As a result of the 1921 Anglo-Irish Treaty, the British courts were turned over to the Irish Free State. Count Plunkett requested a petition of "habeas corpus" for the detention without trial of his son, George (an anti-Treaty guerilla), in 1922 after the split between Irish nationalists over the treaty. The judge, Diarmuid Crowley, ordered the younger Plunkett's release; however, Crowley was arrested by the Free State government. The Dáil court system was shut down and declared illegal after this incident, although a commission was appointed to iron out the loose ends in open cases. The courts were officially abolished by the Dáil Éireann Courts (Winding Up) Act 1923.