumstances. In regard to statutory drafting, the Commission does not favour a radical move towards a “general principles” approach to drafting, but recommends a number of reforms in regard to the language, as well as the structure and format, of legislation, in order to enhance the readability of Acts. It is provisionally recommended that purpose clauses should be included at the head of each Act, replacing the current form of the long title. Recommendations are also made in relation to the amendment and consolidation of legislation.

The Consultation Process


This Consultation Paper is intended to form the basis of discussion and the recommendations in it are provisional only. The Commission will make its final recommendations on this topic following further consideration of the issues and consultation with interested parties. Submissions on the provisional recommendations included in this Consultation Paper are welcome. So that the Commission's Final Report may be made available as soon as possible, those who wish to do so are requested to make their submissions in writing to the Commission by 15 October 1999.





Approaches to Interpretation


Competing Literal and Purposive Approaches to Interpretation in the Irish courts


Two Distinct Approaches


The Influence of EU Jurisprudence: The Growing Importance of Teleological Interpretation


Maxims and Presumptions


The Importance of Context: The Noscitur a Sociis and Ejusdem Generis Rules


Acknowledging Particular Circumstances: Generalia Specialibus Non Derogant


Construing Words as Limiting: Expressio Unis est Exclusio Alterius


Presumption of Constitutionality


Presumption of Compatibility with European Law


Presumption of Compatibility with International Obligations


Presumption that all Laws bear a Meaning


Presumption that an Updated Construction should be Applied


Presumption that Penal and Revenue Statutes be Construed Strictly


Presumption Against Implicit Changes in the Law


Presumption against Retrospective Effect


Presumption against Extra-territorial Effect


Internal Aids to Construction


Use of the Long Title to an Act


Headings and Marginal Notes


The Wider Context: The Use of Extrinsic Aids to Construction


Construction of Related Statutes Together


Legislative History of a Provision


International Conventions and Associated Documents


Australia: Sections 15 AA and AB of The Acts Interpretation Act


Application of Section 15AA in the Courts


Application of Section 15AB in the Courts


Where there is no Ambiguity


Where the Legislation is Ambiguous


Use of Extrinsic Materials to Confirm the Literal Meaning


Relative Weight of Parliamentary Speeches




The Report of the English and Scottish Law Commissions


Report of the Hong Kong Law Reform Commission


Approach to Interpretation


Use of Extrinsic Materials in the Interpretation of Statutes




Introduction: The Evolution of Drafting Style


Supremacy of Parliament


Use Of Precedents and Models by Lawyers


The Power in The Written Word


The Language of Statutes


Why are Irish Statutes Difficult to Understand?


Amendment of Legislation


The Need for Updated Legislation


The Need for Uniformity


To Whom Should Legislation be Addressed?




Plain Language Or Plain English


Advantages and Disadvantages of the Plain Language Approach


(a) Concern that Plain Language will Lower Standards of Good Writing


(b) Concern For Intelligibility


(c) Concern that Plain Language can only be Achieved if Certainty is Sacrificed


(d) Plain Language will Lead to the Loss of Established Meanings of Words Settled over Centuries of Judicial Interpretation


(e) Costs of Plain Language are Prohibitive


Plain Language and Legislation in Some Other Jurisdictions


United Kingdom: Proposals for Law Reform




Codifying the Rules of Interpretation in a New Interpretation Act


Literal and Purposive Approaches to Interpretation




Ascertaining the Context of a Provision: the Use of Internal Aids to interpretation


The Use of External Aids to Interpretation


A General Principles Approach to Drafting




1. Familiar Vocabulary and Preference for Simplicity of Style


3. Changing the Grammatical Structure of Sentences


4. Splitting Subject and Verb


5. Active and Passive Voice


6. Omit Surplus Words


8. Cohesion Among/Between Sentences


9. Creation of Unnecessary Concepts


11. Technical Language


II. Structure And Format


4. Improved Use of Definitions


III. Aids To Understanding


2. Statements of Purpose and Long Titles


3. Use of Mathematical Formulae


IV Amendment and Consolidation




Structure and Format of Acts


Aids to Understanding


Amendment and Consolidation of Legislation







It is fair to say that the present style of drafting has developed because of the literal approach to interpretation adopted by the courts. Indeed, in the Renton Report on the Preparation of Legislation (1975)1 it is suggested that:

“unsatisfactory rules of interpretation may lead the drafters to an over-refinement in drafting at the cost of the general intelligibility of the law.”


What are these rules? The history of the common law is one of competing approaches to statutory interpretation, embodied in a series of rules which give expression to the shifting balance of powers between legislature and judiciary and attempt to preserve a delicate equilibrium between the two. The “literal” approach to statutory interpretation and the “purposive” approach, (closely related to the teleological or schematic approach) are the two often competing methods of interpretation which concern the courts today. The antecedents of the purposive approach may be seen to varying extents in the “mischief rule”2 and the “golden rule”3 developed by the English common law in previous centuries and still invoked by present-day courts. Today, it is most accurate to state that there is no single rule of literal or purposive interpretation, but that a principally literal approach is modified by a purposive approach, with an examination of the Act's purpose becoming more important if the Act is ambiguous or absurd.

Approaches to Interpretation

The Literal Rule


Preserving the separation of powers remains crucial to statutory interpretation. The Irish courts have been conscious of the need to clearly define and delimit their role in interpreting legislation, so as to avoid any implication that they are creating law and thereby usurping the role of the Oireachtas. The role of the courts is seen as best delimited by accepting the primacy of the text of the statute as enacted by the Oireachtas – by adopting a literal interpretation. The literal rule, in its purest form, has an inflexibility which places particular strain on the draftsperson, requiring language which expressly covers all eventualities. This extreme inflexibility can be seen in the words of Lord Esher MR in R v The Judge of the City of London Court4 where he stated that “[i]f the words of an Act are clear,


The Preparation of Legislation: Report of a Committee Appointed by the Lord President of the Council (London, 1975) Cmnd. 6053, at para. 19.1.


Heydon's case (1584) 3 Co Rep 7a.


Warbutton v Loveland (1828) 1 Hud & B 623; People (Attorney General) v McGlynn [1967]IR 232; DPP v Flannagan [1979] IR 265.


you must follow them, even though they lead to manifest absurdity. The Court has nothing to do with the question whether the Legislature has committed an absurdity.”


The literal approach is impractical and unhelpful to the drafter, in that it fails to acknowledge the limited capacity of language, even where there is no particular ambiguity, to assert a single indisputable meaning. Neither does it acknowledge the impossibility of the drafter's taking account of every possible factual situation which may arise under a statute, and catering expressly for each of these situations in a single statutory provision. If the drafter is to write comprehensively enough to anticipate the effect of literal interpretation, it is more than likely that clarity and brevity will be sacrificed.


In the Report of the English and Scottish Law Commissions on the Interpretation of Statutes, it was commented that:

“[t]o place undue emphasis on the literal meaning of the words of a provision is to assume an unattainable perfection in draftsmanship; it presupposes that the draftsmen can always choose words to describe the situations intended to be covered by the provision which will leave no room for a divergence of opinion as to their meaning.”5


It is now generally recognised that the literal approach must be tempered by at least some flexibility in order to avoid an application of a statutory provision by a court which would be absurd or unreasonable. In the case of McGrath v McDermott6 Finlay CJ set out a modified literal approach in relatively flexible terms when he said:

“The function of the courts in interpreting a statute of the Oireachtas is ... strictly confined to ascertaining the true meaning of each statutory provision, resorting in cases of doubt or ambiguity to a consideration of the purpose and intention of the legislature to be inferred from other provisions of the statute involved, or even of other statutes expressed to be construed with it. The courts have not got a function to add to or delete from express statutory provisions so as to achieve objectives which to the courts appear desirable.”7


The literal approach to interpretation is stated, also in flexible form, by Budd J in Rahill v Brady:8

“in the absence of some special technical or acquired meaning the language of a statute should be construed according to its ordinary meaning and in accordance with the rules of grammar. While the literal construction generally has prima facie preference, there is also a further rule that in seeking the true construction of a section of an Act the whole Act must be looked at in order to see what the objects and intention of the


Law Com No.21; Scot. Law Com. No. 11 (1969) at p.17.


legislature were; but the ordinary meaning of words should not be departed from unless adequate grounds can be found in the context in which the words are used to indicate that a literal interpretation would not give the real intention of the legislature.”9


Thus, for example, where there is ambiguity in the terms of a provision, the long title to the Act may be used to assist in the construction of the provision.10

The Golden Rule


The golden rule is still referred to by the courts today as a means of modifying stringent application of the literal rule.11 It was set out by Lord Blackburn in River Wear Commissioners v Adamson.12 The golden rule, he stated, enabled the courts:

“to take the whole statute together, and construe it all together, giving their words their ordinary significance, unless when so applied they produce an inconsistency, or an absurdity or inconvenience so great as to convince the court that the intention could not have been to use them in their ordinary significance, and to justify the court in putting on them some other signification, which, though less proper, is one which the court thinks the words will bear.”13


This is mirrored by the more lenient application of the literal approach to interpretation now favoured by the Irish courts, whereby a literal construction is replaced by a more purposive one in cases of doubt or ambiguity.

The Mischief Rule


The mischief rule, the oldest of the rules of interpretation, reflects a balance of the legislative and judicial powers which some consider renders it inapplicable today.14 It presumes a legal system in which legislative intervention in the common law is an exceptional occurrence, used only to address a “mischief” or “defect” in the common law. Though it may be expressed in outdated terms, however, the rule bears similarities to the purposive and schematic approaches to interpretation which have been developed by modern day courts. The mischief rule has been given legislative force in a number of common law jurisdictions15 and is still cited by the courts. The rule was recently referred to in the Irish High Court,


At p.86. See also the dicta of Henchy J in Minister for Industry and Commerce v Hales [1967] IR 50 at p.74. The view that the Act as a whole should be looked at in the interpretation of one provision is however doubted by McCarthy J in Texaco (Ireland) Ltd v Murphy [1991] 2 IR 449. See infra para. 1.019.


Minister for Industry and Commerce v Hales [1967] IR 50. But see Texaco (Ireland) v Murphy [1991] 2 IR 449


See Denham J in DPP (Ivers) v Murphy [1999] 1 ILRM 46 at p.58.


(1877) 2 Appeal Cas 743


English and Scottish Law Commissions, Report on Statutory Interpretation, 1969, para.33.


See infra, para. 1.151, para. 1.175, para. 1.184.


where Budd J identified the need to examine “the mischief sought to be addressed by the passing of An Blascaod Mór National Historic Park Act, 198916


The mischief rule was set out in Heydon's case,17 where it was held that four matters might be considered in the interpretation of statutes:



What was the common law before the making of an Act;


What was the mischief and defect for which the common law did not provide;


What was the remedy the parliament hath resolved and appointed to cure the disease of the commonwealth;


The true reason of the remedy.

And then the office of all the judges is always to make such construction as shall suppress the mischief, and advance the remedy and to suppress subtle inventions and evasions for continuance of the mischief, and pro privato commodo, and to add force and life to the cure and remedy, according to the true intent of the makers of the Act, pro bono publico

Competing Literal and Purposive Approaches to Interpretation in the Irish Courts


The competing literal and purposive approaches to the interpretation of legislation are set out most comprehensively in Inspector of Taxes v Kiernan18 and in Howard and others; Byrne and others v The Commissioners of Public Works in Ireland.19


In Kiernan, a case which turned on the meaning of the word “cattle”, the courts approach to interpretation was set out by Henchy J. He identified the first basic principle of statutory interpretation that words, where they were used in a statutory provision which was “directed to the public at large” should be given their ordinary or colloquial meaning.


Henchy J quoted Lord Esher M.R in Unwin v Hanson:20

“If the Act is directed to dealing with matter affecting everybody generally, the words used have the meaning attached to them in the common and ordinary use of language. If the Act is one passed with reference to a particular trade, business, or transaction, and words are used which everybody conversant with that trade, business, or transaction, knows and understands to have a particular meaning in it, then the words are to be construed as having that particular meaning, though it may differ from the common or ordinary meaning of the words.”


An Blascaod Mór Teoranta and Others v Commissioner of Public Works in Ireland, Unrep., July 1997


[1981] IR 117. See also the judgment of Barr J in PJ v JJ [1992] ILRM 273


[1891] 2 QB 115 at p.119



It is notable that Henchy J made the “ordinary meaning” rule dependent on context, and on the audience to which a statute is addressed. He made it clear that, if a statute was addressed to a particular class, to whom the words would have a distinct meaning, or amongst whom the words would be used as a term of art, the “ordinary meaning” rule would not apply.21


The second rule of statutory interpretation which Henchy J identified related to statutory provisions creating a penal or taxation liability. In such cases,

“the word should be construed strictly so as to prevent a fresh imposition of liability from being created unfairly by the use of oblique or slack language.”22


Third, Henchy J noted that, in identifying the ordinary or colloquial meaning of a word, the judge should look primarily not to dictionaries or other similar sources, but to his or her own experience of the word's use. Dictionaries should only be used if confusion was caused by, for example, alternative meanings or regional usages, or a change over time in the meaning of the word. In regard to the interpretation of “cattle” on which the case turned, he held:

“In regard to “cattle”, which is an ordinary and widely used word, one's impression is that in its modern usage the word, as it would fall from the lips of the man in the street, would be intended to mean and would be taken to mean no more than bovine animals. To the ordinary person, cattle, sheep and pigs are distinct forms of livestock.”23


Henchy J's approach was followed by McCarthy J in Texaco (Ireland) v Murphy24 where he reiterated the primacy of the “plain meaning” rule, stating that

“[w]hilst the Court must, if necessary, seek to identify the intent of the Legislature, the first rule of statutory construction remains that words be given their ordinary literal meaning.”E25

He went on to say that:

“[t]he legal principle appears clearly to be that if the claim for allowance falls within the express wording of the permitting section, it must be upheld. Arguments based upon the application or otherwise of other sections, proximate or not, appear to me to be unsound in law.”26


The literal approach adopted in Kiernan has not gone unchallenged. The decisions in the Byrne and Howard cases in both the High and Supreme Courts indicate that there is a clear division of opinion on interpretation in the Superior


See also Minister for Industry and Commerce v Pim Brothers Ltd [1966] IR 154 and Minister for Industry and Commerce v Hammond Metal Co Ltd [1947] Ir Jur Rep 59.


[1981] IR 117 at p.122


Courts. The cases concerned the building of interpretative centres at Luggala and Mullaghmore. The questions at issue were whether or not a state authority required planning permission under section 26 of the Local Government (Planning and Development) Act, 1963 and whether or not the existence of section 84 of that Act, which made special provision for a state authority consulting a planning authority before constructing or extending a building, was an indication that the legislature did not intend to place any further obligation on state authorities.


In his High Court judgment in the Byrne case,27 Lynch J. took a largely purposive approach to the interpretation of the 1963 Act, grounded, inter alia, on the following passage from the 4th edition of Halsbury:

“[s]tatutes must be so construed as to make them operative. If it is possible, the words of a statute must be construed so as to give them a sensible meaning. A statute must, if possible, be construed in the sense which makes it operative and does not defeat the manifest intentions of the legislature and nothing short of impossibility so to construe it should allow a Court to declare a statute unworkable. Thus where a statute has some meaning, even if it is obscure, or several meanings, even though there is little to choose between them, the Court must decide what meaning the statute is to bear rather than reject it as a nullity. It is not permissible to treat a statutory provision as void for mere uncertainty: however if the uncertainty cannot be resolved and the provision can be given no sensible or ascertainable meaning, it must be regarded as meaningless. Where the main object and intention of a statute are clear, it should not be reduced to a nullity by a literal following of language which may be due to want of skill or knowledge on the part of a draughtsman unless such language is intractable.”28


He interpreted section 84 of the 1963 Act accordingly:

“I am of the view that the intention of the legislature in enacting s.84 of the Act of 1963 was wholly to exempt the State authorities from the necessity of applying for planning permission under Part IV of that Act. Such authorities may carry out any development they wish without any reference whatsoever to the local planning authority, except where the development consists of or includes the construction or extension of a building, when they must consult with the local planning authority regarding such construction or extension but not any other aspect of their proposed development and even in the case of the construction or extension of a building, if it be in connection with afforestation by the State, they need not refer at all to the local planning authority in such a case.

The philosophy behind s.84 would appear to me to be that development by a State authority will not involve any element of private profit or gain. On the contrary, development by a State authority may be presumed to be for


4th ed. Vol.44, para.860 quoted at [1994] 1 IR 91 at p.97.


public purposes and for the common good. As the main object of requiring planning permission by other persons is to ensure that the proposed development does not conflict with the common good, it is logically unnecessary to require planning permission for development by a State authority.”29


In his High Court judgment on the same point, in the Howard case,30 Costello J. reached a different conclusion, adopting a literal construction of the section. He cited Maxwell on The Interpretation of Statutes,31 in favour of a “natural meaning” approach:

“It may be that the court will not agree that the words give rise to an absurdity; and even if they do give rise to an admittedly incongruous state of affairs, they may still be plain, in which case the court will have no option but to place on them their natural meaning.”32


Costello J found that the terms of section 84 were “clear and unambiguous.” He stated:

“[i]f the result is that State authorities must apply for permission in all cases under section 24 and consult in some cases under section 84, this is not such an absurd result as to require the court to construe from it legislative intent to exempt State authorities from the equally clear obligations imposed by section 24 and, in effect, re-write the section. Furthermore, I do not think that I should infer that the legislature intended by this section to create the claimed exemption when, for the reasons already given, I think there is a reasonable inference that no such intention existed.”33


Accordingly, a difference of opinion emerged between two of the most experienced judges of the High Court, between the respective editors of Maxwell and Halsbury and between a literal and purposive approach to the interpretation of statutes.


The Supreme Court divided on similar lines, a majority taking the literal approach adopted by Costello J. The Chief Justice adopted a narrow approach to the matters which could be considered by the Court, appearing to exclude from its consideration all questions of social policy:

“the Court is of course not in any way concerned with whether the application of the Planning Acts to the Commissioners is or is not politically or socially desirable; that is a question exclusively reserved under the separation of powers for the legislature.”34




[1994] 1 IR 101 at p.120.


At p. 125. This contrasts with the view of the English and Scottish Law Commissions, op cit. fn.



The Supreme Court decided, with particular reference to the decision in Byrne v Ireland35 that there was no presumption as to whether or not the requirements of the Planning Act, 1963 applied to State agencies. Applying the ordinary principles of interpretation to section 84 of the 1963 Act, the majority held that the State was not exempt from the provisions of the Act. Blayney J, with whom the Chief Justice agreed, refused to attribute an intention to the legislature which was not plain from the ordinary meaning of the words of the statute.36 The application of the Act could not be regarded as altered by implication, in the absence of any ambiguity in the meaning of sections 24 and 84. In fact, he found, the meaning of the section was plain. It was not open to the Court to interpret the section by “coming to a conclusion as to the intention of the legislature without that intention being expressed in the section itself.”37 The Court should not, he held, speculate as to the intent of the legislature.38


Blayney J appeared to accept that his approach could lead to the courts giving effect to “absurd” provisions. He noted the submission that it would be an absurd situation if the Commissioners had to comply with section 84 and also obtain planning permission, but held that:

“where, as here, the provisions of the sections are quite clear, the court is obliged to give effect to them even if the effect of doing so may not appear to be entirely reasonable.”39


He quoted the uncompromising view of Maxwell:

“Where, by the use of clear and unequivocal language capable of only one meaning, anything is enacted by the legislature, it must be enforced however harsh or absurd or contrary to common sense the result may be. The interpretation of a statute is not to be collected from any notions which may be entertained by the Court as to what is just and expedient: words are not to be construed, contrary to their meaning, as embracing or excluding cases merely because no good reason appears why they should not be embraced or excluded. The duty of the court is to expound the law as it stands, and to 'leave the remedy (if one be resolved upon) to others'.”40


14 at para.46, which stated that a judge was entitled to take judicial notice of information relating to legal social and economic aspects of the society in which the statute is to operate.


At p. 151, citing S G G EDGAR, CRAIES ON STATUTE LAW, (1971) (7th ed.) at p.65; and Maxwell, op cit. fn.31, at p.28. The approach of Blayney J was recently followed in the High Court by Geoghegan J in Hegarty and Horgan v the Labour Court, Unrep., 12 March 1999.


[1994] 1 IR 101 at p.153


ibid., citing Craies, op cit. fn.36, at p.66 which refers to Lord Watson's judgment in Salomon v. Salomon & Co. Ltd. (1887) A.C. 22, 38 where he said:

“'Intention of the legislature' is a common but very slippery phrase, which, popularly understood, may signify anything from intention embodied in positive enactment to speculative opinion as to what the legislature probably would have meant, although there has been an omission to enact it. In a court of law or equity, what the legislature intended to be done or not to be done can only be legitimately ascertained from what it has chosen to enact, either in express words or by reasonable and necessary implication.”


ibid. quoting Maxwell, op cit. fn.31, at p.29.



Blayney J was of the view, however, that it was questionable whether the provisions of section 84 which were at issue in the case did in fact give rise to an absurdity.


Denham J was also of the view that a literal approach should be adopted. She stated that:

“the correct conclusion to be drawn is that the plain language of the Act must not be extended beyond its natural meaning so as to supply omissions or remedy defects. The court should neither misconstrue words so as to amend defects in the legislation nor legislate to fill gaps left by the legislature. If there is a plain intention expressed by the words of a statute then the court should not speculate but rather construe the Act as enacted.

Applying the rules of interpretation of statutes, in accordance with the fundamental concepts of the Constitution, it would be improper to give a strained construction to the act of 1963. Dealing with the fundamental concepts, the balancing of rights and powers under the Constitution, the primary and literal approach to the construction of the statute is appropriate.”41


In contrast, O'Flaherty J expressed his agreement with the conclusions reached by Lynch J in the High Court, looking to the intention of the legislature and stating that it was inconceivable that section 84 would have been inserted into the Act of 1963 if it had been intended that State agencies would have to apply for planning permission.42

Two Distinct Approaches


The various High and Supreme Court judges who heard these cases can be divided between those who construe a statute in order to ascertain the intention of the legislature and those who construe a statute in strict accordance with its words and drafting. The latter give the ordinary meaning of the words used precedence over the actual intention of the legislature, while paying what can only be described as lip-service to the objective of following the intention of the legislature.


For example, whereas Lynch J. quotes para. 860 of Halsbury, which sets out the canon that, if possible, the words of a statute must be construed in the sense which makes it operative, Denham J. does not quote para. 860 but paras. 863 and 864 which set out the canons of “Primary Construction Without External Aids.”


It is interesting to note that these paragraphs in Halsbury are preceded by the setting out of “General Principles of Construction”, in paras. 855 to 858, which point to different approaches where statutes are “ambiguous” and “unambiguous”. The approach of the majority, as evidenced by the passages they quote, is to a statute which is unambiguous. The passage quoted by Judge Lynch related to


ambiguous provisions. Surely, the very presence of section 84 rendered the 1963 Act ambiguous in this area? Costello J was constrained to describe his conclusion as “not such an absurd result ...”, which appears to suggest that a lesser degree of absurdity might be acceptable. Blayney J acknowledged that the literal approach led to a conclusion which “may not appear to be entirely reasonable.” It seems, on these dicta, that a provision must be entirely or acutely absurd or unreasonable, in order for the purpose of the legislation to be considered.

DPP (Ivers) v Murphy


The recent Supreme Court ruling in DPP (Ivers) v Murphy43 suggests a move towards recognising ambiguity where a provision is absurd on its face – and therefore adopting a purposive approach in such circumstances. The judgment of Denham J (in which Barrington and Lynch JJ concurred) rejected a literal in favour of a purposive approach to the interpretation of section 6 of the Criminal Justice (Miscellaneous Provisions) Act, 1997. Denham J acknowledged the need to ensure that a purposive approach to interpretation did not affect the separation of powers. In adopting a purposive interpretation, she stated a proviso that:

I used to think of my early teenage addiction to the works of Agatha Christie as the literary equivalent of pool-hall prowess, the sign of a mis-spent youth. Looking back on it now, it seems clear that Enid Blyton was the gateway drug: the Famous Five and the Secret Seven gave me a craving that soon only Hercule Poirot and Miss Marple could satisfy.

Apart from the most famous plots, the details have long since faded, save the odd motive for murder (passing on German measles!); weird clues (Lo - Hen - Grin); and peculiar words (mountebanks and anti-macassars); but what still linger in the memory are the paranoid parsing of every paragraph for that tell-tale clue; the late nights when lights out had to be disobeyed as a denouement loomed; and the satisying frustration of being outwitted time and again by a master plotter. Part of the attraction undoubtedly was that Christie was as prolific as she was talented. No matter how many you read, there was always the assurance that there were plenty more.

But where does Agatha Christie’s reputation stand today? Is she still relevant, given the current appetite for gritty realism and bloody gore? Do her books still hold up as great mystery fiction? Or is she still read more for nostalgia than anything else? To mark today’s 125th anniversary of Agatha Christie’s birth, I asked contemporary crime writers to contribute their thoughts on her work. Was she an influence, even if only as someone to react against? Were or are they still a fan and, if so, which is their favourite of her books, and why?

Val McDermid

When it comes to the best Christie, as opposed to the most popular, my vote still goes to The Murder at the Vicarage, the novel that introduces the estimable Miss Marple. Written at the height of Christie’s powers, it’s perfectly constructed, packed with red herrings and smart sub-plots; it’s shot through with sly humour; and it’s full of characters who may be stereotypical but whose motivations and responses we recognise, often with a wry smile.

It’s possible I may be biased in my assessment, for it was The Murder at the Vicarage that made me a crime writer. As a child, I spent a lot of time in my grandparents’ house. I would always arrive with an armful of library books but more often than not, I would run out of reading material. My grandparents were not readers; they had a Bible, of course, but inexplicably, they also had a battered paperback of The Murder at the Vicarage.

Linguistic scientists tell us that a reading age of nine is sufficient to comprehend Christie, and I was a precocious reader. From the age of seven or so, The Murder at the Vicarage became my default reading, the pages I returned to when I’d finished my library stockpile. I fell in love with the complicated intersecting narratives, the recognisable claustrophobia of village life – even in a Scottish mining village, there were parallels – and the cleverness of Jane Marple herself.

When I realised that Agatha Christie had written more than one book, it became my mission to work my way through all of them. I haunted jumble sales, I discovered secondhand bookshops, I stole my mother’s library card so I could access the adult shelves. That was where it dawned on me that there were other writers who wrote detective stories. (I worked it out from the famous logo of the Collins Crime Club – a masked skull brandishing a pistol.) And I was enthralled.

We sometimes hear of cross-species adoption where orphaned animals bond with a very different creature and take on the characteristics of the adoptive animal. I think something similar happened to me with Agatha Christie. I read The Murder at the Vicarage so frequently that embedded within my brain is the notion that grown-up books have to have dead bodies in them.

The stakes are higher when it’s a matter of life and death: the adrenaline surge we get as readers is stronger. There are moments in this novel where we feel both pity and a genuine frisson of fear. Christie is often criticised for her cardboard characters and there’s some truth in that, particularly in the later work. But when she’s at her best, as she is in The Murder at the Vicarage, her characterisation is pointed, economical and often sharply satirical.

Here’s how we’re introduced to our heroine: “I … sat down between Miss Marple and Miss Wetherby. Miss Marple is a white-haired old lady with a gentle, appealing manner. Miss Wetherby is a mixture of vinegar and gush. Miss Marple is much the more dangerous.” And a few lines later, we meet Miss Hartnell who is “weatherbeaten and jolly and much dreaded by the poor”.

We can see these people, hear them and know them. For a writer starting out, that ability to nail people in a line or two was a valuable lesson to learn. The plotting too, obviously. Those interwoven story arcs, each with a set-up, development and pay-off (often an unexpected one) taught me much of what I know about the black art of narrative. It’s no exaggeration to say that The Murder at the Vicarage set me on a path I’ve been happy to follow for 30 years.

Nobody turns a plot with more skill than Christie. When I was starting out as a crime novelist, I learned a lot by unpicking her plots to see exactly how she made them work. She understood completely the arc of set-up, development and pay-off that seems to elude a lot of other writers. She was clever, cunning and original.

There is still a massive audience for so-called ‘cosy’ crime. Looks at the success of series like Midsomer Murders. The dark end of the spectrum gets most of the attention, but there are still a lot of writers who eschew violence and gore and still treat murder like a bloodless parlour game. Particularly in America, where their sleuths include cats, dogs, dry cleaners and caterers.

I think there are a dozen or so novels where she was absolutely at the peak of her powers – The Murder of Roger Ackroyd, Murder on the Orient Express, And Then There Were None, The Murder at the Vicarage, Five Little Pigs, for example – that remain satisfying and will genuinely surprise the reader. She’s a lot better at character in those books than she’s often given credit for. She is very economical but effective with her characterisation and we recognise those people as being drawn from life.

Val McDermid’s latest novel is Splinter the Silence, published by Little, Brown

Sophie Hannah

My favourite Agatha Christie novel, After the Funeral, has a brilliant plot, meticulously planted clues, a memorably dysfunctional family at its centre, and a truly ingenious solution, but it also has something else that I prize highly: the non-transferable motive. Poirot is forever telling Hastings that motive is the most important feature of a crime, and I agree with him. A non-transferable motive is something that no other murderer in no other crime novel has ever had or would ever have – a motive that is unique to this character in this particular fictional situation. With a non-transferable motive, the reader should ideally think, ‘Well, although I would never commit murder for this reason, I can absolutely understand why this character did – it makes perfect sense because of their unique personality/predicament combination.’ On this score, After the Funeral works in the most superb way. It also does something else very clever on the motive front – it offers us a two-layer motive of the following sort: ‘X committed the murder(s) for reason Y. Ah, but why did X have reason Y as a motivation? Because of reason Z.’

I was hooked on the keenly balanced structure and fiendish puzzles in Agatha Christie’s work from the age of 12, in part because she manages to dig beneath the surface of appearances. This is what good fiction does: it enlarges our views of what is possible, rather than reflecting the world of appearances. Agatha Christie’s work has been a conscious and, no doubt, unconscious influence on my own crime fiction. I ended up being asked to write a continuation Poirot novel that became The Monogram Murders largely by accident, but I think I hold dear to the same sort of thinking that lay behind Agatha Christie’s storytelling. It’s necessary to answer the question of ‘who killed x?’ but this isn’t sufficient. The real mysterious hook in crime fiction is not so much whodunnit, but ‘how on earth can the apparently inexplicable be explained?’

Sophie Hannah wrote an Agatha Christie continuation Poirot novel, The Monogram Murders, which was published last September in 34 different languages and a bestseller in 20 countries.

Declan Hughes

Along with Arthur Conan Doyle, Agatha Christie was the first grown-up author I read. I can still remember the thrill of fear I felt, aged 11, when the serial killer is revealed at the end of Murder is Easy. Sparkling Cyanide, Why Didn’t They Ask Evans, I must have read a dozen or more (the beautiful Fontana covers were part of the attraction). The point being, I read her as a child; when I began to read in earnest, aged about 16, she belonged to the childish things I was keen to put away. Set against the landscapes of corruption charted by the socially and politically aware American hardboiled trinity of Hammett, Chandler and Macdonald, Christie’s genteel village mysteries seemed indeed like child’s play.

And that was how I thought, or how I stopped thinking about her, until a few years ago. Increasingly, women were writing the most interesting crime writing; less well-known female voices from the past were being rediscovered. Chandler said Hammett took murder out of the rose garden and dropped it in the alley where it belonged. Why not reread the most famous female crime writer of them all, and see if there was more going on in that rose garden than I remembered?

And there was. Not just the brilliant plotting, for which she is justly renowned. The books are concise, economically written and, at their best, deftly and subtly characterised. She has a taste for the Gothic and an ability to portray evil suddenly and convincingly; as a result, she is often a genuinely frightening writer. She may lack the big social picture, but if part of a crime writer’s remit is to provide a gloss on “Lead us not into temptation”, then Christie portrays the act of murder as transgression with searing force and often, an unexpected sympathy.

The best Christies for me are mostly those without one of her famous detectives. Endless Night, Crooked House, Murder is Easy (the end is still terrifying) and, of course, And Then There Were None all stand up very well; Endless Night in particular has a haunted, Gothic quality redolent of Daphne Du Maurier. A Murder is Announced is the best of the Miss Marples. The Hollow is another Christie in the Du Maurier vein: an intense, heightened Gothic melodrama for its first half, and then Hercule Poirot wanders on, a cartoon character in a human world, and reality is compromised. Poirot is never entirely believable, but he’s worth putting up with for one of Christie’s very best books, Five Little Pigs, and for Death on the Nile, Evil Under the Sun, Sad Cypress and Taken at the Flood. That’s my top ten; Robert Barnard’s A Talent to Deceive is probably the best critical work about her.

Declan Hughes is the author of the Ed Loy series. His latest book is All The Things You Are (Severn House).

John Banville

When I was a boy, back around the close of the Stone Age, I was an avid reader of the novels of Agatha Christie. Nowadays I am with Edmund Wilson, the title of whose 1945 New Yorker essay, Who Cares Who Killed Roger Ackroyd?, expresses my feelings exactly. I say ‘novels’, but I am not sure that is what these books are. They more resemble crossword puzzles, and finishing one of them, like finishing a puzzle, leaves one with the same ashen sense of futility and wasted time.

Christie is certainly a kind of genius, but one cannot help feeling she would have been better off employed in Bletchley Park as a code-breaker, or working for a manufacturer of board games. Her plots, while highly ingenious, are also wildly improbable, if for no other reason than that the characters who drive them are not characters at all, but marionettes, jerking lifelessly on the ends of their all too visible strings. Her worst fault, however, is that we never feel the slightest twitch of sympathy for, or empathy with, the victim, lying there in the library in a neat puddle of blood. Who could possibly care?

John Banville, writing as Benjamin Black, is the creator of the bestselling Quirke series of crime novels.

Linwood Barclay

The first Agatha Christie novel I ever picked up – and I would have been around 12 years old at the time – was The Man in the Brown Suit. It was a Pan paperback edition, and I still recall the feel of it in my hands, how pliable it was, not that book flexibility is a major factor in deciding which novel to read. But this was a book for adults, not one of those mini-hardcover Hardy Boys or Tom Swift novels I’d been devouring up until then. This was a novel about grown-ups, committing real, grown-up crimes.

While The Man in the Brown Suit may not be one of the author’s classics, that didn’t stop me from racing through it and, once finished, looking for more Christie. I discovered Miss Marple and Hercule Poirot (his eccentricities were a nice lead-in for my next discovery, the Nero Wolfe novels by Rex Stout) and locked rooms and bodies in libraries. And Then There Were None (the edition I read was, ahem, Ten Little Indians) blew my mind. Murder on the Orient Express thrilled me. The ABC Murders captivated me.

What fun.

And that’s what Agatha Christie was. Fun. She was a superb entertainer. Many writers since have taken the conventions of the mystery genre and done more with them – Ross Macdonald immediately comes to mind – by working in social commentary and psychological insights.

But who established most of those conventions? Christie was the Steve Jobs of plot twists. She invented dozens of them. Case in point: When a character dies – at sea, plunging off a cliff, in a plane crash – and you don’t actually view that corpse, well, chances are you’ve not seen the last of that character.

Does Christie still hold up today? Does it matter? All of us who write crime fiction owe her as great a debt as we do the inventor of the printing press.

Linwood Barclay’s latest novel is Broken Promise

Liz Nugent

I first came across Agatha Christie on bookshelves at home when I was about 14 years old. I’m pretty sure they belonged to my grandmother. I read and re-read the four or five tattered copies. They were all Miss Marple mysteries, and because of Granny’s connection to the books, I somehow imagined that she was leading this secret life as an amateur detective. St Mary Mead, the fictional setting for the books, was actually Skibbereen and the rector was the parish priest. When I finally saw Margaret Rutherford, and later, Joan Hickson in the role on television, I decided that the casting directors had got it all wrong. Granny was much taller than Hickson, and slimmer than Rutherford.

Agatha Christie is the undoubted Mistress of the genre. The culprit was usually revealed by process of elimination, but I quickly learned that the person who seemed the most innocent would prove to be the miscreant. Miss Marple and Monsieur Poirot took great pleasure in outwitting the local constabulary. But I feel now that these books were of their time, and class (a bit like Granny). Like Enid Byton, Christie did not hide her distaste for foreigners and ‘ruffians’. Still, I found a quote from her today, which stops me in my tracks. Agatha Christie was well-travelled. Syria was, she said: “a gentle fertile country and its simple people, who know how to laugh and how to enjoy life; who are idle and gay, and who have dignity, good manners, and a great sense of humour, and to whom death is not terrible.”

Liz Nugent is the author of Unravelling Oliver, winner of the Bord Gais Energy Irish Book Awards Crime Novel of the Year 2014. It has been translated into nine languages. Her second novel, Lying in Wait, will be published by Penguin in June 2016.

Sinéad Crowley

I first made her acquaintance at my aunt’s house in Kerry. My cousin had a superb Christie collection and, while my days were spent in Knockalougha, my evenings were spent visiting English country homes, posh London flats and even the Middle East. I was captivated.

Christie’s books provided the perfect bridge from the junior to the senior side of the library, containing many of the elements I loved in my favourite children’s books; a complicated plot, heroes and villains, a resolution – although not necessarily an uncomplicated one – and of course, the twist. To me, the ‘reveal’ is the beating heart of the crime novel and I still seek out books that will genuinely take me by surprise.

She remains influential. In the past couple of weeks alone, I’ve read two crime novels, Linwood Barclay’s Broken Promises and Andrea Carter’s Death at Whitewater Church, both of which are set in small towns, with an amateur sleuth at the centre of the action. And, where my own books are concerned, if readers tell me they didn’t guess the end, I’m happy.

It’s hard to pick a favourite Christie but I’m going to go for a Poirot, Death on the Nile. The plot is terrific, the setting superb and the solution ingenious. It also, as it happens, inspired one of the few Christie film/TV adaptations that I actually like. Most of them annoy me when they play up the ‘cosiness’ of her settings to the detriment of what can be quite vicious stories – these are murder mysteries after all! But I have a soft spot for Ustinov’s Poirot on a rainy day.

It’s 95 years since Christie’s first Poirot was published and I’ve no doubt she’ll be widely read in its centenary year, and beyond. To paraphrase Miss Marple, ‘human nature’ hasn’t changed.

Sinéad Crowley is Arts and Media Correspondent with RTÉ News. Her new book, Are You Watching Me?, the second in the DS Claire Boyle series, was published by Quercus in July

John Curran

Christie’s greatest achievement is the little-discussed Five Little Pigs, in which Poirot re-opens a case of murder committed 16 years previously. Thus, his investigation depends on interpretation of character and psychology rather than physical clues. Given the right – ie the wrong – circumstances any one of the five suspects (the ‘little pigs’ of the title) could have murdered the philandering artist Amyas Crale. But which of them did?

This is Christie’s most successful marriage of detective novel and ‘straight’ novel. Under Poirot’s careful questioning five fully realised characters re-create the fatal day 16 years earlier when they were all witnesses to murder; and one of them was a killer. The book has the added interest of using Agatha Christie’s own Greenway House and garden, in Devon, as its setting. Devoted readers can now visit the Battery Garden where Amyas died and Elsa posed and Caroline visited; and where Poirot triumphs.

Christie has lasted almost 100 years and outlasted many developments in crime fiction, so there is no reason to suppose that she will ever go out of style. As long as people enjoy crosswords, jigsaws, word games, Sudoku, bridge they will read Christie‘s detective stories because they are, in essence, literary conjuring tricks and she is the ultimate conjuror.

Yes, certainly, her books invoke nostalgia for an era long past, a time perceived as civilised and elegant. But nostalgia alone does not make for world-breaking records. She still tantalises with one of the oldest questions in fiction: Whodunnit? No one ever came – or, indeed, will come – close to her for plot manipulation and mis-direction or for solving the most complex-seeming puzzle with a simple solution. She will always be the Queen of Crime.

John Curran is the author of Agatha Christie’s Secret Notebooks: Fifty Years of Mysteries in the Making and Tom Adams Uncovered: The Art of Agatha Christie and Beyond

Yrsa Sigurdardottir

Agatha Christie was my introduction to the world of crime fiction as a teenager. At the time I could not get enough of her books and remember being truly devastated when I had read all that was on offer, knowing more were not to come. Although I have not revisited her works in many, many years they still hold a special place in my heart as well as admiration for the author. Her contribution to crime fiction influenced the genre in such a momentous way in its infancy that she really laid the foundation for all that has followed. From her heyday until the present crime fiction has developed and changed, something that is unavoidable and necessary as evolution is the very basis of keeping an art form relevant and alive. Her books are therefore not to all present-day crime readers’ liking or preference; now that gore, realism, political criticism and social commentary have entered the frame. A hundred years from now the form will have adapted further and contemporary crime fiction will no longer be as relevant as now. This is inevitable and nothing to get upset about but one thing is for sure, most if not all contemporary crime writers would consider themselves lucky if their books are still in publication almost a century after they were written as is the case with Agatha Christie. There can be no doubt that her best works can be classified as great mystery fiction as a result. The votes are already in.

My favourite books of hers were the Crooked House and Endless Night, probably because of the highly surprising yet satisfying ending.

Yrsa Sigurdardottir’s novels include Ashes to Dust and I Remember You.

Laura Wilson

Agatha Christie was a fixture of the wider landscape of my childhood, like the Queen and the shipping forecast on the radio and a whole lot of other things that I didn’t question, or ascribe qualities to, because they were just there, permanent and immutable. Christie’s detective novels were some of the first ‘grown-up’ books I read. Initially, it didn’t occur to me to try and work out who the murderer might be. I just enjoyed being bamboozled, safe in the knowledge that Hercule Poirot or Miss Marple would light on the right man or woman, which, at a period when I was beginning to realise the extent to which life is neither just or fair, I found comforting – and, no matter how many Agatha Christies you read, there would always be another one waiting at the library. I didn’t appreciate, until much later on, quite how ingenious they were.

My favourite is Five Little Pigs. I think it has a claim to be considered the best of Christie’s novels – the characters have an unusual (for this author) degree of emotional depth, and she uses the time-lag (the murder has taken place in the past, and the people involved are recalling the events that led up to it for Hercule Poirot) to explore the nature of memory and how our personal concerns may lead us to misinterpret what we see and hear. In retrospect, I think that the dramatic tension created between the characters ‘then’ and the characters ‘now’ probably did have a bearing on my first novel, A Little Death, which deals, in part, with life-changing events that happened in the past.

As to whether Christie’s novels are still relevant – relevant to what, exactly? Social mores may change, but human nature doesn’t, and a fundamental part of human nature is the desire for escapism and the enjoyment of a good story.

Laura Wilson’s latest novel is The Wrong Girl (Quercus)

Michael Stanley

Agatha Christie is often thought of as the archetypical British mystery writer. People who don’t know much about her life, but read a lot of her stories, probably imagine her as a retiring, genteel, middle-class lady pecking away on a typewriter. They know from the film Agatha that she once vanished and holed up in Harrogate – and why she did that and what she did there remains a mystery, but not much else.

In fact, she was an adventurous traveller. In the early 1920s she undertook a year-long trip with her husband Archie, as part of a team to promote the Empire Exhibition. She learnt to surf in Cape Town, subsequently honing her skills in Hawaii, learning to surf standing up – apparently one of the first Brits to do that. She spent time in Egypt, and later with her archaeologist second husband, in Iraq. She also spent time in the Canary Islands, which some years ago held a festival in her honour.

So Christie loved the sun and the sea, and no doubt her curiosity about foreign people and places fuelled her fiction. But what of her settings? Indeed, most of her stories take place in England, but some of the most famous ones have exotic locations – Murder on the Orient Express, Death on the Nile, They Came to Baghdad. However, it seems that Agatha Christie’s only connection with southern Africa was her surfing visit to Cape Town, never setting any of her stories in this part of the world. More’s the pity.

Michael Stanley is the writing team of Michael Sears and Stanley Trollip who write the Detective Kubu crime fiction novels set in Botswana. Their latest books, Deadly Harvest and A Death in the Family, will be released by Orenda Books in the UK as ebooks this year, and in paper next year.

Ruth Downie

Agatha Christie’s books were the reason I never imagined I’d end up as a crime writer. How can you write murder mysteries yourself if you can never work out who did it before Hercule Poirot explains?

It was a long time before I realised that some crime fiction has almost no mystery at all, and that while books may be read from beginning to end, they don’t have to be written that way. When your plot collapses in a hopeless tangle you can go back and sort it out – pausing briefly to reflect that the Queen of Crime would never have got into this mess in the first place.

Christie’s books are far more than plot, though. Her shrewd observation and economy of style are a delight. What more do we need to know of Miss Hartnell in The Murder at the Vicarage, except that she is “weather-beaten and jolly and much dreaded by the poor”?

In an age where crime fiction offers full-frontal autopsy, serial-killer paedophiles and detectives with as many problems as the criminals, there’s still a demand for the gentler world of Christie’s novels.

Our local library delivers books to housebound people. Many of those people live alone, read in bed and don’t want to be frightened out of their wits in the middle of the night (although one or two find it’s a marvellous way to pass the time). For those of us choosing the books, Agatha Christie is a godsend while we wait to gauge the level of grittiness required by a client who ticked the box marked “Mysteries”. Christie’s books are intelligently written, entertaining, and in the case of Miss Marple, celebrate the wisdom of the older woman. All of which is most welcome.

Ruth Downie’s latest novel is Tabula Rasa, the sixth in her series featuring Roman Legionary Medic Ruso and his British partner Tilla. The seventh, Vita Brevis, will be published by Bloomsbury in the spring.

Joseph Finder

It surprises me when people refer to Agatha Christie as a “cosy” writer, and I assume that anyone who shrugs her off as a lightweight has not actually read her. It is easy to focus on the ingenuity of her plot twists, but for me her lasting power is in her ruthless depiction of human nature.

Crime fiction, as a genre, is an extended attempt to explain to ourselves why people do bad things. Christie accepted from the beginning that sometimes people just do, and that perhaps figuring out “why” is not the most important consideration. We read traditional crime fiction because the restoration of order is so deeply satisfying. Agatha Christie may not have been the first author to develop that formulation, but she perfected it – and arguably, 100 years later, no one has done it better.

If I have to pick a favourite, I’ll go with Five Little Pigs, known in the US as Murder in Retrospect (1942). It’s an example of Poirot in his prime, and illustrates my point perfectly. The murderer Poirot exposes may well go unpunished, but the revelation of truth is enough for both him and his client. The punishment of the guilty is less important than the redemption of the innocent. The guilty, Miss Christie implies, are all around us. The innocents, comparatively rare, are the ones who deserve a happy ending.

Joseph Finder is the bestselling author of 12 novels, most recently The Fixer

Dror A Mishani

To me, Agatha Christie’s novels (or some of them) not just hold up today, but pose quite a few challenges to contemporary crime writers. Unlike their common image, as mere intellectual puzzles, I find in her novels deep reflection on the genre, its form and its philosophical and moral worldview.

It’s true that we tend to write more “realistic” crime novels today, and this development in the genre’s history produced and is still producing great literary works. But at the same time it brought the genre closer to all mainstream canonical realistic fiction (the difference in form and literary texture between a Mankell novel and a McEwan novel is not that great), and made us forget, in a way, how experimental, how Modernist in fact, was the literary text that was the puzzle novel in the 1920s and 1930s, a text of which Christie was probably the most important author.

Christie was the author of literary texts that didn’t exist before that. Texts that you wrote and read differently than any other, texts whose fundamental trait was suspicion: suspicion of every word you’re reading, of every sign given in the text. They were texts deeply obsessed with the fluctuation of meanings, that didn’t cease to question the possibility of having an authority over meaning, texts full of false-bottoms, in which what you saw was always hiding some deeper sense. This text of extreme suspicion was a fascinating literary experiment, and for me it’s one of the finest examples of Modernist poetics, just like the literary experiments of Dadaism or Sigmund Freud’s prose (If, for Freud, a cigar is never just a cigar, for Christie a cocoa cup is never a cocoa cup).

In addition, Christie is the best example of the worldview the genre laid out and promoted in those years: everybody, no matter how nice they seem, are potential murderers; If you’re in a room full of what seem to be innocent people you’ll soon discover that at least one of them is a killer and that the rest are guilty of something else (and maybe they’re all killers). This genre’s worldview is, to my mind, a philosophy that most contemporary crime writers inherited, sometimes without even knowing it, and I think that one of the challenges and even moral missions of crime writers today is to try and deconstruct this pessimistic worldview lying under the “cosy” detective novel.

Most of Christie’s novels are very much aware of their philosophical subtext and in fact can be also read as self-reflective and suspicious of the genre itself, its form and its ideology. But the clearest example for that, and my favourite novel of hers, is without doubt Curtain, Poirot’s last case, a novel Christie wrote in the 1940s but asked that it be published only after her death, as if knowing that it was a kind of “black box” of the whole genre, in which the detective (and the reader’s) constant suspicion is described not just as interpretative skill helpful in solving crimes, but also as a possible delusion, capable of inciting crimes, or as a crime in itself.

I like Curtain also because it’s closest to our contemporary understanding of what a good crime novel should be: its realism is stronger and Poirot is a fuller character than he is in all of her other novels, a touching character, practically on his deathbed, fluctuating between delusion and clairvoyance. I think it’s still one of the most shocking and daring crime novels written and I think every aspiring crime writer should read it before he starts his first novel, at least once, in order to understand how complicated and truly dark the genre he’s about to auusme is.

Arlene Hunt

It’s hard to explain how slavishly devoted I was to reading as a semi-feral youth. Books were my friends, my companions, my retreat from the world at large; on any given day I could be found, curled up, legs resting over the back of my dog Pharaoh with my nose buried within the pages of The Famous Five, The Secret Seven or Huck Finn. Many a wet afternoon spent sifting through the countless tattered copies of ‘True Crime’ that littered our home, their gore-filled tabloid covers far removed from anything my grandmother declared – loudly – as ‘proper’ (she read the Ireland’s Own magazine).

Despite my early love of mysteries and crime fiction, I do not believe I picked Agatha Christie to read; rather I stumbled upon her by chance. Books arrived at our home in plastic bags, second and sometimes third hand, a potluck of literature so to speak. From one of these deliveries I plucked, The Mysterious Affair at Styles. This was the first Agatha Christie book I ever read, and as luck would have it, it was my introduction to the great Belgian detective, Hercule Poirot.

I fell in love immediately with this strange precise mercurial being. I admired his astounding abilities to understand the human condition from the comfort of an armchair. Suddenly my life was infinitely richer. Cycling around the village of Redcross, I looked at the homes with renewed interest. Like Poirot, I tried to use my ‘little grey cells’ to fathom what lay behind the net curtains and closed doors. I now understood that each home could contain murder, mystery and certainly treachery, for how could they not? According to Poirot nothing was ever as it first seemed. I created elaborate stories and invented the most unspeakable acts of horror.

Fortunately, for everyone, I kept them to myself.

Poirot appeared in 33 novels and 65 short stories. Years later, Agatha’s creation was brought spectacularly to life on television by David Suchet, who embodied the role of the diminutive moustached genius utterly.

So thank you Agatha Christie, thank you from the bottom of my crime-fiction loving heart for such a man as Poirot.

Arlene Hunt is the author of eight crime-fiction novels, the latest of which is The Outsider (2013). She lives and works in Dublin

Megan Abbott

Agatha Christie was one of the first “grown-up” novelists I ever read. I am guessing I was 10 or 11 and my experience with mysteries had been limited to Nancy Drew and Encyclopedia Brown, but I’d always been curious about the Christie paperbacks on my parents’ shelves and I’d been told my first name had been plucked from one. So, my mom (now a crime novelist herself) handed me The Mysterious Affair at Styles and it began. I swallowed them whole, and even swore to my parents that I’d figured out the twist in The Murder of Roger Ackroyd before the shocker of an ending. My favorites were And Then There Were None and Murder on the Orient Express, the latter of which gave me exciting nightmares. I remember distinctly how sophisticated I felt reading them. These were not only books shelved in the big room at the library, they were books I could talk with my parents about. I felt like I’d entered the adult world and it was a place of treachery and dark deeds – but also, ultimately, a place where resolutions could be had, even a return to order. And even though, as a writer, I may opt for less certain resolutions (and less order), I learned so much about story from these books. And even more about the relationship between writer and reader, and how much trust is involved.

I have no excuse for not returning to Christie in the many years since. A long romance, begun in my teen years, with the American hardboiled distracted me, led me to my big loves, James Ellroy to Raymond Chandler, and the dirty charms of crime novels over whodunnits. But I do know this: as much as Chandler speaks volumes about a dark strain of midcentury America, Christie offers us invaluable insight into England between the wars and after. And as a woman who writes about crime and still gets asked, endlessly, about the “maleness” of the genre, I treasure that I can point to Christie and say: There she is, the master.

Megan Abbott is the Edgar-winning author of seven novels, including The End of Everything, Dare Me, and The Fever. Her next novel, You Will Know Me, comes out in July 2016.

Declan Burke

I could have picked any of a half-dozen titles for my favourite Agatha Christie novel, but Murder in Mesopotamia was the one I re-read – any excuse – for the sake of this piece.

The story is narrated by Amy Leatheran, who is employed by archaeologist Dr Leidner to nurse his wife Mrs Leidner, who ‘has fancies’ – ie, she fears for her life – on the Tell Yarimjah dig where her husband and his associates are excavating ‘a big Assyrian city like Nineveh’. When Mrs Leidner is discovered murdered, and the authorities are called in to investigate, Miss Leatheran is at first amused and then impressed by a certain Hercule Poirot, who just so happens to be travelling through Mesopotamia – even if he is so physically uninspiring that he pales by comparison with her favourite fictional detective, Sherlock Holmes.

The story was inspired by Agatha Christie’s own experience over two decades of digging at various sites dotted around the Middle East (she met her second husband, the archaeologist Max Mallowan, on one of the digs), but the wealth of detail is only one of the novel’s pleasures. Despite the exotic setting, this is a delicious example of the ‘country house’ mystery beloved of the Golden Age of British crime fiction, with a number of suspects, a surfeit of motives and the proverbial shoal of red herrings. It’s also an ingenious riff on the locked-room mystery, although its strongest suit is the psychological aspect – this is a case, Poirot tells Miss Leatheran, that he can only solve once he fully understands the complex psychology of the victim.

Some of Mrs Leidner’s personal history beggars belief, it’s true, but for the most part Murder in Mesopotamia is the very best of Agatha Christie’s oeuvre wrapped up in a concise and economical 220 pages. As for Poirot: he took off for England directly after, Miss Leatheran tells us, taking the Orient Express home – but that, as they say, is a story for another day.

Declan Burke’s latest novel is The Lost and the Blind. He is also the author of Down These Green Streets: Irish Crime Writing in the Twenty-First Century and, with John Connolly, of Books to Die For.

Ian Campbell Ross

Few books remain as powerfully present to the imagination as those first read in childhood. My first Christie was Sad Cypress. I was 11 years old. Stretched out on my bed, I firmly resisted my mother’s suggestion I go out to play until (the murderer safely unmasked) I could close the book. The Collins Crime Club hardback, with its yellow ochre on petrol blue dust-jacket, was a gift from my mother to my father. The plot . . .. But the plot is irrelevant, even if Christie remains the most accomplished plotter in all detective fiction, defying her reader to skip a word. Sad Cypress introduced me to Hercule Poirot, Christie’s counterpart to earlier Great Detectives: Poe’s C Auguste Dupin and Conan Doyle’s Sherlock Holmes. And it wasn’t long before I caught up with Christie’s second great creation: Miss Marple, whose success as a detective comes from the very fact that, as an elderly spinster, she is so frequently overlooked. There are better Christie novels, perhaps, and others that have more completely caught the playful imaginations of such intellectual admirers as Umberto Eco, Michel Houellebecq or Pierre Bayard. Crime fiction today is generally grittier, dirtier than Christie’s but I retain particular affection for Sad Cypress, whose closed, tidy, unreal world first allowed me to glimpse the possibility that detective fiction might not serve to reflect the messiness of life but, as Borges put it, to safeguard order in an era of disorder.

Ian Campbell Ross taught Ireland’s first university course in detective fiction at Trinity College Dublin; he recently co-edited the special number of Éire-Ireland: Irish Crime since 1921 (2014).

Jane Casey

Agatha Christie was the first ‘grown-up’ author I read, which possibly explains a lot. We had old paperback editions with photographic covers. Murder in Mesopotamia had a lumpy mask on the front with a black leering gash for a mouth, and it haunted me. I don’t ever remember finding the content disturbing, though, maybe because Christie focused on how the crimes were committed and who was responsible, not on how the victims suffered – or why. In Christie’s world, corpses are neat and motivations are clear-cut. People kill for money, for love, out of envy or frustration, not because of childhood trauma or for sexual satisfaction. Her detectives are amateurs, wise beyond words, as implacable as the Fates and never wrong. Good is good, evil is evil and absolutely anyone could be a killer.

Everything she wrote – and she wrote a lot – demonstrates her talent for misdirection, her ingenuity and her intelligence. I have many favourites but I loved Evil Under the Sun, which features a tremendously clever fake alibi, and Sparkling Cyanide. The smell of almonds still makes me edgy.

Christie is widely acknowledged as the queen of Golden Age crime, but the stories hold up remarkably well, even if some of the minor characters are as thin as the paper they’re printed on. She had laundry marks and sharp-eyed garage attendants where we have DNA and CCTV, but the thrill of the chase is the same.

Jane Casey is an award-winning Irish crime writer. Her most recent books are After the Fire, the sixth in the Maeve Kerrigan series, and Hide and Seek (for teenagers).

Ragnar Jonasson

I recently re-read Agatha Christie’s first novel, written almost a century ago, and it was breathtakingly good. She was a fully-formed, world-class mystery writer right from the start and authors like her don’t come along very often. I’m sure there are not very many crime novels from the 1920s that have stood the test of time as well as Christie’s best books from that decade, The Murder of Roger Ackroyd, Murder on the Links or The Mysterious Affair at Styles, the first two of which are actually among my all-time favourite Christie books. I discovered Agatha Christie’s books at the age of 12 and read every single Icelandic translation, even though I had to spend my Saturday mornings at the Icelandic National Library to read the out-of-print ones. When I had read all I could find in Icelandic, at 17, I started translating her books for her Icelandic publisher. And now, in my thirties, I’m still as big a fan as ever and regularly re-read her books. She has been a great influence on me, and probably on most other crime writers in one way or another. Her plots are so superb and surprising, yet simple when explained, and it has been said that she has used every single original idea for a twist at the end. (Annoyingly for other crime writers, that’s probably true!) She was also the master of creating a setting and atmosphere, be it the Orient Express, the Nile, a small English village, a mysterious island or a snowbound manor house. The fact that her books are still being read all over the world and that new television series based on her works are being created regularly shows us that she is as relevant as ever, and still the undisputed Queen of Crime.

Ragnar Jonasson is author of Snowblind (translated by Quentin Bates), Orenda Books

Gunnar Staalesen

When I, as a young reader, discovered Agatha Christie, through my parents’ bookshelves, I was so fascinated by her mysteries that during the years up till I was in my twenties, I think I must have read most of her books, many of them in Norwegian translation but later on in the original version, too. I was always impressed by her plotting, the way she crafted her intrigue, and the inevitable surprise ending! I enjoy Miss Marple, but one of my favourite detectives through all times is Hercule Poirot – clever (using his ‘small, grey cells’ to search out the guilty parties, and amusingly unsympathetic!

When I wrote my first detective novel in 1975, I was clearly influenced by the Swedish writers Sjöwall & Wahlöö, as well as the American trinity Hammett, Chandler and Ross Macdonald, but in plotting I have very often looked to Christie. I reckon that she and Macdonald are some of the very best plotters in the whole of 20th-century crime fiction. I remember clearly writing the book using a Christie template: several suspicious characters, all with a reason to kill, but most of them with an alibi …

Whichis the best Christie book ofthem all? My lecturer in English literature at the University of Bergen, mystery novelist Robert Barnard, was an expert in Agatha Christie, and he called Five Little Pigs ‘the best Christie of them all’. He knew what he was talking about. Murder on the Orient Express is of course a masterpiece, too, as is And Then There Were None. In many of her books, it’s easy to forget ‘whodunnit’ and get as much pleasure re-reading them years later. In others, however, such as Murder on the Orient Express and And Then There Were None, it is impossible to forget.

As a crime writer, I have looked more closely at Ross Macdonald when I have studied how to plot a crime novel, but I was very happy when I could finish one my Varg Veum novels, still not translated into English, Bitter Flowers, with what I called a ‘Poirot ending’. In the final chapter, my private detective confronted four people in a living room, and only one of them is guilty …

I imagine that one can find some Christie influence even in my latest book published in English, We Shall Inherit the Wind. The truth is that I, like most crime writers, can’t resist the temptation to put a little Christie into our work.

Gunnar Staalesen is author of We Shall Inherit the Wind (translated by Don Bartlett), Orenda Books

Adrian McKinty

Agatha Christie’s reputation as a writer of ‘cosy’ mysteries is unfortunate. It is, I think, largely a byproduct of the numerous BBC adaptations of her work set in the postwar England of retired squadron leaders, glamorous widows and intelligent spinsters. Who wouldn’t like to flit through the nostalgic world of perfectly lit Cotswolds villages and beautifully restored steam locomotives?

My experience of Christie was different from the get-go. The first book I read at the age of 11 was Murder on the Orient Express, which, if you’ll recall, is one where everyone did it. A train from Istanbul to Paris is caught in a snowstorm and a decidedly dodgy American traveller, Mr Rathchett, is killed. Hercule Poirot uncovers the fact that he is a notorious kidnapper and child murderer who escaped justice stateside. Everyone in Poirot’s carriage had a reason to get revenge on Ratchett. What I liked about the book was the cynical ending. Poirot proposes two solutions to the Yugoslavian police detective, Bouc. The first is that a stranger boarded the train and killed Ratchett, the second that it was a revenge conspiracy. Bouc knows what really happened but decides to accept the first solution.

This was the first book I’d read where the murderers got away with it and it wasn’t the first or last time Christie pulled this trick. Christie is a lot darker and a lot more interesting than the sepia-toned BBC versions would have you believe.

Adrian McKinty is the author of the Sean Duffy series, the latest of which is Gun Street Girl.

Aly Monroe

My mathematician father used to describe Agatha Christie’s novels as ‘the best literary Sudoku around, at her best as good as a Rubik Cube’. This wasn’t a put-down. He believed Christie worked her own chosen small square of ivory as expertly and imaginatively as Jane Austen had hers.

I tend to agree. Nobody goes to Christie for fine writing or convincing love stories or penetrating psychological insight into the characters described. Within the genre, however, Christie could work ingenious and imaginative twists that surprise. In part this is because her style is rarely other than serviceable but mostly because the turns remain genuinely clever in upsetting expectations.

Anthony Shaffer’s play Sleuth appeared in 1970 before Christie died and included a witty scene to mock the far-fetched ingenuity that had come to characterise the traditional country house murder – in the play a character necessarily combines the skill of a ballet dancer and the strength of a weightlifter to tiptoe along a line in a tennis court and then toss a dead body into the areas that will show footprints.

Christie was better than that because her psychological insight was into her readers’ grasp of reality and observation when facing puzzles – and the attractions of a certain abstract quality. My father liked her famous stories like The Murder of Roger Ackroyd and Then There Were None precisely because they were puzzles, the figures or characters were moved about and a solution calculated. In her best work the solution completely upset the traditions of traditional mysteries. Forget the lack of social commentary – Agatha Christie loved to disconcert.

Since her death, her limitations have turned out to be her strength. My own favourite of her novels is Curtain, Hercules Poirot’s last case, written during the Blitz but not published until shortly before her death. It has lasted well, better than more direct efforts at elegiac comment of that grim time. In a country house she invokes Jacobean theatre instead, unsettling views on the power of suggestion and relentless logic and pressure towards an evil choice being the only one available. Her puzzles work because she has her foundation secure. She remains one of the Great Enjoyables.

Aly Monroe, author of the Peter Cotton series, is finishing a stand-alone novel, The Lure, about a female cryptographer in 1964

Barbara Nadel

I am always torn between Murder on the Orient Express and Murder in Mesopotamia. I prefer the mysteries set abroad, probably because I sometimes found it difficult to relate to Christie’s England. Through a foreign prism it seems more understandable somehow. I guess I’d have to say Murder on the Orient Express if pushed – mainly because I have always loved the notion of intrigue aboard a train.

Was Christie an influence on my work? Indirectly inasmuch as my mother read copious amounts of crime fiction, including Christie, when I was a child. We had a houseful of books which I was actively encouraged to read. I took my cue from my mother and read a lot of crime from a very young age. But I never wanted to emulate Agatha Christie. What she taught me however was that women could write crime very well.

Is she still relevant? I think so. Whatever one may think of Christie’s books they are well written, absorbing and extremely entertaining. They also represent a time, known in crime fiction circles as the Golden Age. This was when people like Christie – namely Dorothy L Sayers and Josephine Tey – were also creating memorable and iconic detective fiction scenarios and characters of their own. In large part Agatha Christie and her contemporaries crafted the crime fiction genre that we know today. And, if for no other reason, that will mean that her work will always be relevant.

Do her books still hold up as great mystery fiction or are they read more for the sake of nostalgia? What I think marks Christie’s books out is the fact that she created a whole other world that, in many ways, is a lot safer and more appealing than our own. Only later on in her career did things like nuclear bombs come into being. Agatha Christie came way, way before the horrors of 9/11 and the current spate of conflicts in the Middle East that impinge upon us all. So nostalgia for a gentler age is a factor. But her plots are good – she loved plotting apparently – and they still work and remain entertaining. More importantly, time spent in Christie’s world is exciting and fun. What more could one want?

Barbara Nadel’s latest book is Enough Rope (Quercus), the fourth in my London-based Hakim and Arnold series.

Brian McGilloway

My first encounter with Christie wasn’t through her books, strangely, but rather through the film adaptations which we watched as a family on Bank Holiday afternoons when I was young. Peter Ustinov as Poirot in Death on the Nile still sticks in my mind. These were the first crime films I saw and the idea that someone could solve crime using only their intellect was fascinating. The books became, in many ways, gateways into darker crime fiction. So, while my influences now are mostly American, Christie’s work was the starting point for my love for crime fiction. And irrespective of her direct influence on writers now, there is no doubt that so many of the tropes of the genre which modern writers use and attempt to subvert, were established by Christie. Like Wilkie Collins, she explored the idea that crime could happen among the upper classes as easily as the working ones and, as with Collins’ Cuff, she understood the importance of the central detective; particularly one whom others underestimate. The fads for blood and guts and serial killers ebb and flow over time, but the centrality of a fascinating character at the heart in crime fiction will never change. In that regard, Christie will always hold her place amongst the royalty of crime writing.

Brian McGilloway’s new novel, Preserve the Dead, is available now.

Karen Sullivan, publisher at Orenda Books


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