Finding a suitable definition for the ¿Administration of Justice¿ is something which has eluded the Irish Courts. The Zalewski decision does not provide such a definition¿in fact, it is noted in the decision that this would be impossible¿but it is the first decision in a long time to consider the meaning of the term in great detail, as well as the meaning and intent of Arts 34 and 37 of the Irish Constitution. The case sets an important precedent on the approach to be taken in assessing a body alleged to be unconstitutionally exercising the administration of justice and while the court is agreed on the approach to Art.34, the conclusions reached on the Art.37 ¿saver¿ remain open to question due to the lack of clarity in the majority judgment and the strength of the three dissenting judgments on this point. This article will examine the decision, looking in particular at the approach to the McDonald test, and will analyse the potential confusion which may result from the lack of precision around the Art.37 conclusion.