A senior counsel representing 36 gardai, Mr John Rodgers SC, has withdrawn from the Barr Tribunal.
The Tribunal was informed that the withdrawal of Mr Rodgers was in protest at remarks made about him by the chairman, Mr Justice Robert Barr.
Solicitor for the gardai, Mr Tom Murphy, informed the Tribunal this afternoon that Mr Rodgers's position at the Tribunal was "untenable" in the wake of the remarks.
Mr Rodgers - a former Attorney General - did not address the Tribunal.
The comments in question were made in an exchange between Mr Murphy and Mr Justice Barr, in relation to an argument which occurred between Mr Rodgers and Mr Justice Barr yesterday.
Mr Justice Barr told Mr Murphy that Mr Rodgers had been "quite wrong" to interfere with Mr Justice Barr's cross-examination of Professor John Harbison.
"I was being bullied, and I am not a judge one should attempt to bully," Mr Justice Barr said.
The chairman went on to state that he hoped Mr Rodgers would not interfere in such a way in future. Mr Justice Barr said there was an "odd man out" at the Tribunal and that "I hope he might conform with the conduct of others".
Mr Murphy applied for, and was granted, an adjournment to allow his clients to consider their position.
Granting the adjournment until January 13th, Mr Justice Barr stated that "we will all reflect and that includes me."
The chairman conceded that "an element of impatience" was one of his "many" failings, but, that at the age of 73, "I am not going to change."
Today's sitting of the Tribunal was the last scheduled before the Christmas recess.