The Sunday Tribune has learned that, when O'Donoghue appears before the Court of Criminal Appeal on Thursday, his barristers will refer to the unprecedented publicity surrounding his case and argue that it will make continuing to live in Ireland an unrealistic prospect for their client once he is released.

Thursday's hearing will consider an appeal by the Director of Public Prosecutions against the "leniency" of O'Donoghue's four-year prison sentence.

It is also expected that comments made in court by Majella Holohan, Robert Holohan's mother, about Wayne O'Donoghue will be described as an "outrageous slur" and "groundless allegations" and that the three appeal court judges will be asked to take them into account when they adjudicate.

The three judges will also be asked to take into account the fact that the O'Donoghue case has been at the centre of a media frenzy that has made it one of the most high-profile cases in the history of the state.

The case was due to be heard earlier this month but an application by O'Donoghue's counsel to have it adjourned was granted to allow them time to consider an 18-page submission from the DPP .

The DPP has advanced six grounds to support the claim that the sentence is unduly lenient.

Among other things, it is argued that the sentence failed to take into account O'Donoghue's concealment both of the killing and of Robert Holohan's body.

However, it is understood that O'Donoghue's legal team will draw attention to the fact that judge Paul Carney had due regard to the coverup when he described it at as "appalling", and stated that there was "no excuse for it" and "no mitigation for it".

When Wayne O'Donoghue broke down in front of his father and admitted that he was responsible for the death of his 11-year-old neighbour, he handed himself into gardai.

During last year's manslaughter trial, Carney stated: "I am satisfied that from the point where the accused first confessed to his father, genuine remorse was in play".

It is understood that this may also be used in O'Donoghue's defence during this week's appeal hearing.