which the ESO was envisaged. In terms of the practical steps taken, the first UK ESO example involved an initial adjournment to allow the prosecution and the judge to consider the ESO, followed by a two week period during which the issuing UK authorities translated the documents and sent them to the Spanish authorities. The Order was sent through the Liaison Magistrates, there the authorities took over 21 days to consider its contents. The whole process took approx. 6-8 weeks in total. During this time the individual was held in custody. In the second example, also from the UK, the accused was granted bail in the UK pending a decision on the ESO. This initial bail application was made arising from the previous lengthy procedural delays experienced during the course of the first ESO application. In both cases, the objections to the ESO were grounded on the concern of a risk that the accused would not return for trial. On foot of granting the application for the ESO, the individuals were admitted to bail and permitted to return to Spain, with conditions including curfew, a specific residence requirement, reporting conditions to police of the local area. In addition there were conditions undertaking to maintain contact with the solicitor in the UK including a specific requirement notifying them of travel arrangements, and providing this information to the Crown Prosecution Service (CPS). The accused was also required to appear before Court on arrival to Spain to acknowledge the bond. In one of the cases there was a restriction, prohibiting the accused from entering Madrid where the complainant was Studying, and an additional security or bail payment in the sum of £5000. As a result of the ESO, both accused were able to continue with their employment and studies, and both returned to the UK for trial and as was required for, and the adjournments that took place from time to time. The case which centred around the rape allegation recently concluded, some 12months after the defendant was admitted to bail pursuant to the ESO. The individual was acquitted on all counts, and the presumption of innocence was given real meaning. In a parallel setting, without the ESO, that individual would have remained in custody, with all the challenges of a foreign in prison, for a year awaiting trial in a matter where he would subsequently be acquitted. Ireland In Ireland, an application was made before Dublin District Court in January 2015 for a Hungarian national charged with a criminal offence in Ireland, to return to Hungary pending trial on the basis that the applicant would return to Ireland for each court appearance but would reside in Hungary under the auspices of the ESO, where there were family connections and employment. The objections from the prosecution were based on the fact that Ireland had not yet implemented the Framework Decision. The applicant relied on the CJEU decision of Pupino223 and it was submitted that the State, by objecting to the application should not be permitted to benefit from the fruits of a failure to implement. The Court, while critical of the failure to implement the decision, felt however that its hands were tied by the fact that it had not been implemented. However, in the interest of justice, the Court amended the terms of the bail without a supervision requirement, to allow the applicant to return to Hungary and only to return to Ireland for each court appearance, which she duly did to the conclusion of the case. 223 In Pupino it was held that “the principle of conforming interpretation is binding in relation to framework decisions adopted in the context of Title VI of the Treaty on European Union. When applying national law, the national court that is called upon to interpret it must do so as far as possible in the light of the wording and purpose of the framework decision in order to attain the result which it pursues”. Case C-105/03 Criminal Proceedings against Maria Pupino [2005] para 43. 55