Case 181/84 R v Intervention Board for Agricultural Produce, Ex p. Man (Sugar) 
- An export licence application from Man (Sugar) was 4 hours late
- This would cost Man (sugar) millions of pounds
- Could relief from forfeiture be obtained?
- Forfeiting Man (Sugar)’s ability to obtain a licence would be disproportionate
- This case recognised the need for proportionality in EU law