In-house lawyers of NRAs may not represent their clients before the European Court of Justice: A case note on UKE (2011). Research Papers in Law, 3/2011

From the Introduction. It is not frequent for a National Regulation Authority (NRA) to bring an action against the Commission decision and, cynically speaking, case Prezes Urzędu Komunikacji Elektronicznej2 v Commission3 shows that the avoidance of a sweeping retaliation may be one of the reasons for it. The General Court followed the Commission‟s argument that, notwithstanding the peculiarities of the employment conditions of the Polish Regulator‟s legal counsel giving it virtually full independence, as well as the fact that the Polish law itself does not differentiate between in-house counsel and third party attorneys, the claim should be rejected on the grounds of inadmissibility. The GC based its judgment on Art 19 of the Statute of the Court of Justice4, which requires that, with the exception of the Member States' Governments and the EU Institutions, parties to the dispute must be represented by a lawyer. In so doing, the Court explicitly referred to the infamous Akzo Nobel Chemicals and Akcros Chemicals v Commission5 and EREF v Commission6. Most importantly, the Court stated that the lawyers representing Prezes Urzędu Komunikacji Elektronicznej (UKE) are bound to enjoy a degree of independence inferior to that of lawyers who are not linked to their clients by an employment contract7.

Vistas fiscales, 1876 a 1885 /

Mode of access: Internet.

Sentencing and dispositions of youth DUI and other alcohol offenses: a guide for judges and prosecutors.

Mode of access: Internet.

Opinions of the Attorney-General of Porto Rico to the Governor, the heads of departments, the Judiciary and other officials in relation to their official duties and construing and explaining the insular constitution and laws.

Vol.1 includes the annual reports of the Attorney-General to the Governor of Puerto Rico and to the Attorney-General of the United States.

Annual report of the Attorney General to the Governor of the state of Ohio for the year ending .

Includes opinions of the Attorney General.

Biennial report.

Mode of access: Internet.

Report of the attorney general for the year ending ...

Title varies slightly.

Annual report of the Attorney General.

Description based on: 1852.

Report of the Attorney General of the Commonwealth of Pennsylvania, for the years .

Description based on: 1887 and 1888.

An analysis of 1974 and 1975 professional surveys: final report.

National Highway Traffic Safety Administration, Office of Alcohol Countermeasures, Washington, D.C.

Blueprint to end ocean pollution : report /

Cover title.

Biennial report and opinions of the Attorney General of the State of Oregon.

Period covered by reports is irregular.

O. Henry's own trial: brief for W.S. Porter in the appeal August 30, 1898,

Reproduced from the original records of the U.S. Circuit Court of Appeals at New Orleans.

Biennial report of the Attorney General to the Governor of the State of Alabama.

Vols. for 1894/96-1936/38 include the opinions of the attorney general.

Biennial report of the Attorney-General.

33rd-35th reports (1963-64--1967-68) published in one volume.