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The Empire Strikes Back: Yukos-Russia, 1-1

Published on May 26, 2016        Author: 

In the latest chapter to the ever fascinating Yukos dispute, Russia recently secured a victory in the District Court of The Hague, which set aside the US $ 50 billion awards issued two years ago by an arbitral tribunal constituted under the Energy Charter Treaty (ECT). The crucial issue was whether Russia was bound to arbitrate under the ECT’s provisional application clause. The arbitral tribunal, comprised of Y. Fortier, C. Poncet, and S. Schwebel, said ‘yes’; three Judges of The Hague District Court, D. Aarts, I.A.M. Kroft and H.F.M. Hofhuis, said ‘no’. It will be argued here that the District Court put too much emphasis on the domestic constitutional legality of the ECT’s provisional application, at the expense of investors who were entitled to believe that Russia had agreed to such provisional application.

Earlier Episodes of the Dispute

The dispute between the now defunct oil company Yukos and Russia has grown into a protracted legal battle, involving a number of investment arbitration tribunals, the European Court of Human Rights, and domestic courts in various jurisdictions. At one point the largest oil company in Russia, Yukos was liquidated in 2006 by the Russian authorities in the process of enforcing tax reassessments, which allegedly demonstrated that Yukos had engaged in large-scale tax evasion. According to Yukos and many international observers, the tax reassessments were a pretext for regaining control over the Yukos imperium and bringing down its influential CEO Mikhail Khodorkovsky.

Foreign shareholders of Yukos have brought investment arbitration claims against Russia under various treaties, including the 1989 UK-Russia BIT (award), the 1991 Spain-Russia BIT (award), and the ECT. The investors have been largely successful, obtaining their biggest win on 18 July 2014, when a tribunal constituted under the auspices of the Permanent Court of Arbitration issued three awards granting a total of US $ 50 billion to the claimants, on the ground that Russia had breached the expropriation provision of the ECT (Article 13). These awards have now been set aside by The Hague District Court (some reactions here and an analysis of the consequences here).

Provisional Application

Whereas previous battles focused on whether the Russian tax reassessments and subsequent enforcement measures were mala fide, the crucial issue at the current stage is whether the arbitration clause of the ECT (Article 26) was actually applicable with regard to Russia, which signed but never ratified the treaty, and withdrew from it in 2009 (not the only Member State to do so).

Pursuant to Article 45 ECT, a signatory State agrees to apply the treaty provisionally ‘pending its entry into force’, ‘to the extent that such provisional application is not inconsistent with its constitution, laws or regulations’ (para. 1) and if that State had not objected to provisional application at the moment of signing (para. 2(a)). Given the fact that Russia had not issued such an objection (unlike Norway, Iceland and Australia), the dispute focused on whether a provisional application of the ECT was consistent with Russian law.

Consistency of What: the Piecemeal v. the All-or-Nothing Approach

In spite of its apparently casual wording, Article 45(1) or ‘the Limitation Clause’ raises complicated questions of interpretation. A first point of disagreement between the arbitral tribunal and the Hague District Court is what exactly needs to be consistent with Russian law: the idea of provisional treaty application as such, or the provisional application of specific treaty provisions. According to the court (5.18), the issue of consistency should be assessed separately for any treaty provision to be applied provisionally (‘piecemeal approach’), and not for the entire treaty as a whole (‘all-or-nothing approach’), as the tribunal had found (like the tribunal in Kardassopoulos v. Georgia). While the tribunal and the court emphasized different textual elements of Article 45(1), their conclusions also demonstrate different preoccupations. According to the tribunal, the piecemeal approach would ‘create unacceptable uncertainty in international affairs’, allowing a State to opt out of provisional application at any time, in particular after a dispute had arisen (para. 315 Interim Awards). The court, on the other hand, emphasized that Article 45(1) serves to avoid conflicts between domestic law and international obligations (5.19). The provision might indeed cause some uncertainty, but this was the choice of the States party to the ECT and apparently justified by the wish to prevent inconsistencies between international and domestic law.

What Constitutes an Inconsistency?

On the basis of its piecemeal approach, the Hague District Court focused on whether the arbitration clause of the ECT was consistent with Russian law. In this context, the Yukos shareholders argued that an inconsistency between Article 26 and domestic law could only exist in the form of an explicit prohibition under Russian law. The court took a wider approach, ruling that a provisional application of the ECT’s arbitration clause would also be inconsistent with Russian law if there would be no legal basis for this type of dispute settlement. The court would also find an inconsistency if investor-state arbitration did ‘not harmonise with the legal system’ or if it were ‘irreconcilable with the starting points and principles that have been laid down in or can be derived from legislation’ (5.33).

Applying this framework of analysis, the court found that Russian law did not provide ‘a separate legal base’ for investor-State arbitration (5.58). It did not attach much weight to the fact that in 1996 the Russian government had stated that the provisions of the ECT were ‘consistent with Russian legislation’ (5.60). Instead, the court pointed at the history of the ratification of some other investment treaties, demonstrating a parliamentary concern that Russian law did not contain a legal basis for investment arbitration (5.64).

State Sovereignty v. the Legitimate Expectations of the Investor

Provisional application is an exception to the normal rules on how treaties enter into force (reports of the ILC’s Special Rapporteur here). Whereas the period between signing and ratifying normally allows States to reconsider the matter and verify whether domestic law needs to be adapted, a provisional application provision purports to bind States already while these assessments are being made. This is a serious intrusion into State sovereignty, which explains why the ECT contains a Limitation Clause and why it allows signatories to opt out by means of a declaration.

State sovereignty, however, is not the only interest at stake in the context of provisional application, and needs to be balanced against the legitimate expectations of other parties and, in the case of the ECT, investors. When Russia signed the ECT without making a declaration under Article 45(2), it might be thought that it created a presumption of compatibility between the ECT and domestic law. Neither the tribunal nor the court followed the shareholders’ argument that the absence of a declaration under Article 45(2) precluded Russia from invoking the Limitation Clause. However, Russia’s choice not to signal any objections to provisional application but to wait until a claim was filed, sheds doubts on the credibility of the defence. This is even more problematic because the alleged inconsistency concerns ambiguous provisions that seem to allow for legitimate disagreement as to whether they allow investor-State arbitration.

The Hague District Court put a strong emphasis on the importance of the domestic separation of powers. Noting that only the Russian Parliament possesses legislative powers, the court concluded that parliamentary approval was necessary for the creation of a form of dispute resolution which did not have a legal basis in Russian law (5.93). This argument seems to revert back to the question of whether the principle of provisional application is acceptable as such. One could reply that the choice to adopt a provisional application provision in a treaty already means that the signatory States temporarily circumvent the domestic separation of powers, and that they may have good reasons to do so.

Tribunals v. Courts

It is tempting to consider other, more fundamental reasons why the Hague District Court might have decided to set aside the awards. First, since Article 45(1) makes provisional application conditional on domestic law, the court may have felt a need to defer to Russia’s interpretation of its own laws and to follow its argument of inconsistency. Second, it is probable that a court in the Netherlands – with its strong tradition of parliamentary sovereignty – is relatively susceptible to Russia’s arguments concerning the domestic separation of powers. Third, and perhaps most importantly, it is striking that the arbitral tribunal on the one hand and the District Court on the other seem to approach the State in a different manner. The court appears well-disposed towards the State, sharing Russia’s alleged concern over the domestic constitutionality of the provisional application of the ECT, whereas the tribunal is more critical, suggesting doubts as to whether Russia’s invocation of Article 45(1) is sincere and credible. Arguably, the different approaches demonstrate differences between the preoccupations of arbitral tribunals and courts (not only within host states) and the ways in which they balance State sovereignty against investor interests.

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Extra-Territorial Claims in the “Spider’s Web” of the Law? UK Supreme Court Judgment in Ministry of Defence v Iraqi Civilians

Published on May 25, 2016        Author: 

Over the past decade, the direction of travel of jurisprudence by English courts has significantly departed from an earlier position that considered the acts of the UK government in the exercise of foreign relations to be a non-justiciable area, and shifted towards scrutiny of the impact of UK foreign policy decisions on individuals (see Al Rawi v Secretary of State for Foreign and Commonwealth Affairs [2008] QB 289; the Binyam Mohamed case, and more recently the discussion of crown act of state doctrine in Serdar Mohammed v Secretary of State for Defence). After all, as stated by Lord Sumption back in an address at the London School of Economics in 2012, “the acts of the executive are by definition justiciable in its own courts”. The most significant factor for such a shift, as Lord Sumption noted, was the enactment into English Law of the European Convention on Human Rights (“ECHR”).

Despite this shift in the judicial attitude with regard to review of acts of the executive in foreign affairs, jurisdictional issues (ratione temporis) and time bars are proving to be hurdles in the path of claimants bringing claims with regard to acts engaged in by the UK government extraterritorially. The recent Supreme Court decision in Keyu and others v Secretary of State for Foreign and Commonwealth Affairs  [2015] UKSC 69 (“the Batang Kali massacre case” on which see this previous post) dealt with a temporal jurisdictional obstacle. The Supreme Court’s 12 May 2016 decision in Ministry of Defence (Respondent) v Iraqi Civilians (Appellant) [2016] UKSC 25 (“The Iraqi civilians case”) is another example of a hurdle faced by claimants, this time in the guise of a time bar.

While the Batang Kali massacre case was concerned with the Supreme Court’s interpretation of public international law rules, (quite centrally, with the duties Article 2 ECHR imposes on the UK in the context of inquiries), the decision in the Iraqi civilians case concerned English private international law, and turned on a point of interpretation of The Foreign Limitation Periods Act 1984.

In the Iraqi civilians case, the Supreme Court gave judgment in relation to 14 lead claimants (in claims by over 600 Iraqi citizens), who had alleged unlawful detention and/or physical maltreatment at the hands of British armed forces in Iraq between 2003 and 2009.

The Supreme Court held, applying Iraqi limitation law, that the claims of the Iraqi civilians in England were time-barred. It dismissed the appeal. This post addresses the central holding of this case. Read the rest of this entry…

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Conferring ‘Market Economy Status’ to China in the EU – A Mission Impossible?

Published on May 23, 2016        Author: 

On May 9 of this year, the German and French ministries responsible for trade and economic affairs posted a joint letter to EU Trade Commissioner Cecilia Malmström. The document outlines “Common Core Demands from Germany and France on modernizing Trade Defence Instruments (TDI) of the European Union”. Among others, it requests that “the EU must further explore and use the possibilities of China’s WTO Accession Protocol not to use the standard calculation methodology to the extent the producers under investigation can not clearly show that market economy conditions prevail in the industry producing the like product with regard to the manufacture, production and sale of that product [emphasis added].”

The phrase highlighted in this quote is identical to language contained in Art.15(a)(ii) of China’s Accession Protocol (CAP) to the WTO. The provision is set to expire on December 11, 2016. This very fact has generated fierce debates in Europe and the United States that increasingly conflate the legal with the political dimension of the issue. The purpose of this post, in this context, is to scrutinize the legal effect of the expiry of the said provision on EU anti-dumping law and practice vis-à-vis China.

Three days after the Franco-German initiative, the European Parliament (EP) passed a resolution on “China Market Economy Status” with broad inter-party support amidst manifestations of steel workers and trade union leaders outside the plenary in Strasbourg. “[A]s long as China does not meet all five EU criteria required to qualify as a market economy”, the resolution states, “the EU should use a non-standard methodology in antidumping and antisubsidy investigations on Chinese imports (…), in accordance with and giving full effect to those parts of Section 15 of China’s Accession Protocol which provides room for the application of the non-standard methodology”. In consequence, the EP “calls on the Commission to make a proposal in line with this principle”.

This post questions the legal assumptions that the political positions quoted above rely on. The remainder of this post demonstrates that Art.15 CAP does not, after December 11, 2016, allow for the use of non-standard methodologies for price comparisons in anti-dumping investigations that are inconsistent with the provisions of the WTO Anti-Dumping Agreement (ADA). Should the Union follow the path to protectionism recommended by Berlin, Paris, and the EP, the EU will unmistakably violate its obligations under the ADA. In order to comply with its WTO obligations after December 11, 2016, in contrast, EU institutions need to bring EU secondary legislation and future anti-dumping measures against Chinese producers into conformity with the ADA. It is beyond doubt otherwise that the EU will be subject to a larger number of unfavorable legal decisions adopted by the WTO Dispute Settlement Body (DSB). In the aftermath of these decisions, in case of non-compliance, the EU will be confronted with hefty retaliatory measures authored by China and authorized by the WTO DSB.

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Announcements: Inaugural lecture and workshop in Maastricht; CfS Melbourne Journal of International Law; CfS Groningen Journal of International Law

Published on May 22, 2016        Author: 

1. Inaugural lecture and workshop in Maastricht. The workshop ‘A State-Centric International Legal System?’ will run from 27 May 2016 at the School of Business and Economics, Maastricht University. It brings together leading scholars in international law, human rights and EU law. They will debate the challenges of a state-centric design of international law. The debate will be divided into two panels. One will address state-centrism in international law from the perspective of the rules governing the use of force, while the other one will be conceptual in nature. The debate will be critically discussed and moderated by members of the Maastricht Law Faculty. Confirmed speakers include Prof Erika de Wet (Pretoria), Prof Katja Ziegler (Leicester), Prof Jean d’Aspremont (Manchester), Prof Cedric Ryngaert (Utrecht), Dr Christina Eckes (Amsterdam) and Prof Cees Flinterman (Maastricht). The workshop will be followed by Prof Vidmar’s inaugural lecture: Wrongfulness, Responsibility and Defences in International Law. Participation is free of charge, but please register

2. Melbourne Journal of International Law Call for Submissions. The Editors of the Melbourne Journal of International Law (‘MJIL’), Australia’s premier generalist international law journal, are now inviting submissions for volume 17(2) by 1 July 2016. This issue will have a special focus on the legal implications of the Trans-Pacific Partnership, and space will also be available for articles on other issues of international law. Submissions and inquiries should be directed to law-mjil {at} unimelb.edu(.)au. For more information, please see here.

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Leap Ahead or More of the Same? The European Commission’s Proposed Revisions to the Dublin System

Published on May 20, 2016        Author: 

On 4 May, 2016, the European Commission published a series of proposals in the field of Home Affairs, including proposed revisions to the contentious Dublin Regulation. This package of proposals signals the start of a process of revising the Common European Asylum System (CEAS), the recast instruments which came into force over the last two years. The need for such an upgrade is evidenced by the EU Member States’ disappointing response to the so-called ‘migration crisis’, but is also necessitated by fundamental flaws in the legal output stemming from the political compromise that led to the second version of the CEAS. Analysis of the EC’s proposed revisions reveal, however, that they would do little to remedy these flaws and are unlikely to gain support, not least due to a lack of solidarity among Member States.

Before evaluating the proposal, it ought to be noted that, of all the regional developments in the field of forced migration, the EU has by far the greatest law making competence (when compared to other regional bodies), as well as some of the more advanced instruments. The principles of protection that guide a regional response are incorporated in a series of binding instruments covering both substantive and procedural issues. This builds on the right to asylum explicitly guaranteed in Article 18 of the European Charter of Fundamental Rights. The last 12 months have seen significant pressure put on both European solidarity and the right to asylum from the number of applications received and from the response of both the EU (as an institution) and its individual Member States.

The Dublin System is possibly one of the most widely criticised elements of the CEAS—it is also widely misunderstood by the public, misrepresented by the media and misapplied by States. Furthermore, it is a flawed instrument that places excessive burdens on the Member States at Europe’s periphery, ignores the asylum seekers’ desires (and the linked agency to move farther), and (wrongly) assumes equal levels of protection across the various EU Member States. The system’s application has restrictions applied from its own founding legislation and through decisions of both the Strasbourg and Luxembourg Courts. An official evaluation of the Dublin system (to which the Commission Proposal refers) found that the underlying aim of reducing secondary movements has clearly failed, with 24% of applicants in 2014 having already sought asylum elsewhere (this figure does not even include people who whilst having been in other countries were not formally in the asylum system). Moreover, the regulation has limited impact on the distribution of applicants within the EU, given that net transfers in Dublin procedures are very few. The recent proposal by the EC aims to address some of these weaknesses but, in my view, fails to do so effectively.

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Is there a place for sovereign immunity in the fight against terrorism? The US Supreme Court says ‘no’ in Bank Markazi v. Peterson

Published on May 19, 2016        Author: 

The US Supreme Court’s judgment of 20 April 2016 in the case of Bank Markazi, aka The Central Bank of Iran, Petitioner v. Deborah Peterson, et al. highlights the increasingly isolated nature of US practice on sovereign immunity. As well as addressing issues of constitutional law, the judgment is also significant from an international law perspective; the highest jurisdiction of the US took a dangerous step toward the effective application of its terrorism exception to sovereign immunity.

The terrorism exception was introduced to the Foreign Sovereign Immunities Act of 1976 (FSIA) by an amendment made in 1996, and then further revised in 2008.  28 U.S.C. §1605A reads:

A foreign state shall not be immune from the jurisdiction of courts of the United States or of the States in any case […] in which money damages are sought against a foreign state for personal injury or death that was caused by an act of torture, extrajudicial killing, aircraft sabotage, hostage taking, or the provision of material support or resources for such an act if such act or provision of material support or resources is engaged in by an official, employee, or agent of such foreign state while acting within the scope of his or her office, employment, or agency.

The court can hear a case under this provision provided the foreign State has been designated as a State sponsoring terrorism by the Department of State and the claimant or the victim was at the time of the act a US national. This law aims at providing justice for victims through massive civil liability judgments, punishing foreign States committing or sponsoring terrorism, and discouraging them from doing so in the future.

In this post I focus not on the content of the judgment, but rather on the impact of US practice, which has recently seen all assets of the Iranian Central Bank located in the US subject to execution, on international law. Read the rest of this entry…

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Snippets on the UK and the ECHR

Published on May 18, 2016        Author: 

Some brief notices on the UK, the ECHR, the planned repeal of the UK’s Human Rights Act and its replacement with a British Bill of Rights that our non-UK readers in particular might find of interest: almost all is quiet on the Western front, but not quite. From today’s Queen’s Speech in Parliament we could only learn that the Government still plans to scrap the HRA and replace with the British Bill of Rights, but we still have no inkling about what exactly that would entail and when. Basically the whole matter is on hold at least while Britain ponders Brexit, and even then it is likely that the new Bill (after extensive consultations) will not make radical changes to the existing HRA framework, other than for appearances’ sake.

Cambridge’s Mark Elliott has more, as does Rightsinfo. Also at Rightsinfo, Adam Wagner and Rebecca Hacker have an excellent post with a bit of colourful statistics showing just how gentle Strasbourg has been to the UK in recent years – which demonstrates not only how much damage the UK has inflicted on the ECHR system over very little real-world intrusion in its affairs, i.e. mostly for petty domestic politics, but perhaps also how (regrettably? consciously?) responsive Strasbourg can be to some state-administered spanking.

Finally, readers might be interested in a new website/blog launched by the estimable Conor Gearty of the LSE, who has a forthcoming book with OUP on the relationship between Britain and Strasbourg, On Fantasy Island. Conor will blog with excerpts from the book, working his way through its main themes: the fantasies, the facts, and the future.

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UK Investigatory Powers Tribunal Rules that Non-UK Residents Have No Right to Privacy under the ECHR

Published on May 18, 2016        Author: 

In another major development on the surveillance/privacy front, on Tuesday the UK specialized surveillance court, the Investigatory Powers Tribunal, ruled that persons not present within the United Kingdom are not within the jurisdiction of the UK in the sense of Article 1 of the European Convention on Human Rights, and accordingly do not have any of the rights under that Convention (para. 49 et seq). In other words, a person in say France or the United States subjected to surveillance by GCHQ does not have an ECHR right to privacy vis-a-vis the UK, which accordingly has no Convention claim to answer. This is I think the first time that a British court has expressly dealt with extraterritoriality in the surveillance context. The IPT’s reasoning essentially rests on a Bankovic analogy – if you are in say Serbia and the UK drops a bomb on you, the Strasbourg Court has said that you don’t have the right to life. How could you then have the right to privacy if all the UK did was to simply read your email while you were in Serbia?

I have extensively argued elsewhere why that analogy is wrong (as is Bankovic itself), so I won’t belabour that point further (see here and here). It was entirely predictable that the IPT would adopt this restrictive position, which is perfectly plausible under Strasbourg case law (even if fundamentally mistaken). The IPT was correct in ruling, however, that distinctions as to the Convention’s applicability can’t really be made on the basis of whether the person is present is some other Council of Europe state, or is outside the ECHR’s espace juridique altogether. Anyway, the issue of the Convention’s extraterritorial applicability to mass electronic surveillance abroad is one for Strasbourg to decide and (hopefully) fix, and it will have the opportunity to do so in these cases and others. What the Court will do is of course anyone’s guess, because its decision will inevitable have ripple effects on other scenarios, such as extraterritorial uses of lethal force, e.g. drone strikes.

I have also argued, however, that there is particular scenario in which the applicability of the Convention becomes more attractive (or less dangerous as a matter of policy) – when the surveillance actually takes place within the surveilling state’s territory, even if the affected individual is outside it. Imagine, for example, if the UK police searched my flat in Nottingham while I was visiting family in Serbia – surely I would have Article 8 rights, even though I would not be on UK territory when the search took place. Why then should I not have these rights if an email I send while I am in Serbia is routed through my university server in Nottingham and intercepted by GCHQ there? In both cases the intrusion into privacy happens on the UK’s territory, even if I am outside it. In fact, in its judgment the IPT briefly addresses this scenario, if all too briefly and less than convincingly, although I’m not sure that the point was extensively argued.

In any case, the main paragraphs on the jurisdiction issue are below the fold. The judgment also deals with the very important question of standing/victim status, finding that all but six of the 600+ claimants lacked locus standi even under a very low threshold of showing that they are ‘potentially at risk’ from surveillance measures (applying the European Court’s recent Zakharov judgment, para. 171).

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Silencing the Canary: the lawfulness of the U.K. Investigatory Powers Bill’s secrecy provisions under the ECHR

Published on May 17, 2016        Author: 

Following the Snowden revelations in 2013 concerning the complicity of the tech industry in widespread electronic government surveillance in the U.S., tech companies have individually and collectively become increasingly active as advocates of privacy and free speech rights, culminating in legal challenges to government electronic surveillance.

Since the dropping by the U.S. Department of Justice (DOJ) of its much publicised writ against Apple, which sought to compel Apple to hack the security key code system of the Apple iPhone 5, the battle between tech companies and the DOJ over privacy and encryption in the U.S. has taken another turn.  In April, Microsoft filed a suit in the District Court of Seattle against the DOJ challenging the ‘secrecy order’ provisions (a range of anti-tipping off and gagging powers) under the Electronic Communications Privacy Act (ECPA).

With the Investigatory Powers Bill (IPB), which contains similar secrecy requirements, currently being debated before the U.K. Parliament, the U.S. case provides fair warning of possible human rights challenges tech companies may bring against the U.K. government. This post will consider the implications of the Bill’s secrecy provisions in light of the rights of tech companies under the European Convention on Human Rights (ECHR).

The Microsoft – DOJ claim                                                 

In short, the ECPA allows a U.S. government agency to apply to the Court for a warrant requiring Microsoft, or any other internet company, to hand over their customers’ private data. In addition, an order can be made by the court preventing the company from publicising the fact that they have been required to disclose the data. Read the rest of this entry…

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Announcements: Max Planck Group Leader in Bogotá; UN Audiovisual Library of International Law

Published on May 15, 2016        Author: 

1. Max Planck Group Leader in Bogotá, Colombia. The Max Planck Institute for Comparative Public Law and International Law (Heidelberg) and Universidad de Los Andes (Bogotá, Colombia) are looking to hire a Principal Investigator to lead a newly established Max Planck Tandem Group in Transformations of Public Law. Other than research, responsibilities include supervision of two doctoral students at Universidad de Los Andes. There is no mandatory teaching load. The Group will be located in Bogotá, and the Leader will be expected to reside in that city. The initiative will provide funding for at least one extended research stay per year of the Group at the Max Planck Institute for Comparative Public Law and International Law. Additional information may be found here. The deadline for applications is 15 May 2016.

2. New additions to the UN Audiovisual Library of International Law. The Codification Division of the UN Office of Legal Affairs recently added a mini-series on “Droit de la responsabilité internationale” by Professor Mathias Forteau to the UN Audiovisual Library of International Law. The mini-series consists of the following four lectures: “Sources et évolution du droit de la responsabilité internationale”, “La réclamation en responsabilité internationale”, “Les conditions d’engagement de la responsabilité internationale”,  and “Le contenu et la mise en œuvre de la responsabilité internationale”.

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