A fundamental tenet of Plender’s contention that the ‘incipient’ citizen can be seen to have emerged from the early case law on free movement is that the ‘worker’ can be construed as the early prototype of the citizen. This ties in particularly with the linkages made between market citizenship and EU Citizenship.1 The legal evolution of the ‘worker’ has arguably been the foundation stone of all free movement of persons law upon which the later temple of citizenship was built. This is particularly so as the concept of the ‘worker’ has been incorporated to include large parts of the law or, in the alternative, has been used as a counterpoint to either dovetail with or juxtapose against other aspects of free movement law (such as on establishment).