The case of "Foster v British Gas" demonstrates the court's willingness to confer the rights of a directive unto individuals, for the purpose of this case the court purported that any government organisation, nationalised company or company working in the public sector can be considered as a public body for the purpose of implementing vertical direct effect when a more narrow reading of the case might infer that horizontal direct effect would need to required for application. This is demonstrated in the case of "Van Colson" where the court established the practice of 'reading in' a directive into existing national law to realise the directive's effect – despite it not actually being a part of the legislation. Further case law to demonstrate this practice is "Francovich v Italy" where action could be taken against the government by an individual for their failure to implement a directive and the subsequent loss of rights suffered in court.