The school's lawyer said he had at times been inside the school grounds but not the building since then.
The school was not making an application at this stage to attach and commit him to prison for continuing contempt of court orders.
The court also heard the Attorney General believes he could apply to sequester his assets to recover some €190,000 in daily fines imposed on him for continuing breaches of orders by attending the school during terms since August 2022.
The AG does not not think there is anything wrong with him being the moving party in such an application as the AG would have standing “in the public interest”, counsel for the AG told the court on Tuesday.
Mr Burke was released from prison before Christmas when the Co Westmeath school was closed for the school holidays.
He has spent more than 500 days in Mountjoy Prison for refusing to abide by a court order to stay away from the premises.
The court heard on Tuesday Mr Burke returned to the school when it reopened on January 6 and has been there on most working days since.
He did not appear in court on Tuesday afternoon, but wrote reiterating his contention that the courts have denied him his constitutional rights to freedom of conscience and the free profession and practice of religion.