The principle of State liability
Question
“The possibility for the individual under Francovich to claim damages against the Member State where a directive has not been correctly implemented is not, in my view, an adequate substitute for the direct enforcement of the directive. It would often require the plaintiff to bring two separate sets of legal proceedings either simultaneously or successively, one against the private defendant and the other against the public authorities, which would hardly be compatible with the requirements of an effective remedy” (Advocate General Jacobs in Vaneetweld v SA Le Foyer)
Is this an accurate assessment of the principle of State liability? Illustrate your answer by reference to the case law.