The +Italic Simmenthal -Italic judgment of 1978 shed light for the first time on the tension between the centralised model of judicial review of legislation +Superscript 1 -Superscript and the principle of primacy of EU law. 2 However, it has only been in recent years that the difficult coexistence of the two systems has become evident, so much so that it now questions the fundamental role of the centralised review of legislation as hitherto known in Europe, and perhaps, in the long run, its very survival. 3 Technically, what is particularly challenged by the principle of primacy is a specific way of access to constitutional courts, through a question of constitutionality raised by ordinary courts. Obviously, this is not just a question of pure procedure. What is at stake is the constitutional courts' 'core business', i.e. the protection of fundamental rights that might be taken away from them to the benefit of ordinary courts in partnership with, and under the guidance of, the Court of Justice