C-106/77 Amministrazione delle Finanze v Simmenthal SpA [1978]
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C-106/77 Amministrazione delle Finanze v Simmenthal SpA [1978] ECR 629 is a significant EU law case that addresses the conflict between a national legal system and European Union law. The case establishes the duty of national courts to give full effect to EU provisions under the principle of the supremacy of EU law.
Simmenthal SpA imported beef from France to Italy, and Italy imposed a public health inspection fee under a 1970 Italian law. This conflicted with European Community Regulations from 1964 and 1968. Italian courts faced the question of whether the later Italian law should prevail over the conflicting EU Regulations, arguing that the national law had to be applied until declared unconstitutional.
The European Court of Justice (ECJ) held that the national court had a duty to give full effect to Community provisions, even if a conflicting national law was adopted later. The ECJ emphasised the principle of the precedence of Community law, stating that EU law automatically rendered any conflicting provision of national law inapplicable upon its entry into force. Moreover, the ECJ held that EU law also precluded the valid adoption of new national legislative measures that would be incompatible with EU provisions.
The key passage highlighted the relationship between EU provisions and national law: "Furthermore, in accordance with the principle of the precedence of Community law, the relationship between provisions of the treaty and directly applicable measures of the institutions... render automatically inapplicable any conflicting provision of current national law but... also preclude the valid adoption of new national legislative measures to the extent to which they would be incompatible with Community provisions".
Amministrazione delle Finanze v Simmenthal SpA is a landmark case reinforcing the supremacy and direct effect of EU law over national laws. The judgment clarified that conflicting national laws, even if adopted later, cannot prevail over existing or future EU provisions. This principle ensures the uniform application and effectiveness of EU law across member states, establishing the foundations for the legal order within the EU.
The Simmenthal case is pivotal in affirming the principle of supremacy of EU law and its direct effect. By emphasising that conflicting national laws are automatically rendered inapplicable, the ECJ reinforced the binding nature of EU law on member states, safeguarding the integrity and effectiveness of the European legal order. The judgment underscores the commitment to the principles of the EU treaties, ensuring that obligations undertaken by member states are upheld unconditionally and irrevocably.
