According to the argument that a Directive cannot be relied on in an action against an individual, it should be noted that, under Article 189 of the EEC Treaty, the structure mandatory of a directive which includes the reason for the likelihood of challenging the directive in the municipal court, exists only in relation to 'each Member State to which it is addressed'. The Directive alone may not be capable of establishing obligations on an individual and a provision of a Directive cannot be relied upon against a person. Numerous reasons have been given why directives should not have direct horizontal but only vertical effect. The Court of Justice's reasoning in the Marshall case was textual, based on Article 288. This argument raised two problems. The first problem is that the logic of the Court of Justice is controversial in textual terms. Article 288 simply states that a Member State is only bound by a Directive if that particular Member State is mentioned as bound, as a means of countering the rules bound to all Member States (general applicability). It did not consider whether a directive, which binds a Member State, can impose an obligation on an individual. The second problem is that the textual reliability of the European Court of Justice contradicts its approach to the direct effect of specific treaty articles (e.g. directives) which are only addressed to the Member State. Article 157, for example, is addressed only to Member States, as States must ensure the application of the basis of equal pay for male and female workers. In the Defrenne case, the European Court of Justice held that Article 157 can be invoked against the state. It was held that, the fact that Article 119 is mandatory in nature, the prohibition of discrimination between men is a ... means of paper ... in the Wells case. It is unclear whether legal certainty is the political reason for the textual limit considered above, or whether it is a non-dependent normative justification for denying horizontal direct effect. Regarding the topic it is sufficient to say the following. First, assuming that directives have horizontal direct effect, they would only apply if they satisfy the Van Gend criterion. The directive must be clear, precise and unconditional. Secondly, the meaning of legal certainty is unclear because the European Court of Justice has not provided any definition. There is therefore no credible meaning of that term which analyzes the denial of the direct horizontal effect of the directives. Thirdly, by way of comparison, the problem of legal certainty arises with the principle of indirect effect and ancillary effect, which are the main essential elements for the omission of the horizontal direct effect of directives.