members have commented on Fair Trials’ news section, the Court appeared, paradoxically, to have thus used the Access to a Lawyer Directive as a justification for not following a clear evolution in the case-law of the ECtHR. That said, as in France, the case placed the legislator under the microscope. c. Template pleadings in Spain A LEAP member in Spain, working with Asociación Libre de Abogados, a lawyers’ network, sought to confront the situation arising in police stations in which lawyers have been admonished by police for advising clients to remain silent, together with the lack of access to the case file prior to questioning. They circulated a template pleading for the purposes of habeas corpus applications challenging the regularity of police arrests, which was made available to colleagues, drawing upon the Directives. In respect of the Right to Information Directive, the pleading makes straightforward arguments based on direct effect of Article 7(1), arguing that the latter entitles them to the police file prior to questioning. In respect of the Access to a Lawyer Directive, the pleading relies upon subsequent cases developing the Wallonie principle. It then argues that, due to the violation of the suspect’s rights, the police arrest is not regular. One such case is pending before the Constitutional Court. 4. Some pre-deadline ideas We think it will, realistically, be challenging to obtain positive results on the basis of the Access to a Lawyer Directive prior to its transposition deadline (the same goes for other directives which may in due course be adopted further to the Roadmap). We propose some arguments below, though we would say clearly that some of these are very far-reaching. Arguments based on the Wallonie doctrine  The national authorities, both the investigative ones and the courts, are bound by the obligation now articulated in Article 4(3) TEU to ‘take any appropriate measure, general or particular, to ensure fulfilment of the obligations arising out of the Treaties’, which includes the Access to a Lawyer Directive. The obligations under Article 288 to achieve the objectives of that directive have already come into being by virtue of that measure entering into force.  Arguably, relying on Kolpinguis, the duty of conforming interpretation arises prior to a directive’s transposition deadline, so if the national law can be interpreted and applied in line with the Access to a Lawyer Directive, it should be.  More clearly established is the obligation of the Member State to refrain from taking, prior to the transposition deadline of a directive, measures liable seriously to compromise the achievement of the latter’s objectives after that deadline (Wallonie). This includes the courts, which are bound to refrain from adopting interpretations of national law in this period which would mean the results would not be achieved following the transposition deadline (.  Whilst the Wallonie case-law plainly refers to legislative measures, arguably, measures of a more particular nature (such as investigative actions) should also be avoided in the period prior to the transposition deadline of the Access to a Lawyer Directive if they are liable seriously to compromise the objectives of the latter. So, in particular, if a person is to be questioned, doing so in a manner contrary to the 18