Editing Directive (European Union) (section)

===Direct effect===
Even though directives were not originally thought to be binding before they were implemented by member states, the European Court of Justice developed the [[doctrine]] of [[direct effect]] where unimplemented or badly implemented directives can actually have direct legal force. In the important case of ''[[Francovich v. Italy]]'', the ECJ extended the principle of ''[[Van Gend en Loos v Nederlandse Administratie der Belastingen|Van Gend en Loos]]''<ref> ''Van Gend en Loos'':  EU Treaties are capable of creating legal rights enforceable by both [[natural person|natural]] and [[legal person]]s in the courts of Member States.</ref> to provide that Member States who failed to implement a directive could incur liability to pay damages to individuals and companies who had been adversely affected by such non-implementation.