26It is settled case-law that Member States may not impose a criminal penalty in this area so disproportionate to the gravity of the infringement as to become an obstacle to the free movement of persons, in view of the effect which the right to drive a motor vehicle has on the actual exercise of a trade or profession by an employed or self-employed person, particularly with regard to access to certain activities or certain offices (see Skanavi and Chryssanthakopoulos, paragraphs 36 and 38).
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