Alice-Mary Higgins (Independent)
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It was very useful to hear about the Rosneft case, which was a really interesting example in terms of the clear precedent it set on the question of public policy involving both goods and services and, indeed, compliance with international law being considered as an appropriate use of the public policy grounds. I want to talk about a related issue, namely, the question of the primacy of international versus EU law. We have heard different opinions on this. Professor Tridimas noted the obligation of member states in relation to international law and the recognition of same. In Article 347 of the TFEU there is reference to the very exceptional public policy grounds and it specifically uses the word "obligations". There is almost a recognition there within the TFEU that member states have obligations. It is interesting that this is the language that is used. The "obligations" phrase is the same phrase that is used in paragraph 278 of the ICJ judgment, which is pertinent in the context of this particular legislation. Professor Tridimas has given an opinion on the primacy of international over EU law but Professor Butler has expressed a different opinion. He has given an opinion on the primacy of EU law over public international law, if I understand him correctly. That is a key point that should be clarified. I have another question but will begin with that one.