Mixed disputes are maritime boundary delimitation disputes that involve a dispute in relation to the sovereignty or other rights over continental or insular land territory, even if it centers on the precise location of a baseline . Undoubtedly, the International Court of Justice (ICJ) can adjudicate over mixed disputes owing to its broad jurisdiction articulated inArticle 36 of its Statute. However, what about the International Tribunal for the Law of the Sea (ITLOS) namely established in 1982 United Nations Convention on the Law of the Sea (UNCLOS)? Can ITLOS adjudicate over mixed disputes, or is its jurisdiction limited only to the law of the sea disputes concerning the interpretation or application of UNCLOS?
This blog post assumes that ITLOS possesses the jurisdiction to adjudicate over mixed disputes. The author will demonstrate that this jurisdiction can be exercised by utilizing an a contrario reading ofArticle 298(1)(a)(i) of UNCLOS, the principles of effectiveness, and the consensual jurisdiction of ITLOS.
Finally, after establishing jurisdiction, the author will briefly highlight how ITLOS is also empowered to apply requisite laws to dispense mixed disputes, even though UNCLOS is the constitution of the seas and not land.
Possible Bases for Jurisdiction over Mixed Disputes
1. An a contrario reading of Article 298(1)(a)(i) of UNCLOS
I commence with this basis because it is perhaps the most compelling argument favoring the position that ITLOS can exercise jurisdiction over mixed disputes.
Having appeared in the first contentious case of the Permanent Court of International Justice, the SS Wimbledon case , an a contrario reading “can be summarized by the Latin principle ubi lex voluit, dixit; ubi noluit, tacuit,” which means “what the law wishes, it states, what the law does not want, it keeps silent upon.”  Simply put, an a contrario reading seeks to ascertain the parties’ intentions by examining the text and context of the treaty’s provisions . It, therefore “excludes an interpretation wider than the literal one, and it rebuts any analogical or extensive interpretation.” 
An excellent illustration of an a contrario reading was manifested in the ICJ judgment passed in the Tehran Hostages case . In the Tehran Hostages case, it was argued that sinceArticle 12 of the United Nations Charter expressly disallows the General Assembly from making recommendations pertinent to disputes simultaneously as the United Nations Security Council is executing its functions under the United Nations Charter, the ICJ should also, by analogy, be prohibited from adjudicating over a dispute which the United Nations Security Council is actively engaging. This argument was not accepted by the ICJ on the ground that, inter alia:
“WhereasArticle 12 of the Charter expressly forbids the General Assembly to make any recommendation about a dispute or situation while the Security Council is exercising its functions in respect of that dispute or situation, no such restriction is placed on the functioning of the Court by any provision of either the Charter or Statute.”
Similar to Article 12 of the UN Charter,Article 298(1)(a)(i) of UNCLOS includes an exclusionary clause expressly excluding mixed disputes from conciliation under Annex V, Section 2. However, no such exclusion is made concerning the compulsory jurisdiction of ITLOS. Therefore, an a contrario reading of Article 298(1)(a)(i) of UNCLOS warrants that the exclusionary clause be read as applying only to compulsory conciliation under Annex V, Section 2 and not the compulsory jurisdiction of ITLOS.
This position is supported by the travaux préparatoires, which reflects that the clause contained in Article 298(1)(a)(i) was inserted because, “some States feared that under the guise of a dispute relating to a sea boundary delimitation, a party to a dispute can bring up a dispute involving claims to land territory or an island.”  Interestingly, however, the travaux préparatoires does not disclose that similar fears “were expressed with regard to mixed disputes being heard by the compulsory procedures specified in Section 2.”  Neither did the question of making the exclusionary clause applicable to the mandatory procedures specified in Section 2 with regard to States not making Article 298 declarations ever arose at the Third Conference. 
An a contrario reading of Article 298(1)(a)(i) also finds support from past judges of ITLOS and international lawyers alike. For example, Judge Rao posited that where no Article 298(1)(a)(i) declaration is made, “a court or tribunal would be competent to deal with mixed disputes.”  He explained that Article 298(1)(a)(i) should be given its most natural meaning, which is that the exclusionary clause only applies to compulsory conciliation. Accordingly, the logical corollary thereof would be that “since the exclusionary clause does not apply to a compulsory procedure provided for in section 2 of Part XV, a mixed dispute……falls within the jurisdiction of a compulsory procedure.”  Judge Rao adopted this reasoning again, without reservation, in conjunction with the then Registrar of ITLOS, Phillip Gautier, at para 3.049 in their joint text, The International Tribunal for the Law of the Sea: Law, Practice and Procedure. 
Judge Treves  shares similar sentiments. According to him, read an a contrario, Article 298(1)(a)(i), supports the view that, “when no declaration has been made in accordance to Article 298(1)(a)(i), a dispute on delimitation of a maritime area necessarily involving the concurrent consideration of a dispute concerning sovereignty or other rights over land can be brought to the court or tribunal having jurisdiction under Article 287.”  Judge Treves further added that the argument an a contrario sensu “seems sufficient to discard the view that whenever a case presents a land aspect, compulsory jurisdiction of the courts and tribunals competent under the Convention should automatically be excluded.” 
While Alan Boyle respects that a State has the option of excluding such disputes from compulsory jurisdiction under Article 298(1)(a)(i), he contends that “the implication must be that, where this option is not exercised, a tribunal, including the ITLOS, may, if necessary, deal with both the land and the maritime dispute.” 
At this juncture, it is pertinent to note that an a contrario reading of Article 298(1)(a)(i) arose for discussion in the Award in the Arbitration regarding the Chagos Marine Protected Area.  The detailed facts of the case do not warrant repetition. However, in Chagos, Mauritius argued that to determine as to whether the United Kingdom’s declaration of the Marine Protected Area breached the provisions of UNCLOS, the Tribunal was required to determine who had sovereignty over the Chagos Archipelago (i.e., who was the “Coastal State” underArticles 2, 55, and 76 of UNCLOS). According to Mauritius, the Tribunal had jurisdiction to determine such an issue via an a contrario reading of Article 298(1)(a)(i). Interestingly, the United Kingdom did not disagree with an a contrario reading of Article 298(1)(a)(i) within the context of mixed disputes  but rather disagreed that it could be applied outside a maritime boundary delimitation dispute such as the present one, which concerned the establishment of a Marine Protected Area. The Tribunal favored the latter contention and stated that:
“Article 298(1)(a)(i) relates only to the application of the Convention to disputes involving maritime boundaries and historical titles. At most, an a contrario reading of the provision supports the proposition that an issue of land sovereignty might be within the jurisdiction of a Part XV court or Tribunal if it were genuinely ancillary to a dispute over a maritime boundary or a claim; of historic title.” 
Consequently, it can be concluded that the Tribunal in Chagos supports an a contrario reading of article 298(1)(a)(i). However, as indicated, they agreed with the United Kingdom that this was not the case it could be applied. 
2. The principle of effectiveness
Coined by Sir Gerald Fitzmaurice , the principle of effectiveness warrants that we effectively construe what the parties actually agreed on as to give a particular instrument its full effect. 
As perArticle 288(1) of UNCLOS, ITLOS only has jurisdiction over disputes concerning the interpretation or application of UNCLOS. Strictly interpreted, this means that ITLOS can only adjudicate maritime disputes. However, because land dominates the sea  in most, if not all maritime boundary delimitation disputes, there will exist a relationship with a dispute in relation to sovereignty or other rights over continental or insular land territory, even if it centres on the precise location of a baseline.
As Boyle puts it, there is no “neat division between a law of the sea case and other types of disputes. In some cases, the delimitation of a maritime boundary may necessarily require a decision concerning disputed sovereignty over land, for example, where an island is used as a basepoint for an EEZ or continental shelf claim.” 
Therefore, when these mixed disputes arise, those in favor of the principle of effectiveness argue that to give full effect to the resolution of maritime delimitation disputes, ITLOS must be deemed competent to adjudicate over land sovereignty disputes. Otherwise, the provisions relating to maritime delimitation will be stripped of their total reach.
For example, Judge Rao , argues that there is nothing in UNCLOS which excludes such competence . He further posited that to dismiss a mixed dispute because there are “no substantive provisions in the convention on land sovereignty issues, would be to denude the provisions of the convention relating to sea boundary delimitations of their full effect and of every purpose and reduce them to an empty form.” 
Judge Eiriksson seems to have agreed with Judge Rao. He makes the point that notwithstanding the general focus of article 288 of UNCLOS as a “treaty tribunal” dealing with questions of interpretation or application of the convention and other international agreements, “questions in relation to customary international law and other questions outside the scope of the convention and other agreements would be addressed, was it necessary to decide on the question raised”.  Thus, it can be argued that he agrees with the principle of effectiveness to the extent that he does not believe that the Tribunals were given the power to adjudicate over UNCLOS disputes without the requisite powers to dispose of non-UNCLOS disputes as is necessary. Hence, it is not surprising that Judge Eiriksson goes on to say that, “for example, questions of maritime delimitation would often depend on questions of sovereignty over land territory and the Tribunal could not be expected to refrain from pronouncing on such questions in deciding on the matter before it.” 
During his tenure as President of ITLOS and in a statement to the Informal Meeting of Legal Advisors of Ministers of Foreign Affairs, Judge Wolfrum  posited that the competence of the tribunals under their compulsory jurisdiction to “deal with the main claim that maritime delimitation be effected according to Articles 15, 74 or 83 includes the associated question of delimitation over land or islands.”  This approach, according to him, “is in line with the principle of effectiveness and enables the adjudicative body in question to truly fulfill its function,” since “it is apparent that maritime boundaries cannot be determined in isolation without reference to the territory.” 
More recently, Peter Tzeng in his piece, Supplemental Jurisdiction under UNCLOS, posited that “the text of Article 288(1) provides that UNCLOS tribunals “shall” have jurisdiction over UNCLOS disputes, but it does not expressly state that they “shall not” have jurisdiction over non-UNCLOS disputes. As a result, if one applies the principle of effectiveness, it appears that UNCLOS tribunals should be able to exercise jurisdiction over any non-UNCLOS disputes whose resolution would help give full effect to the resolution of the UNCLOS dispute.” 
Undoubtedly, the principle of effectiveness cannot be ignored since, apart from the fact that at least two former Presidents of ITLOS have endorsed its application, it is a plausible route to be utilised to resolve mixed disputes.
3. The consensual jurisdiction of ITLOS
For this blog, the consensual jurisdiction of ITLOS refers to those instances where its jurisdiction is seized following the conclusion of an agreement between two States providing for its seisin . Therefore, hereunder, we are not addressing those instances where unilateral seisin of the Tribunal is made based on the fact that both State parties to the dispute have made Article 287 declarations under UNCLOS.
Be that as it may, the main contention hereunder is that, once the parties agree to submit a mixed dispute to the Tribunals, then that agreement will form the basis for the jurisdiction of ITLOS, thus enabling it to adjudicate over the mixed dispute.
In this regard, it is submitted that Articles 288(2) of UNCLOS and Articles 21 and 24(1) of the Statute of ITLOS provide for the consensual jurisdiction of ITLOS.
- Article 288(2) provides: “A court or tribunal referred to inArticle 287 shall also have jurisdiction over any dispute concerning the interpretation or application of an international agreement related to the purposes of this Convention, which is submitted to it in accordance with the agreement.”
- Article 21 of Statute of ITLOS provides: “Thejurisdiction of the tribunal comprises all disputes and all applications submitted to it in accordance with this Convention and all matters expressly provided for in any other agreement which confers jurisdiction on the Tribunal.”
- Article 24(1) of Statute of ITLOS provides: “Disputes are submitted to the Tribunal, as the case may be, either by notification of a special agreement or by written application, addressed to the Registrar. In either case, the subject of the dispute and the parties shall be indicated.”
In analyzing the provisions above, Alan Boyle notes the distinction between the usage of the phrases “any other agreement” with respect to Article 21 of the Statute of ITLOS and “international agreements related to the purpose of the Convention” in Article 288(2) of UNCLOS. According to Boyle, the implication of this difference with respect to wording appears to be that an “agreement” under article 21 “need not be a treaty nor relate to the purposes of the Convention.”  Consequently, Boyle contends that “the broadest view of the tribunal’s consensual jurisdiction is that it may hear any case brought to it by the parties to a dispute, regardless of whether any law of the sea issue is involved.” 
Judge Wolfrum takes the view that the employment of special agreements under article 24(1) of the Statute of ITLOS can invoke the consensual jurisdiction of ITLOS to adjudicate over mixed disputes. According to him, “with regard to jurisdiction based on a special agreement, the area to be delimited will normally be determined in the special agreement between the parties and nothing prevents them from submitting to the Tribunal any maritime delimitation case involving issues regarding land boundaries or cases involving disputed sovereignty over islands.” 
Judge Tullio Treves asserted that “the agreement of the parties may give jurisdiction to a court or tribunal different from the one that would be competent underArticle 287.”  He took this position because while the convention introduces compulsory jurisdiction of adjudicating bodies over maritime boundary delimitation disputes, it does “not exclude that procedures namely entailing binding decisions be set in motion by agreement.”  As such, he posited that it must be agreed that ITLOS “should not be seen, as it sometimes is, as a compulsory- jurisdiction-only tribunal. It is open to examining cases submitted by agreement.”  Buga adds that notwithstanding the convention’s silence on territorial issues, “two parties can always agree to submit to a tribunal territorial sovereignty question together with maritime issues.” 
Notably, it can be argued that the consensual jurisdiction of the Annex VII tribunal, which shares the same jurisdiction as ITLOS underArticle 288 of UNCLOS, was already seized to dispense of a mixed dispute in the Bay of Bengal Maritime Boundary Arbitration.  In this particular case, inter alia, both parties had agreed that the Radcliffe Award had authoritatively defined the terminus of the land boundary between them.  However, they disagreed on the precise location of the land boundary terminus. Nevertheless, they agreed that the annex VII tribunal would have jurisdiction to identify the location of the land boundary terminus based on the Radcliffe Award of 1947, before resolving the maritime dispute.  Therefore, based on that agreement, the Tribunal proceeded to determine the precise location of the land boundary terminus. In so doing, they were not interpreting UNCLOS as they were established to do but applying the agreement. As such, this shows that indeed the parties can expand the jurisdiction of the tribunals under Article 287, including ITLOS, by way of agreement for had Bangladesh and India not agreed, the tribunal may have been faced with a jurisdictional objection.
Notably, Eiriksson contends that UNCLOS even provides for the utilization of the consensual jurisdiction by those State parties who made Article 298(1)(a)(i) declarations, exempting mixed disputes from compulsory jurisdiction. 
In this regard, he identifiesArticles 298(2) & (3) along with 299(1) of UNCLOS. Articles 298(2) & (3) of UNCLOS provide:
(2) “A State Party which has made a declaration under paragraph 1 may at any time withdraw it, or agree to submit a dispute excluded by such declaration to any procedure specified in this Convention.”
(3) “A State Party which has made a declaration under paragraph 1 shall not be entitled to submit any dispute falling within the expected category of disputes to any procedure in this Convention as against another State Party, without the consent of that party.” (emphasis added)
Article 299(1) of UNCLOS provides “A dispute excluded under article 297 or excepted by a declaration made under article 298 from the dispute settlement procedures provided for in section 2 may be submitted to such procedures only by agreement of the parties to the dispute.” (emphasis added)
Articles 298(2), (3), and 299(1) all permit the concerned parties to agree to allow the exempted disputes, including mixed disputes, to be once again justiciable by Part XV procedures.
Consequently, the position that mixed disputes can be adjudicated by ITLOS based on their consensual jurisdiction is vital.
What Law(s) Would ITLOS Use to Dispense Mixed Disputes?
Having established the bases of ITLOS’s jurisdiction over mixed disputes, one possible concern that remains is that UNCLOS has no substantive provisions that address sovereignty disputes. However, it is submitted that this is of no consequence because once ITLOS establishes that it has jurisdiction over the mixed dispute, resort can be made toArticle 293 of UNCLOS, which dictates that the applicable law to be used when adjudicating cases, is not only the convention but also other rules of international law not incompatible with the convention.
Indeed, the Preamble of UNCLOS does state that matters which are not regulated by the convention continue to be governed by the respective rules and principles of general international law. Article 293 enables ITLOS to use these rules and principles of general international law to aid in adjudicating its cases. Therefore, there is no doubt that if faced with a mixed dispute, ITLOS, being empowered to apply general international law, would be capable of resolving the same.
Notably, Article 293 was used by both ITLOS and the Annex VII tribunal to resolve an issue pertinent to the use of force, which UNCLOS does not govern. In particular, in the Saiga case  ITLOS stated that:
“In considering the force used by Guinea in the arrest of the Saiga, the Tribunal must take into account the circumstances of the arrest in the context of the applicable rules of international law. Although the Convention does not contain express provisions on the use of force in the arrest of ships, international law, which is applicable by virtue of Article 293 of the Convention, requires that the use of force must be avoided as far as possible and, where force is unavoidable, it must not go beyond what is reasonable and necessary in the circumstances. Considerations of humanity must apply in the law of the sea, as they do in other areas of international law.” (emphasis added)
Moreover, in the award in the arbitration regarding the delimitation of the maritime boundary between Guyana and Suriname  the Annex VII Tribunal accepted the reasoning of ITLOS when rejecting Suriname’s contention that they cannot adjudicate alleged violations of the United Nations Charter and general international law. In particular, it stated that the interpretation of Article 293 by ITLOS in the Saiga case was a reasonable one. 
There is no denying that the coast of a particular State influences its maritime entitlement, regardless of the extent. To accept the strong view expressed by some that ITLOS should not deal with cases concerning mixed disputes is to accept that some States may plead that the case involves a sovereignty dispute in an effort to escape UNCLOS. Some might wish to argue that you can avoid dealing, even with the location of a land boundary terminus, by beginning to draw the equidistance line from the sea and come in towards the land. As soon as you reach the disputed area, you stop there and call the non-delimited area, a gray area. 
However, how many States would want to go to court for a few meters and a large gray area? Sensibly speaking, they will want to have the Tribunals decide on the location of the land boundary terminus to get the maximum result from the delimitation. The Bay of Bengal Maritime Boundary Arbitration between Bangladesh and India is a case in point.114 Indeed, as I have highlighted, there are at least three (3) avenues vis-à-vis, an an a contrario reading of Article 298(1)(a)(i) the principle of effectiveness, and the consensual jurisdiction of the Tribunals, through which mixed disputes can be adjudicated.
Truthfully, I had hoped that this issue would be addressed in great detail in the incidental proceedings (preliminary objections) of the dispute concerning delimitation of the maritime boundary between Mauritius and Maldives in the Indian Ocean (Mauritius/Maldives). However, the Special Chambers at para 110 of their judgment only indicated that they consider:
“that a dispute, which requires the determination of a question of territorial sovereignty, may not be regarded as a dispute concerning the interpretation or application of the Convention under Article 288, paragraph 1, of the Convention.”
This position was perhaps taken because arguments in favor of its jurisdiction over such cases were not proffered by either of the parties to the dispute. Mauritius argued that there was no issue of sovereignty. As such, para 114 of the judgment indicates that the Special Chambers was only asked to recognise and respect the ICJ’s advisory opinion on the issue and proceed to delimit the maritime boundary. Whether this amounted to adjudication over a sovereignty dispute can be canvassed in another blog post.
Other questions that remain outstanding are: Does the sovereignty dispute’s magnitude matter? If yes, of what magnitude must it be about the maritime boundary delimitation dispute to become justiciable under the jurisdiction of ITLOS? Is it enough for the determination of the sovereignty dispute to be necessary for the determination of the maritime boundary delimitation dispute? Or, should the sovereignty dispute be both ancillary to and necessary to determine the maritime boundary delimitation dispute?
These can be canvassed in another post but undoubtedly, ITLOS can exercise jurisdiction over mixed disputes.
The views and opinions expressed in this blog are those of the author and do not necessarily reflect the official policy or position of his place of employment.
About the Author
Mr. Joshua Benn is an Attorney-at-Law and a fellow of the International Tribunal for the Law of the Sea and Nippon Foundation’s Capacity-Building and Training Program on Dispute Settlement Under the United Nations Convention on the Law of the Sea (‘UNCLOS’).
He is currently employed as a Legal Officer within the Frontiers Department of the Ministry of Foreign Affairs and International Cooperation, Guyana.
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Preferred Method of Citation
Joshua Benn, “ITLOS & Mixed Disputes: Untapped Jurisdiction” (IJPIEL, 26 January 2022)
 R. Wolfrum, Statement to the Informal Meeting of Legal Advisers of Ministries of Foreign Affairs, New York, 23 October 2006)
 SS “Wimbledon”, Judgments, 1923, PCIJ, Series A, No. 1
 (F. Macagno & D. Walton, “Arguments of Statutory Interpretation and Argumentation Schemes,” International Journal of Legal Discourse, 2017, Vol. 2, pages 47-83 (specifically page 54))
 (A. Yusuf & D. Peat “An a contrario interpretation in the Jurisprudence of the International Court of Justice,” Canadian Journal of Comparative and Contemporary Law, Vol. 3, pages 1-18 (specifically page 6))
 Supra 3
 United States Diplomatic and Consular Staff in Tehran, Judgment, I.C.J. Reports 1980, p.3
 Center for Oceans Law and Policy, “Settlement of Disputes, General and Final Provisions and related Annexes and resolutions,” United Nations Convention on the Law of the Sea 1982, A Commentary, 1989, Vol. 5, 536 pages (specifically page 117, para 298.20)
 (Chandrasekhara Rao, P. “Delimitation disputes under the United Nations Convention on the Law of the Sea: settlement procedures” in: T.M. Ndiaye, R. Wolfrum (eds), C. Kojima (ass. Ed.), Law of the Sea, Environmental law and Settlement of Disputes, Liber Amicorum Judge Thomas A. Mensah, (Leiden/Boston, Martinus Nijhoff, 2007), pp. 877-897 (specifically page 888)
 Id. p.892
 Id. p.890
 Supra 7 – p. 92
 Tullio Treves served as a Judge of ITLOS from 1996 to 2011
 (T. Treves, “‘Compulsory’ Conciliation in the UN Law of the Sea Convention,” in: V. Götz, P. Selmer and R. Wolfrum (eds), Liber Amicorum Günther Jaenicke-zum (Berlin: Springer, 1998), pages 611-629 (Specifically page 626)
 Id. p. 77
 (A. Boyle, “Dispute Settlement and the Law of the Sea Convention: Problems of Fragmentation and Jurisdiction”, International and Comparative Law Quarterly, 1997, Vol. 46, pages 37-54 (Specifically page 49)
(Between Mauritius and the United Kingdom of Great Britain and Northern Ireland, 18 March 2015, Reports of International Arbitral Awards, Volume XXXI pp. 359-606
 Id. para 195
 Id. para 218
 Id. para 219
 (Sir G. Fitzmaurice, “The Law and Procedure of the International Court of Justice 1951-4: Treaty Interpretation and Other Treaty Points”, British Year Book of International Law, 1957, V. 33, pages 202-293, (specifically page 211)
 (Orakhelashvill, The Interpretation of Acts and Rules in Public International Law, Oxford, 2008, 593 pages (specifically page 397)).
 (Bay of Bengal Maritime Boundary Arbitration between the People’s Republic of Bangladesh and the Republic of India, Award of 7 July 2014, Report of International Arbitral Awards, Volume XXXII pp.1-182 – para 279)
 Supra (specifically page 891)
 Id. page 891
 Judge Gudmundur Eiriksson served as a Judge of ITLOS from 1996 to 2002. (Eiriksson, The International Tribunal for the Law of the Sea, The Hague, London, Boston, 2000, 387 p. (specifically page 113)
 Judge R. Wolfrum served as Judge of ITLOS from 1996 to 2017
 P. Tzeng, “Supplemental Jurisdiction under UNCLOS,” Houston Journal of International Law, 2016 Vol. 38, pages 499-57, (specifically page. 562)
 (Eiriksson, Op. Cit., p. 123. See also M. García-Revillo, The Contentious and Advisory Jurisdiction of the International Tribunal for the Law of the Sea, Netherlands, 2015, 341 pages (Specifically pages 7-202)
 Supra, Wolfrum, Op. Cit., p.5
 (T. Treves, “What do the United Nations Convention and the International Tribunal for the Law of the Sea offer as regards maritime delimitation disputes?” in: R. Lagoni and D. Vignes (eds.), Maritime Delimitation, (Martinus Nijhoff, 2006), pages 63-78 (Specifically page 79)
 Irina Buga, “Territorial Sovereignty Issues in Maritime Disputes: A jurisdictional Dilemma for Law of the Sea Tribunals,” International Journal of Marine and Coastal Law, 2012, Vol. 27, pages 59-96 (Specifically page 67)
 (Tthe Bay of Bengal Maritime Boundary Arbitration between the People’s Republic of Bangladesh and the Republic of India, Award of 7 July 2014, Report of International Arbitral Awards, Volume XXXII pp.1-182)
 Id. para 58
 Id. para 67
 (MIV “SAIGA” (No. 2) (Saint Vincent and the Grenadines v. Guinea), Judgment, ITLOS Reports 1999, p.I0.)
 (Award of 17 September 2007, Report of International Arbitral Awards, Volume XXX pp.1-144)
 Id. para 406
 (See N. Klein, “Dispute Settlement in the UN Convention on the Law of the Sea”. Cambridge, United Kingdom, the Pitt Building, 2005, 369 p (specifically page 260); Bernard H. Oxman, “International Maritime Boundaries: Political, Strategic and Historical Considerations”, University Miami Inter-American Law Review, 1995, Volume 26, pp.243-296 (Specifically page 20)