On July 10, 2014, the Court of Justice of the European Union (the Court) issued [3] a preliminary ruling in Naime Dogan v. Bundesrepublik Deutschland, finding unlawful the introduction of legislation requiring a basic knowledge of the German language as a condition for the issue of a visa to a non-resident spouse wishing to join his or her sponsor in Germany.  The Court held that the legislation constituted a “new restriction” breaching the “standstill” clause in Article 41(1) of the Additional Protocol [4] (unofficial translation) to the Agreement Establishing an Association Between the European Economic Community and Turkey [5], which prohibits the introduction of new restrictions on the freedom of establishment or freedom to provide services.  According to the press release [6], the Court held that the legislation was not justified by an overriding reason in the public interest because “the language requirement at issue goes beyond what is necessary” to achieve the objective of “the prevention of forced marriages and the promotion of integration.”