Referendum-emergent constitutional provisions pose particular challenges for international human rights law. Domestic law is primarily a matter for States, and its provisions do not and cannot excuse non-compliance with international obligations. However, when those domestic laws are not only in the national constitution but placed there by referendum of the People, clear questions of legitimacy arise in assessing their compliance with international obligations. Taking the case of A, B & C v. Ireland as its central focus, this chapter shows how such provisions raise questions for European consensus. It argues that, rather than guide the Court in its difficult and delicate task of evolving the Convention in respect of abortion, this case shows how European consensus can be a mechanism of avoiding making decisions on difficult questions and deferring to the ‘will of the People’ in domestic States, whether that is directly expressed through referendum or obliquely through primary legislation.