The Irish Free State came into existence in December 1922 as a dominion within the British Commonwealth of Nations. John O'Byrne was the sole King's Counsel (KC) appointed after independence, in June 1924 when he was Attorney General of Ireland. Shortly after the Courts of Justice Act 1924 came into effect, Chief Justice Hugh Kennedy, in conjunction with the Bar Council of Ireland, revived the issue of patents of precedence, which had been used in the 18th and 19th century as an alternative to a patent as KC, but had fallen into disuse from 1883 as the strictures formerly associated with the rank of KC were abolished. The Free State patent wording was based on that issued to Daniel O'Connell; the recipient would be styled "Senior Counsel" (SC) (). According to the view held at the time, the "privilege of patent" was part of the royal prerogative within the Free State. The early patents were issued under by the Governor-General as the King's representative, on the advice of the Executive Council (government). On 14 July 1924 the Chief Justice called the first recipients to the "within the bar" and bestowed their patents. The form of the 1924 patent omitted the appointment as "one of our counsel learned in the law" from the KC patent, but retained its grant of "precedence and preaudience" to rank next after the previously appointed KC or SC. The Constitution (Amendment No. 27) Act 1936 abolished the office of Governor-General and the Executive Powers (Consequential Provisions) Act 1937 was held to have transferred the royal prerogative to the Executive Council (government). Although the 1937 Constitution of Ireland created the office of President of Ireland, it was still the Taoiseach as head of government who signed patents of precedence under the Executive Powers (Consequential Provisions) Act 1937.