Nóirín O’Sullivan may be called back to the Disclosures Tribunal after new documentation was received by counsel for Maurice McCabe.
The Tribunal has heard that an internal garda review referred to Maurice McCabe as a "paranoiac who had lost control of his station".
Counsel for Sgt McCabe said his client had never seen the Byrne McGinn report, and was furnished with an extract yesterday.
Michael McDowell asked how it was that "he had seen the back" of former Garda Commissioner, Nóirín O’Sullivan, considering this new evidence.
Chairman Peter Charleton said he would consider asking the former Commissioner back if it was required.