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Case 186/87 Cowan v Trésor [1989]


  • Cowan, a citizen of the UK, was mugged whilst on holiday in France (exercising his EU free movement rights)
  • French law only permitting criminal compensation to be given to French nationals


  • Was this in breach of EU law?


  • Yes


  • In order to not breach the concept of the free movement of services, Cowan should be treated like every other (french) citizen
  • This case recognised the principle of non-discrimination
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