Freedom of establishment under article 43, which entitled a person from one MS to equal treatment with those from another, was held to be directly effective. Implementation merely made the principle easier to apply. Given the fundamental nature of freedom of establishment and equal treatment, the exceptions under article 45 cannot be read so widely as to go beyond the objective for including them, and should therefore be limited to jobs that involve the exercise of official authority. This was not the case here (lawyer). No real discussion on the direct effect point because commission accepted it. V odd as it didn’t seem to fulfil the Van Gend en Loos criteria (Craig).
ECJ: The exceptions only may occur with reference to e the exercise of powers with a ‘direct and specific connection with the exercise of official authority’. In the absence of secondary legislation, only the ‘core’ of article 43 was directly effective.
