The Constitution of Ireland of 1937 provides that "Titles of nobility shall not be conferred by the State" (Article 40.2.1°) and "No title of nobility or of honour may be accepted by any citizen except with the prior approval of the Government" (Article 40.2.2°). Legal experts are divided on whether this clause prohibits the awarding of membership of the Order of St Patrick to Irish citizens, but some suggest that the phrase "titles of nobility" implies hereditary peerages and other noble titles, not lifetime honours such as knighthoods.