... its notification to the plaintiff, or, in the absence thereof, of the day on which it came to the knowledge of the latter, as the case may be. Thus the time limit may well have passed before the alleged illegality or indeed the private party's wish or need to litigate has become apparent. Under Article 234, there is no such time limit. This allows the individual a broader scope to bring an action. However, in the case Walter Rau Lebebsmitttel V. Bundesanstalt fur Landwirtschaftliche Marktordnung(1987) a challenge under Article 234 will not be possible if the matter could have been raised by a person who had standing under Article 230, and who knew of the matter within the time limits for a direct action. In Article 230, the requirements that individuals would have to have to meet to be able to challenge a EU provision under Article 230 is very ...

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