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Case C-91/92 Faccini Dori [1995]


  • Faccini Dori concluded an English language course contract when away from home, which was prohibited under a directive
  • Italy had not implemented the directive (as it should have done years earlier)


  • Could the contract be avoided?


  • No


  • Directives do not have horizontal effect
  • However, Faccini Dori could recover her losses from Italy under the doctrine of state liability for its wrongdoing
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