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the prior ‘fair and impartial procedure’ and ‘judicial review’ now referred to in Article 1.3(a) of the Framework Directive seem only to guarantee a court hearing on appeal from an initial ruling (which must be ‘fair and impartial’ but could be non-judicial) to disconnect.88
88. For critical commentary, see Monica Horten, “Telecoms Package: The Verdict” (http://www.iptegrity.com 13 November 2009)