Article 141 is enforceable by an individual (see Kowalska v Freie und Hansestadt Hamburg (1990)). It is supplemented by the Equal Pay Directive. Generally, such directives are not enforceable by an individual, as it is left to the Member State to comply with the directive, using whatever form or method they choose. However, the Equal Pay Directive is an exception to this, as, first, it gives meaning and clarity to Art 141 and, as a result, is applied through Art 141; secondly, it fulfils the test in Van Duyn v Home Office (1975), where it was held that a directive could be enforced by an individual if it was ‘sufficiently clear, precise, admitted of no exceptions and, therefore, of its nature, needed no intervention by the national authorities’. The Directive states that: