The issue of the imposition of financial penalties on a Member State for failing to fulfil its obligations under the Treaty has been dealt with in previous articles and annotations of this journal.1 For the sake of clarity and completeness, the relevant legal provisions are reiterated below.

EStAL 3|2013 Commission v Italy: Summary 551 Summary: EC v Italian Republic Case C?496/09 Action by the Commission under Article 228 EC for failure of the I