20It is settled case-law that the Court cannot in any event take account of measures adopted by a Member State after the commencement of an action for failure to fulfil its obligations in order to comply with those obligations (Case C-71/97 Commission v Spain [1998] ECR I-5991, paragraph 18) and that, moreover, a Member State cannot rely on provisions, practices or circumstances in its own legal order to justify failure to implement a directive within the prescribed period (Case C-274/98 Commission v Spain [2000] ECR I-2823, paragraph 19).
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