The High Court has heard that Ian Bailey is still a person of interest in the investigation into the murder of Sophie Toscan Du Plantier in west Cork in 1996.
Retired Garda John Wilson is under cross examination in Mr Bailey's case against An Garda Síochána and the State for wrongful arrest.
Mr Wilson has said Mr Bailey and his partner were subjected to an unacceptable level of surveillance up to two years ago.
Counsel for the State Luan Ó Braonáin put it to Mr Wilson that Mr Bailey remains a person of interest in the murder investigation.
He said just because the DPP directed no prosecution on the information available at the time, it does not mean the investigation should stop.
Mr Ó Braonáin said 23 entries on the Pulse system were made about Mr Bailey in 2001 when there was a review of the case going on.
In the same year Mr Bailey had been arrested for assault on his partner Jules Thomas.
He said in 2001 "there was a lot going on and a lot to record".
Mr Wilson said he did not suggest the investigation should stop after a DPP direction not to prosecute but he stood over his evidence yesterday that Mr Bailey was subjected to a level of surveillance reserved for active criminal offenders.
He said any incidents of domestic violence would or should be recorded elsewhere on the Pulse system but not in the intelligence collation section on a person.
It was put to Mr Wilson that in 2010 there were 20 entries in the Pulse system relating to Mr Bailey.
At that stage he was on bail on a European Arrest Warrant.
Half of the entries related to him signing on while on bail on that warrant, one was about a court appearance and the remainder were sightings of him.
Mr Ó Braonáin said this was to keep gardaí informed that he was still in the jurisdiction and abiding by the terms of his bail.
Mr Wilson said he still stood over his evidence that the level of surveillance of Mr Bailey was "oppressive".
Mr Ó Braonáin said nowhere on the system was there a reference to surveillance.
Mr Wilson said it was "very obvious that the contrary was the case".
Mr Ó Braonáin said there was a big difference between urban and rural areas where in urban areas there were cameras in every location, unlike rural areas where movements had to be recorded.
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