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In Van Gend en Loos the CJEU recognised that the individuals can rely on a Treaty provision before a national court on the condition that the provision is clear, precise and unconditional. These conditions have been clarified and relaxed in subsequent cases. The CJEU later recognised that the Treaty provisions can be invoked not only against the state (vertical direct effect), but also in a dispute between private parties (horizontal direct effect). The scope of the direct effect doctrine has later been expanded to cover regulations, decisions and directives. However, the Court recognises only vertical direct effect of directives provided the time limit for the implementation of the Directive has expired. The Court has attempted to remedy the inequalities resulting from the denial of horizontal direct effect of directives by giving a broad definition of state entity, and introducing the doctrines of indirect effect, incidental direct effect and Member State liability.