The report into the resignation of Martin Callinan as Garda Commissioner has been delayed indefinitely.
Former Supreme Court justice Nial Fennelly says he cannot proceed with his report because of the Ian Bailey case.
Mr Bailey is currently suing the Gardaí for wrongful arrest in connection with the death of Sophie Toscan du Plantier.
In a letter to the Taoiseach, Justice Fennelly says that case is "inextricably linked" to the secret Garda recordings which caused Mr Callinan to resign.
As a result, the interim report into Mr Callinan's departure will be delayed until Mr Bailey's court action has finished.