The Constitutionalisation of the Treaties by the European Court of Justice

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The Constitutionalisation of the Treaties by the European Court of Justice

Introduction

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On it's formation in 1957 the European Economic Community Treaty[1]

was seemingly another international treaty to which the six original

Member States[2] had signed. In the realm of international law such

treaties are binding merely on the governments of Member States which

have signed them. In it's essential provisions, the Treaty made

reference only to the Member States who themselves had no reason to

believe this Treaty would be any different.

However, it was latent from the start that this Treaty had the

potential to extend beyond the reach of previous international

treaties[3]. It provided for a unique institutional structure[4] from

which flowed unprecedented law-making and judicial powers. The focus

of this essay will be on one of these institutions, the European Court

of Justice (hereinafter referred to as the Court).

According to the Treaty the purpose of the Court is to 'ensure that in

the interpretation and application of this Treaty the law is observed'[5].

It was under the guise of 'interpretation' and in particular the use

of Article 234[6] that the court was able to attribute qualities to

the Treaty that were not prima facie evident. This essay will trace

how the court in conjunction with national courts used this Article to

develop the doctrines of direct effect and supremacy, and how it

expanded the use of such doctrines to law created under the Treaty

which neither explicitly or impliedly warranted their ascription.

The doctrines thus mentioned attributed to the Treaty, characteristics

more in line...

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...ommunity Law' (1983) 8 ELRev. 155

[20] Case 36/74, [1976] ECR 455

[21] Case 6/64, [1964] ECR 585

[22] This is also the opinion of Mancini, 'The Making of a

Constitution for Europe', Common Market Law Review, vol. 26, 1989,

p600

[23] Craig and de Burca, 1998, EU Law, Text, Cases and Materials p.

259

[24] loc. Cit. N.15

[25] Case 11/70, [1970] ECR 1125

[26] Case 106/77, [1978] ECR 629

[27] Case C213/89, [1990] ECR I-2433

[28] Case 41/74, [1974] ECR 1337

[29] Mazzalai, Case 111/75, [1976] ECR 657, at 665

[30] Hartley , op.cit. p.202

[31] Case 148/78, [1979] ECR 1629

[32] Marshall, Case 152/84, [1986] ECR 723 ; Faccini Dori v Recreb,

Case C-91/92, [1994] ECR I-3325

[33] 'From CILFIT to ERT : the Constitutional Challenge Facing the

European Court' (1991) 11 YBEL 1, 2-3

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