Margaret Delaney, of Clonlea House, Ballyogan Road in Stepaside, also told the inquiry that she never gave her consent for the demolition to the Railway Procurement Agency (RPA). "I would certainly have said no, I would have to fight it because of the family situation. We have worked so hard to get where we were with the house."

The family addressed the public inquiry into the extension of the Luas line from Sandyford to Cherrywood in south Dublin last Wednesday.

The RPA had told the inquiry earlier in the week that the family had accepted the need to demolish their home, something Delaney said she rejected "100%".

In her witness statement, Delaney outlined the importance of Clonlea House to herself and her husband, her children and mostly her brother John, who she said is moderately handicapped and would be incapable of coping with the move.

"The main reason why our home is unique to our special needs is the fact that John, my only sibling, lives there, " she said. They bought the house in 1992 and refurbished it completely to make it suitable for John, she said.

"At the present time, John is a very happy, content individual with a certain amount of independence, " Delaney said.

However, she added that routine is of the utmost importance to him and previous disruptions to that, such as the changing of his bus route, had caused him great distress.

Last summer, she said, changes in John's rehab routine, due to a one-week holiday, had resulted in him having a seizure that was later discovered to be a brain haemorrhage. He now has an aneurysm at the base of his skull. A specialist in Beaumont Hospital wanted to do some tests to see if anything can be done, but so great is John's fear of hospitals that such a visit may trigger another brain haemorrhage.

Delaney said John's medical and rehab files were available if verification was required and added: "In summary, John needs routine. Changes to his routine cause severe distress, which causes seizures, which in turn is quite likely to cause another brain haemorrhage which will threaten his life . . .

and that is not something a value can be placed on."

The family's legal representative, Eamon Galligan SC, contended that the environmental impact assessment the line failed to take into account alternative route options that would preserve the house. Conall Newman, a senior consultant at Simon Clear and Associates said no mitigation measures were proposed regarding Clonlea House and its survival. "The assumption or presumption that Clonlea House would be demolished due to the presence of a development plan road objective resulted in no attempt to suggest alternatives or to mitigate against the removal of a protected structure, " he said.

The hearing continues tomorrow.