Steymann v Staatssecretaris van Justitie

He joined the Rajneesh movement, a religious group who provided for each other's material needs through commercial activity including running a discothèque, a bar, and a launderette.

In turn, the Bhagwan Community provides for the material needs of its members, including pocket-money, irrespective of the nature and the extent of the work which they do.

12 In a case such as the one before the national court it is impossible to rule out a priori the possibility that work carried out by members of the community in question constitutes an economic activity within the meaning of Article 2 of the Treaty.

In so far as the work, which aims to ensure a measure of self-sufficiency for the Bhagwan Community, constitutes an essential part of participation in that community, the services which the latter provides to its members may be regarded as being an indirect quid pro quo for their work.

13 However, it must be observed, as the Court held in its judgment of 23 March 1982 in Case 53/81 Levin v Staatssecretaris van Justitie (1982) ECR 1035, that the work must be genuine and effective and not such as to be regarded as purely marginal and ancillary.