ABSTRACT
If supremacy defines the relationship between the Member States and the European Union (EU), then direct effect defines the relationship between the citizens of the various Member States and the EU in the form of its laws. Direct effect is therefore another major element in ensuring that EU law is applied harmoniously throughout the Member States. It has been instrumental in ensuring that the broad objectives of the Treaties have been observed by the Member States and incorporated into national law. Direct effect and indirect effect and state liability are all devices created by the Court of Justice to ensure effective enforcement of the Treaties. Direct effect was relevant to the case because there was a conflict between what fell within national law and how it conflicted with EU law. The Court identified that there were two types of direct effect: vertical direct effect and horizontal direct effect.
