The High Court is also considering further contempt proceedings against Mr Burke and his family.
The High Court will decide next Tuesday if Enoch Burke is to be sent back to prison.
The former school teacher was absent from a hearing yesterday because he was once again at Wilson's Hospital School in Westmeath, according to the Irish Independent.
His presence there directly breaches an injunction restraining him from going to the school.
Mr Justice Brian Cregan is also considering bringing further contempt proceedings against Mr Burke, and his family for their conduct in the courtroom last week.
Mr Burke was suspended from Wilson's Hospital School and dismissed six months later after a protracted dispute over a request to use student's chosen pronouns and new name.
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