The Mahon tribunal today issued a warning to members of the public attending the proceedings to refrain from "laughing loudly, clapping or jeering" during the cross-examination of witnesses.
Judge Alan Mahon said he was "increasingly concerned" by the conduct of certain members of the public gallery.
He said although members of the public were welcome to attend the tribunal they must conduct themselves in a manner befitting a court.
The public gallery burst into applause several times during property developer Mr Tom Gilmartin's evidence on Tuesday.
Judge Mahon said if disturbances continued the tribunal would be forced "to take steps", warning the capacity of the public gallery may have to be reduced to maintain order.
A member of the Garda today attended the proceedings to ensure order in the public gallery.
