If the Seanad had rejected or amended the bill, the Dáil would have had to be recalled from its summer recess to consider the Seanad's changes. A bill passed by both Houses of the Oireachtas is sent to the President of Ireland to be signed into law. There were suggestions that the Seanad might petition President Michael D. Higgins to call an ordinary referendum on the bill. Paschal Donohoe suggested Higgins might refer the bill to the Supreme Court under Article 26 of the Constitution, to test whether it is constitutional. The President is required to summon a meeting of the Council of State before any referral, and on 24 July he called such a meeting for 29 July. Of the 24 members of the Council, 21 attended. Of the three absentees, Mary Robinson and John Bruton both made written submissions; the third, Albert Reynolds, had Alzheimer's disease. A bill allowed by the Supreme Court under Article 26 can never subsequently have its constitutionality challenged in court. News reports suggested that, for this reason, most members of the Council advised the President not to refer the bill, to allow the Supreme Court to consider it in the light of specific future cases rather than abstract hypothetical cases. Higgins had until 31 July 2013 to either sign or refer the bill; in the event, he signed it on 30 July without referral. The bill was criticised by commentators on both sides of the Irish abortion debate, both for being too restrictive, and for not being restrictive enough. Jurist Gerry Whyte listed and critiqued five hypothetical grounds on which the Act could be argued to be unconstitutional: the lack of explicit time limits; the lack of an opt-out for institutions (as opposed to individuals) with conscience objections; the fact that a refused abortion can be appealed but an allowed abortion cannot; the lack of allowance for fatal fetal abnormality; and the possibility that the X-case judgment is not binding with regard to allowing suicide as grounds. The Irish Catholic Bishops' Conference wrote a series of pastoral letters condemning the bill. In May 2013, Fine Gael TD Tom Barry wrote to Cardinal Seán Brady and the nuncio, Charles John Brown, asking whether TDs would be excommunicated if they voted for the bill. Derek Keating's parish priest stopped him serving as minister of the Eucharist after he voted for the Act. Pro-Life commentators criticised the bill's lack of time limits. Breda O'Brien suggested doctors might induce labour of a borderline-viable fetus, resulting in permanent health problems associated with premature birth.