In common law jurisdictions the father, by what is called the principle of "paternal supremacy", has the right to decide the religious upbringing of all the children of the marriage. At first, this held also in the Republic of Ireland, even if he had entered into a contrary agreement in writing. The Supreme Court of Ireland still upheld paternal supremacy in 1945 in a judgement that the children, whose father had died, should be kept in a Protestant orphanage rather than be placed in the charge of the Catholic mother. It attributed no force to the signed promises that the father had made before the marriage nor to the argument that the 1937 Constitution of Ireland, adopted eight years earlier, declared that "the State recognises the Family as the natural primary and fundamental unit group of Society", and that it "acknowledges that the primary and natural educator of the child is the Family". Largely because this judgement ignored the promises made in the prenuptial agreement, it caused deep resentment in Catholic circles.