In a submission to the government on a redress scheme, Harding Clark predicts that fewer than 200 women will be eligible for the scheme, with payments ranging between 60,000 and 380,000 depending on age, number of children and the nature of the medical procedure involved.

"The ex gratia offer of redress so calculated is intended to take into account all injury, loss and damage suffered by the applicant, " Harding Clark notes in correspondence which is being considered by the government.

Some 27m would be allocated for direct compensation payments with another 4m for legal and administration costs.

As recommended by Harding Clark, the redress board would have three part-time members, one of whom would be a judge or leading barrister. She has suggested that the board operate from the same offices in Dublin as her original inquiry into the maternity unit at Our Lady of Lourdes Hospital in Drogheda.

Harding Clark has also recommended that the redress board scheme is not contentious and that the women involved should not require legal representation, although they should not be prevented from seeking legal advice.

A maximum sum of 10,000, on top of any compensation award, would be paid to cover legal and medical fees incurred in making an application to the redress board.

Some of the 30m-plus costs would be recouped. Documents outlining how the redress scheme would operate note that the insurers of the previous and current owners of the hospital could provide 6m in return for a indemnity against any further claims.

Harding Clark has also sought a contribution of 8m from the Medical Defence Union in relation to its members who worked at the hospital. However, the judge notes that she is "not hopeful of any contribution" while the MDU is involved in existing litigation relating to indemnifying several of its members. The documents also state that the religious organisation that ran the hospital may contribute 1.5m.

The compensation payments will be calculated on the basis of a points system recommended by Harding Clark.

The women involved will be allocated points based on their age and number of children when the unnecessary operation took place, as well as the nature of the medical procedure undertaken. There will be higher points for younger women and those with fewer children.

The document gives the example of a patient who was aged 28 with four children (including her new baby) at the time of the unnecessary hysterectomy. This woman would receive 140,000 in compensation. In another example, a 36-year old woman with no children before having a hysterectomy at the time of the birth of her first child would receive 160,000 in compensation. In a sample analysis based on information on 81 women available to the Harding Clark inquiry, 67 would received above 100,000, 13 above 200,000 and one above 300,000. No appeal system will be included.

Harding Clark's original report, which was published earlier this year, was critical of both Neary and management practices at the Drogheda hospital. "This is not a simple story of a surgeon with poor surgical skills or a doctor deficient in academic excellence. . . It is a story of a committed doctor with a misplaced sense of confidence in his own ability, " the report stated.

Neary was struck off the medical register for professional misconduct in September 2002. The Clark inquiry conducted 320 interviews with 380 witnesses. It found that 180 peripartum hysterectomies . . . removal of a woman's womb within six weeks of delivery . . . were carried out at Drogheda over 25 years, of which 129 were attributed to Neary. Most obstetricians carry out between two and 10 peripartum hysterectomies in their career.

"It was difficult to fathom, therefore, how one obstetrician could carry out nearly 130 hysterectomies over 25 years without questions being asked, " the report noted.

Some 40% of Neary's peripartum hysterectomies were on women having their first or second child. The report concluded that "the numbers are truly shocking". These women will now qualify for the highest levels of compensation under the new redress scheme.