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Hilson takes a close look at the unreported case C-387/97 Commission v Hellenic Republic. The case concerned Greece being in breach of its obligations after flytipping both toxic and non-toxic waste into the Kouroupitos ravine, only 200 metres from the Mediterranean Sea. Enforcement proceedings began in 1990 and were being ignored in 1993. Fresh proceedings began under Article 228 (previously Article 171) and recommendations for penalty payments began. Hilson discusses environmental justice and explores the issues behind who pays the fine, as well as comparing Article 228 and state liability. 2001 3(2) Env L.Rev 131