Capital punishment in the Republic of Ireland was abolished in statute law in 1990, having been abolished in 1964 for most offences including ordinary murder. The last to be executed was Michael Manning, hanged for murder in 1954. All subsequent death sentences, the last handed down in 1985, were commuted by the President, on the advice of the Government, to terms of imprisonment of up to 40 years. The Twenty-first Amendment of the constitution, passed by referendum in 2001, prohibits the reintroduction of the death penalty, even during a state of emergency or war. Capital punishment is also forbidden by several human rights treaties to which the state is a party.