Weekend Edition Nº187

EU Citizenship and Brexit: A Mid-Term Review

Polly Ruth Polak 1

In 2001, the Court of Justice made an aspirational statement that remains a subject of intense debate.2 Indeed, just how far has EU citizenship progressed towards its destiny of becoming ‘the fundamental status of the nationals of the Member States’?3 When it comes to answering this elusive question, one might find new insight by assessing the relevance EU citizenship had during the process of the UK’s withdrawal from the Union. Simply put, if EU citizenship and the rights it entails can be disregarded, downgraded or even erased, how valuable was it in the first place? In the early days, between the Brexit referendum and the effective withdrawal of the UK, academic speculation about the potential consequences for EU citizenship of leaving the EU ran high. These initial debates essentially mirrored the opposing conceptions that have always surrounded Union citizenship.4 On the one hand, EU citizenship can be considered a merely political creation; a simple continuation of the classical four freedoms that does not go beyond a set of market-oriented rights enshrined in EU secondary law. Consistent with this view, such rights can be removed just as easily as they are granted. In this sense, certain scholars argued at the time that EU citizenship could not possibly affect, legally speaking, the regulation of withdrawal, mainly because Article 50 did not contain any EU citizenship-related conditions. From this perspective, any protection offered of EU citizens’ rights depended solely on the political will of the withdrawal negotiators: anything was possible.5 Alternatively, it could be considered that years of jurisprudential evolution of EU citizenship has transformed it from a purely political concept into a bedrock for asserting tangible legal rights.6 This other side of the debate linked Article 50 TEU with the constitutional framework of the Treaties and believed in certain legal constraints stemming from other EU rules and principles that necessarily required withdrawal to be legally consistent with the protection of EU citizenship.7

1. Professor of International and European Law at the University of Salamanca (Spain).

2. Jo Shaw, ‘EU Citizenship: Still a Fundamental Status?’ Robert Schuman Centre for Advanced Studies Research Paper No. RSCAS 2018/14, 2018.

3. Judgment of the Court of 20 September 2001, Rudy Grzelczyk v Centre public d’aide sociale d’Ottignies-Louvain-la-Neuve, C-184/99, EU:C:2001:458, para 31.

4. Dimitry Kochenov, ‘The Present and the Future of EU Citizenship: A Bird’s Eye View of the Legal Debate’, Jean Monnet Working Papers (NYU Law School) No.2/12, 2012.

5. Dimitry Kochenov, ‘EU Citizenship and Withdrawals from the Union: How Inevitable is the Radical Downgrading of Rights?’, LEQS Discussion Paper Series no. 111, 2016.

6. Phoebus Athanassiou and Stephanie Shaelou, ‘EU Citizenship and Its Relevance to EU Exit and Secession’, in Dimitry Kochenov (ed.), EU Citizenship and Federalism: the Role of Rights (CUP, 2016), p. 731.

7. Piet Eeckhout and Eleni Frantziou, ‘Brexit and article 50 TEU: A constitutionalist reading’ 3 Common Market Law Review 54, 2017, pp. 695-733.

This paper returns to these debates just over four years after Brexit became final. As conveyed in Cambien, Kochenov and Muir’s 2020 collective volume ‘European Citizenship under Stress: Social Justice, Brexit and Other Challenges,’8 among the different obstacles to EU citizenship fulfilling its destiny to become ‘the fundamental status’ of nationals of the Member States, Brexit occupies a particularly prominent place. It is thus interesting today to consider how the concept and scope of EU citizenship and the rights attached to it have emerged from this significant challenge. In order to do so—and with the benefit that always comes from hindsight—this paper will address three pivotal aspects regarding EU citizenship before, during and after the UK’s withdrawal from the Union while also considering some more recent developments and others yet to come.

1. Voting Brexit

If EU citizenship and the rights it entails can be disregarded, downgraded or even erased, how valuable was it in the first place?

To begin with, it is safe to assume that the only means under the democratic principle to take the constitutionally momentous step of withdrawal from the EU would be via a referendum in the withdrawing state.9 This, however, means grappling with the issue of determining who has the right to vote on the potential loss of their EU citizenship.10 The first question to consider, therefore, is whether EU citizenship has a role to play when a Member State establishes its franchise in order to determine who can vote on the decision to withdraw from the EU and to potentially remove their EU rights. The franchise established in the UK for the EU referendum is especially interesting in this regard, notably for its controversial nature. Indeed, based on the franchise for the general elections in force at that moment, the European Union Referendum Act 2015 denied the vote to some of the individuals that were to be the most affected by the result: British nationals living in other Member States if they had been away for more than 15 years, and non-Commonwealth EU citizens living in the UK. Following O’Neill’s arguments at the time, this franchise clearly violated EU law by penalising British nationals who had exercised their free movement rights and by discriminating EU citizens resident in the UK as Irish, Cypriot, and Maltese nationals were allowed to vote due to their Commonwealth citizenships, but all other EU citizens in the UK were not.11

8. Nathan Cambien, et al. (eds.), European Citizenship under Stress: Social Justice, Brexit and Other Challenges (Brill, 2020).

9. Polly Ruth Polak, ‘Beyond Article 50 TEU: The Constitutionalisation of EU Withdrawal’, Re:constitution Working Paper 34, 2024 (forthcoming).

10. Jo Shaw, ‘Unions and Citizens: Membership Status and Political Rights in Scotland, the UK and the EU,’ in Carlos Closa (ed.), Secession from a Member State and Withdrawal from the European Union (CUP, 2017), p. 153.

11. Aidan O’Neill, ‘(Dis)Enfranchisement and Free Movement,’ in Panos Koutrakos, Niamh Nic Shuibhne and Phil Syrpis (eds), Exceptions from EU Free Movement Law: Derogation, Justification and Proportionality (Bloomsbury, 2016).

It is safe to assume that the only means under the democratic principle to take the constitutionally momentous step of withdrawal from the EU would be via a referendum in the withdrawing state

Interestingly, the British courts agreed that the national competence to decide the EU referendum franchise had to be exercised with due regard to EU law, and that if the conditions for the UK parliamentary franchise laid down in national legislation restricted the exercise of the EU right of free movement, this could run contrary to that legal order. However, the court also considered that the 15-year rule, although a disadvantage, could not be characterized as a restriction. Specifically, it was not a measure liable to dissuade or deter EU citizens from exercising their rights of free movement. On the contrary, it had the legitimate purpose of confining the vote to those citizens with a close and objective connection with the UK.12 This assertion weakens considerably when taking into account the European Commission’s starkly opposite view: ‘it must be taken into account that national policies which lead to disenfranchising citizens may be considered as limiting the enjoyment of rights attached to EU citizenship, such as the right to move and reside freely within the EU, a fundamental right of every EU citizen. This is at odds with the founding premise of EU citizenship, namely that it is additional to national citizenship and is designed to give additional rights to EU citizens, whereas in this case the exercise of the right of free movement may lead to losing a right of political participation.’13 In fact, the UK court’s ruling has been further discredited by the passage of the new UK Elections Act 2022 which has removed the 15-year limit on voting rights in the UK general elections for British citizens living overseas and which had inspired the EU referendum franchise. The UK Governments’ declarations on adopting its new ‘votes for life’ policy are especially revealing of the contestable nature of the previous system: ‘British expatriates are also directly affected by decisions made in the UK Parliament – for example, on foreign policy, defence, immigration, or pensions. It is therefore right that they have a voice in elections to that body. There is considerable demand for these reforms. Expats of all political stripes are keen to have their say on issues that affect them.’14

12. UK High Court of Justice, Harry Shindler and Jacquelyn Maclennan v. Chancellor Of The Duchy Of Lancaster and Secretary of State for Foreign And Commonwealth Affairs, [2016] EWHC 957.

13. European Commission, Communication addressing the consequences of disenfranchisement of Union citizens exercising their right to free movement, COM(2014) 33 final, 29 January 2014.

14. UK Policy Paper, Overseas electors: Delivering ‘votes for life’ for British expatriates, 3 February 2022.

Brexit has clearly highlighted the need to take close account of EU citizenship rights when designing national rules determining the franchise for an EU withdrawal referendum

Brexit has clearly highlighted the need to take close account of EU citizenship rights when designing national rules determining the franchise for an EU withdrawal referendum. However, regarding the participation of resident EU citizens, the legitimacy for their enfranchisement in the referendum was counterbalanced by arguments against the government creating an artificial majority to precondition the outcome by including a group so obviously in favour of EU membership. To this, however, we might add the curious fact that the UK authorities did not oppose including EU citizens in the Scottish independence referendum of 2014 despite similar allegations of using loaded dice. In any case, and notwithstanding clear democratic and justice-based arguments for including those who are taking advantage of EU free movement rights in the other direction, that is, EU citizens residing in the withdrawing state, there have been no legal challenges nor developments concerning the legality of their questionable disenfranchisement in the Brexit referendum.

2. Negotiating Brexit

The second question to ask is if EU citizenship was treated as a legal restraint on the Brexit negotiations. I believe this to be true in a number of ways. Firstly, there was never any doubt among the parties that EU citizenship was the most powerful part of EU law when it came to conditioning the withdrawal negotiations. So much so that it was the only substantive issue dealt with in depth during the first phase of withdrawal talks towards reaching a divorce deal, while the vast amount of other material aspects affected by the UK’s withdrawal were left to be part of the future trade agreement.15 Furthermore, although Article 50(3) TEU allows for a unilateral withdrawal, the negotiators were also aware that a no deal Brexit would prove particularly severe for citizens exercising free movement rights. Where valuable rights are lost litigation is likely and thus it was probable that both national courts and the Court of Justice would have been open to offering some kind of legal protection to so-called ‘former EU citizens.’16 Thus, not only to protect EU citizens but also to protect themselves from a certain avalanche of legal claims, both negotiating parties took unilateral action in case they failed to agree on mutual safeguards

15. Polly Ruth Polak, EU Withdrawal as a Supranational Affair: The Case of Brexit, Brill Nijhoff, 2023.

16. Eleanor Spaventa, ‘Mice or Horses? British Citizens in the EU 27 after Brexit as “Former EU Citizens”’, 44 European Law Review 5, 2019, 589.

for citizens’ rights. In this sense, the EU27 prepared national contingency measures coordinated by the European Commission to ensure continued legal residence for UK nationals already residing in their territories.17 Meanwhile, the UK Government’s EU Settlement Scheme to allow EU citizens to remain in the UK and protect their rights was to be put in place with or without a deal.18

Nonetheless, we can also discern here clear indication that EU citizenship didn’t prove as legally powerful as some had hoped.19 Indeed, protection was only ever intended for certain EU rights, mainly, free movement, and only for those already exercising it. Thus, Brexit also highlights uncomfortable truths: EU citizenship is to a certain extent a simple collection of rights, as only some were treated as legally significant under the concept of ‘acquired rights’ while others were deemed entirely removable. Even the right to free movement, recognised as the most important of the rights that needed protecting from withdrawal, was split into the right to reside in the host state and what was labelled as ‘future’ movement rights. Only the former was considered unnegotiable, while allowing British nationals living abroad to conserve their EU rights beyond their host state was only ever treated as another bargaining chip in the negotiations.20 Moreover, Brexit also damages recent arguments that EU citizenship has come to mean more than cross-border movement,21 in as much as ‘static’ EU citizens were entirely left out of the withdrawal negotiations. Finally, although an agreement on citizens’ rights was a major priority for the Brexit talks and unilateral measures were forthcoming in case they failed, EU citizenship also proved too weak to ensure more immediate guarantees. In this sense, calls to ring-fence these rights from the rest of the divorce issues and offer reciprocal protection no matter what were ignored on

There was never any doubt among the parties that EU citizenship was the most powerful part of EU law when it came to conditioning the withdrawal negotiations

17. European Commission, Communication and legislative proposals from the Commission on limited contingency measures in the absence of an agreement on a future partnership with the United Kingdom, COM(2020) 831 final, 10 December 2020.

18. UK Government, No-Deal Readiness Report, 14 October 2019.

19. Volker Roeben et al., ‘Revisiting Union Citizenship from a Fundamental Rights perspective in the time of Brexit’, European Human Rights Law Review 5, 2018, pp. 450-473.

20. Adam Łazowski, ‘When Cives Europae became bargaining chips: free movement of persons in the Brexit negotiations’, 18 ERA Forum 4, 2018.

21. Daniel Sarmiento and Eleanor Sharpston, ‘European Citizenship and Its New Union: Time to Move On?’, in Dimitry Kochenov (ed.), EU Citizenship and Federalism. The Role of Rights (CUP, 2017).

EU citizenship is to a certain extent a simple collection of rights, as only some were treated as legally significant under the concept of ‘acquired rights’ while others were deemed entirely removable

the basis of the ‘nothing is agreed until everything is agreed’ principle.22 Thus, EU citizens endured a terrible period of uncertainty while their rights were made conditional upon reaching a deal on all other divorce matters. Similarly, it was only very close to the finish line that the parties began showing real concern about a no deal scenario and decided to offer conclusive unilateral guarantees.

3. Challenging Brexit

Part Two of the EU-UK Withdrawal Agreement (WA) creates a new category of migrant, the so-called ‘Brexit citizen.’ These relatively privileged migrants are UK citizens that were residing in the EU and EU citizens residing in the UK at the end of the transition period (31 December 2020). In essence, they are now protected for life, along with their families, by the legal regime of Directive 2004/38/EC under the EU law principles of direct effect and primacy, and under the coverage of prior EU case law and the CJEU’s preliminary ruling mechanism within a period of 8 years from the date of entry into force of the agreement.23 On the other hand, all ‘moving’ Brits have lost their EU citizenship and most other rights attached, including any ‘future’ movement rights. All ‘static’ Brits have reverted entirely to third-country nationals. Thus, while the WA is an unprecedented and extraordinary supranational instrument24 as a direct consequence of the legal obligation that weighs on the parties to prevent the termination of significant rights,25 it has also been the object of serious criticism from a Union citizenship point of view. In other words, it brings to the fore another set of harsh realities concerning the limits of EU citizenship. As we already mentioned when discussing the Brexit negotiations, the WA

22. Stijn Smismans, ‘Ring-Fencing Citizens’ Rights in the Brexit Negotiations: Legal Framework and Political Dynamics’, DCU Brexit Institute Working Paper, 2019.

23. Agreement on the withdrawal of the UK of Great Britain and Northern Ireland from the EU and the European Atomic Energy Community [2020] OJ L 29/ 7.

24. Stijn Smismans, ‘EU citizens’ rights post Brexit: why direct effect beyond the EU is not enough’, 14 European Constitutional Law Review 3, 2018, pp. 443-474

25. Polly Ruth Polak and Ramses A. Wessel, ‘The Emergence of EU Withdrawal Law’, 61 Common Market Law Review 1, 2023, pp. 167-194.

is a stark reminder of the requirement for a cross-border element as a precondition for triggering EU rights. In addition, as O’Brien points out, the new regime is also clearly constructed not around the concept of EU citizenship but around the limitations and conditions in Directive 2004/38.26 It thus also puts the spotlight on the need to have an economic activity or sufficient resources as well as comprehensive health insurance to benefit from free movement rights. Finally, the division of free movement rights into right of residence in the host state and no rights of future movement by which British Brexit citizens are essentially ‘locked’ in one Member State, further complicates any view that EU rights are part of a single borderless space creating a unique supranational relationship between their beneficiaries and the EU as a whole.27

The Withdrawal Agreement is a stark reminder of the requirement for a cross-border element as a precondition for triggering EU rights

It is notable, however, that unlike the more complicated task of making politicians accountable, the WA is a binding legal instrument justiciable both in the national courts of the Member States and the UK, as well as before the Court of Justice. The latter, therefore, has the ability to answer all our questions regarding whether the WA does in fact offer sufficient coverage of EU citizens’ rights after withdrawal. There is, however, an obvious drawback in so far as the Court can only answer when and what it is asked. Unfortunately, and despite most scholars arguing that it is possible to request a 218(11) TFEU Opinion on a withdrawal agreement’s compatibility with the Treaties, none was requested of the UK’s draft WA.28 Similarly, all individual actions for annulments lodged with the General Court regarding citizens’ rights in the Brexit context have been dismissed on account of not meeting the restrictive conditions on standing of Article 263 TFEU.29 Thus, for the time being, there have only been two major judgments from the Court of Justice on the implications of Brexit for Union citizens, both arising from proceedings brought by the same British national before the same French court that decided to twice activate the preliminary reference mechanism. The first thing that strikes us, therefore, is the surprisingly low level of litigation that has actually emerged from Brexit in this area, particularly as no British court—midway through their 8 year deadline—has yet requested any preliminary rulings. Nonetheless, these two decisions can provide us with some insight into the Court’s perception of EU citizenship and withdrawal and further inform our understanding of its real value.

26. Charlotte O’brien, ‘Between the devil and the deep blue sea: Vulnerable EU citizens cast adrift in the UK post-Brexit’, 58 Common Market Law Review 2, 2021, pp. 431-470.

27. Eleanor Spaventa, ‘Brexit and the free movement of persons: what is EU citizenship really about?’, In Niamh Nic Shuibhne, Revisiting the Fundamentals of the Free Movement of Persons in EU Law (OUP, 2023), p. 158.

28. Polly Ruth Polak, ‘The UK Withdrawal Agreement as a Sui Generis EU International Treaty and its Admissibility to the CJEU’s Opinion Procedure’ in José Martín y Pérez de Nanclares y Daniel González Herrera (eds.), El diálogo judicial internacional en la protección de los derechos fundamentals (Tirant lo Blanc, 2019).

29. Judgment of the General Court of 26 November 2018, Shindler and Others v Council, T- 458/ 17, EU:T:2018:838; Order of the General Court of 24 June 2020, Price v Council, T- 231/ 20, EU:T:2020:280; Order of the General Court of 8 June 2021, Silver and others v Council, T-252/ 20, EU:T:2021:347.

E.P., a United Kingdom national, had resided in France since 1984. Following the entry into force of the WA, she was removed from the electoral roll in France. E.P. then filed two complaints, one concerning her deprivation of the right to vote and to stand as candidate in French municipal elections and another with regards to the removal of her right to vote and to stand in elections to the European Parliament. However, when the French Court referred the questions to the EU Court, it began by asking more generally whether Union citizenship and the rights it entails could be removed on account of Article 50 TEU and the EU-UK WA. In the first case, C-673/20, Préfet du Gers I, 30 the Court dismissed any argument that British citizens could retain EU citizenship after the UK’s withdrawal by noting that possession of the nationality of a Member State is essential to acquiring and retaining the status of citizen of the Union and to benefit fully from the rights attached. As a result, the Court concluded that UK nationals no longer enjoy the right to vote and stand as a candidate in municipal elections in the Member States. In the second case, C-716/22, Préfet du Gers II,31 the Court applied a similar interpretation to conclude that UK nationals no longer benefitted from a right to vote and to stand as candidates in elections to the European Parliament in their Member State of residence. Thus, these rulings essentially confirm that neither the loss of EU citizenship nor the loss of the electoral rights attached to it, due to the voluntary withdrawal of a Member State from the Union, is incompatible with the Treaties.

Préfet du Gers I has been heavily critisised, among other reasons, for the lack of any ‘consideration of the fact that Union citizenship might be a status that transcends the confines of international law nor of any residual responsibility of the EU towards its former citizens’32 in what might be seen as a ‘considerable blow to EU citizenship as a status.’33 Although these views may be justified, I would however refrain from reading too deeply into these judgements. Firstly, the idea that one must hold the nationality of a Member State to be a citizen of the Union was already widely accepted in scholarship before these decisions were delivered.34 The fact is that retaining EU citizenship after a state withdraws from the Union is not only incompatible with basically all references to citizenship in EU law, but would somewhat defeat the purpose of leaving.35 Nonetheless, this still doesn’t mean that all EU citizenship rights are removable, and these judgments do not confirm this either. On the contrary, while the Court is very direct in asserting that the loss of nationality of a Member State entails the loss of Union citizenship, it also indicates that the consequence is that such nationals no longer meet the essential condition to benefit fully from the rights attaching to that status, thus suggesting loss of citizenship does not imply loss of all EU rights. Likewise, the Court very carefully circumscribes its answers to the two political rights at hand and thus I don’t believe we need to make any general conclusion that former EU citizens can be deprived, again, of all their EU rights. In this sense, when the Court states that ‘[i]t is irrelevant, in that regard, that United Kingdom nationals have previously exercised their right to reside in a Member State’ (emphasis added), it is clearly referring to ‘the

30. Judgment of the Court of Justice of 9 June 2022, Préfet du Gers I, C- 673/20, EU:C:2022:449.

31. Judgment of the Court of Justice of 18 April 2024, Préfet du Gers II, C-716/22, EU:C:2024:339.

32. Spaventa n 27, p. 183

33. Serhii Lashyn, ‘Sacrificing EU citizenship on the altar of Brexit’, 29 Maastricht Journal of European and Comparative Law 6, 2022, p. 744.

34. Vaughne Miller, ‘Brexit and European Citizenship’, House of Commons Briefing Paper, 6 July 2018, p. 15.

35. Martijn van den Brink and Dimitry Kochenov, ‘Claiming “We are out but I am in” post-Brexit. AG Collins’ Opinion in the Préfet du Gers Case’, Verfassungsblog, 25 February 2022.

While the Court is very direct in asserting that the loss of nationality of a Member State entails the loss of Union citizenship, it also indicates that the consequence is that such nationals no longer meet the essential condition to benefit fully from the rights attaching to that status, thus suggesting loss of citizenship does not imply loss of all EU rights

right to vote and to stand as a candidate in municipal elections in their Member State of residence’ mentioned in the previous sentence,36 and thus it would be hasty to conclude that whether the UK citizen has exercised any Treaty rights before withdrawal is immaterial, nor that no rights at all remain from their previous Union status. Likewise, the Court recognises that the EU institutions enjoy broad discretion in policy decisions in the conduct of external relations and are not required to grant, unilaterally, third-country nationals rights ‘such as the right to vote and to stand as a candidate in municipal elections’37 or ‘such as the right to vote and to stand as a candidate in elections to the European Parliament’,38 both of which are ‘reserved solely to Union citizens.’39 Indeed, where it seems logical and legitimate that voting rights should fall within political discretion as they are so obviously connected to the EU citizens’ interest in taking part in the political life of the Union and therefore tend only to be exercised by them, there are a number of core EU citizenship rights that, unlike these, are sometimes provided to third country nationals (for example, to citizens from the EEA countries and Switzerland), and may well merit a different approach from the Court in the context of withdrawal. Thus, one might still expect a different outcome if the Court is questioned about other aspects of the WA, such as the political decision to exclude other EU rights or the downgrading of included rights and their legal protection as an ex EU citizen transitions from the coverage of the Treaties to that of the WA.40

36. Préfet du Gers I, para 58

37. Id., para 99

38. Préfet du Gers II, para 68

39. Ibid.

40. Niamh Nic Shuibhne, ‘Protecting the legal heritage of former Union citizens: EP v. Préfet du Gers’, 60 Common Market Law Review 2, 2022, pp. 475-516

4. Conclusions

In this Long-Read, I have returned to the UK’s withdrawal from the EU as one of the most significant challenges to the concept of EU citizenship in recent times with the aim of assessing just how far it has come from its original conception as a mere set of economic rights to a truly fundamental status whose disregard, downgrading or loss can be legally challenged in court. The first issue touched upon was whether EU citizenship can condition a withdrawal referendum franchise. We have seen how the UK courts have recognised that it would be contrary to EU law if national legislation in this regard restricted EU free movement. Thus, it has become quite clear that disenfranchising nationals abroad is at odds with the ‘founding premise of EU citizenship.’ However, there have been no legal challenges or developments when it comes to excluding resident EU citizens in this kind of referendum. Secondly, no substantive issue emerged as of greater relevance for the UK’s withdrawal negotiations while also proving worthy of unilateral contingency measures in case of a no deal Brexit. Nonetheless, Brexit has so far proven that only certain EU rights cannot be made entirely contingent on political agreement while the rest can be left to politicians to be used as bargaining chips. Finally, EU citizenship is not an autonomous status that can be acquired or retained without the nationality of a Member State. Likewise, political rights generally reserved to Union citizens can be legally removed from the citizens of a state that has withdrawn from the Union. However, the EU-UK WA is testament to the fact that EU citizenship offers the holder a number of rights that must under all circumstances be guaranteed. What we can only guess at for the time being, is whether this unique but quite limited regime conserving free movement rights only for those who were exercising them at the time of Brexit, only in their host state, only if they meet certain economic conditions and only if they have successfully applied for residency, is a legally valid outcome of a Member State’s withdrawal in light of EU citizenship.

My conclusion, therefore, is that Brexit has not changed the nature of EU citizenship but simply provided insight into its present status. There is no doubt that while it has held significant legal power over every phase of the UK’s withdrawal, it has also revealed its current limitations. Nonetheless, it is important to bear in mind that there is still time for Brexit to be seized by the Court as an opportunity to continue advancing EU citizenship towards its destiny.

There is still time for Brexit to be seized by the Court as an opportunity to continue advancing EU citizenship towards its destiny

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