IT is difficult - but not impossible - in other European jurisdictions to prosecute negligent civil servants.
In Britain, all government departments and agencies are generally protected from criminal prosecution by Crown immunity.
A spokeswoman for the British Director of Public Prosecutions said individual employees of government departments would be prosecuted if they committed a criminal offence outside work, but within terms of their employment, they are normally protected by Crown immunity.
The public can sue the government departments or agencies, but not an individual employee. A spokeswoman for the British Department of Health said if the hepatitis C scandal had happened in Britain, the only option for the victims would be to sue the National Blood Authority.
She added that in 1992, the government paid £80 million in compensation to people infected with HIV from blood transfusions, to prevent the need for litigation.
In Germany, officials guilty of negligence are usually subjected to internal disciplinary procedures and, in the most serious cases, removed from their posts. Criminal prosecutions are rare.
The closest German parallel to Ireland's hepatitis C scandal was the discovery in 1993 that two private medical firms had sold HIV infected blood to hospitals, causing the death of at least two people. One company, which had mixed blood from a number of donors to cut costs, was closed down and four employees jailed for up to four years.
Two senior figures in the Federal Health Administration were sacked on account of the scandal, but despite abundant evidence of negligence by the health authorities, no officials were prosecuted.
In France, scandals involving blood tainted with the HIV virus and growth hormones carrying, Creutzfeldt Jakob Disease (CJD) have ruined the careers of two dozen French health officials, two of whom have served prison sentences. In both scandals, medical personnel placed a higher priority on saving money than on the lives of their patients.
The French contaminated blood scandal broke in 1990, when it was learned that five years earlier, officials had knowingly distributed HIV tainted blood. Four doctors were tried for "fraudulent vending". Three were convicted and two served prison sentences. Mr Michel Garetta, the former director of the French National Blood Transfusion Centre, was sentenced to four years in prison, but was freed in May 1995 after serving 30 months.
Some 1,300 people were infected with AIDS and more than 500 have died as a result of decisions taken by Mr Garetta and his colleagues. Another 15 officials are under investigation in the blood scandal.
France's chief prosecutor recommended that charges against three former government ministers in the HIV tainted blood case be dropped for lack of evidence; all three had been charged with complicity to poison. The prosecutor said the justice system cannot be the arbiter of political responsibility.
In another scandal, pharmacy officials distributed growth hormones contaminated with CJD between 1984 and 1986. More than 42 children poisoned by the hormones have died of CJD. The former director of the Central Hospitals Pharmacy was charged with poisoning; a deputy was charged with manslaughter and poisoning.
In Italy, when a person dies in unnatural circumstances, a criminal investigation is held. A recent example is the investigation into the January train crash in Piacenza, in which eight people died.
That inquiry divides along two lines - human error or technical fault. If the preliminary inquiry concludes the crash was caused by human error, there will be no further legal action, since both drivers died in the crash. If, on the other hand, the inquiry concludes the crash was caused by a technical error, then those people with overall responsibility for the maintenance of the railway line, the design of the train and the train maintenance, may all be charged with manslaughter.
A highly controversial example of the Italian legal system's understanding of the term "overall responsibility" comes from the trial in relation to the death of the Formula One driver, Ayrton Senna, in a crash at the 1994 San Marino Grand Prix while driving for the Williams team.
Charged with "culpable homicide" (manslaughter) are the two senior figures in the Williams team, two track officials and the Formula One race director on the day of the crash. They could face sentences of up to five years, but the trial is widely expected to end in either acquittal or a suspended sentence.
Recent sentences issued to persons "in authority" include those imposed on former prime ministers, Bettino Craxi and Arnaldo Forlani, in relation to illegal party financing. Although they argued they knew nothing of the funds coming into their parties, the courts ruled against them, arguing that they had been guilty of personal corruption.