This principle concerns the rights of individuals or companies in Member States to rely on the law affecting them in a certain way. Provided such reliance is reasonable and in good faith, they should not be allowed to suffer loss as a result of a change in that law. . A linked principle is that of non-retroactivity. In the absence of clear indication to the contrary, legislation will be presumed not to affect actions which took place before it was passed. A particular application of this general rule is that if an activity was not illegal when carried on, an individual may not thereafter be held criminally liable for it by a subsequent change in the law. Thus in Pretore di Saló case 14/86 the ECJ held that Directive 78/659 concerning water standards for freshwater fish could not impose criminal sanctions on Italian nationals without having been properly implemented by the Italian authorities. When fulfilling their obligations for ‘sympathetic interpretation’ the national courts must take care not to violate these rights (Kolpinghuis Nijmegen case 80/86). Arguments based on these principles were put forward by the motor industry during the development of the new Directive on end-of-life vehicles, in an effort to resist an obligation to recover and recycle older vehicles which were not designed with this in mind