A number of victims of Brendan Smyth are to take legal action against the Gardaí, after it emerged they were aware of his activities in the early 1970's.
Northern Ireland's Historical Institutional Abuse Inquiry heard on Wednesday that Gardaí were made aware of the paedophile priest's abuse of children in 1974.
Human Rights Lawyer Kevin Winters is expected to write to the Garda Commissioner Noirin O'Sullivan, asking why the information was not acted upon.
Meanwhile Cardinal Seán Brady who gave evidence to the inquiry on Thursday said internal church inquiries into child abuse took place under a "shroud of secrecy" to "save the church from scandal".
The former head of the Catholic Church in Ireland admitted it was a "dark chapter in the Church's history."