DID THE US INVOLVEMENT IN IRAQ PROVIDE JUSTICE OR VIOLATE THE LAW

This article is written by Lithivarshini.C of 7^th Semester of BALLB of Tamil Nadu Dr. Ambedkar Law University

ABSTRACT:

The US involvement in Iraq, specifically the 2003 invasion, is a subject of ongoing debate regarding its adherence to international law and principles of justice. This abstract explores the multifaceted nature of the issue, addressing arguments for and against the intervention’s legality and ethical basis. Analyzing the absence of explicit UN authorization, the concept of humanitarian intervention, and the aftermath of the invasion, this abstract seeks to present a balanced perspective on whether the US involvement in Iraq can be deemed a violation of international law or a pursuit of justice. The systematic nature of these violations provides compelling evidence of a policy that is rotten at its core and requires fundamental change.[1] The essay delves into the complexities of state sovereignty, the consequences of military interventions, and the challenges of reconciling global security concerns with established legal norms. Ultimately, the abstract highlights the intricate web of legal interpretations, geopolitical motivations, and moral considerations that define the ongoing discourse surrounding this significant event in contemporary international affairs.

Key Words: United States, Iraq, United Nations, Violation, Legality

INTRODUCTION:

The topic of the US involvement in Iraq, particularly the 2003 invasion, is a complex and multifaceted subject that has generated intense debate and analysis within the realms of international law, politics, ethics, and global security. The decision to intervene in Iraq has raised significant questions about the balance between state sovereignty, humanitarian intervention, the legality of the use of force, and the consequences of such actions on both regional stability and international relations. As the world witnessed the events unfold, opinions diverged on whether the US involvement constituted a justifiable response to perceived threats or a violation of established international legal norms. This essay delves into the intricacies of the US intervention in Iraq, exploring arguments related to justice, international law, and the broader implications for global governance and diplomacy. By examining key legal principles, geopolitical motivations, unintended consequences, and ethical considerations, this essay seeks to shed light on whether the US involvement in Iraq provided justice or contravened established international legal frameworks.

The reality of US involvement:

1. The Case for Justice:

Proponents of the US intervention in Iraq argue that the removal of Saddam Hussein’s brutal regime was a justifiable pursuit. Saddam’s regime was notorious for human rights abuses, including mass killings and the use of chemical weapons against its own citizens. Advocates contend that the intervention aimed to liberate the Iraqi people from oppression, thus aligning with the principles of justice and humanitarian intervention.

• The Question of International Law:

The legality of the US invasion of Iraq under international law has been a contentious point. Critics highlight that the invasion was conducted without explicit authorization from the United Nations Security Council (UNSC). This raises concerns about the violation of the UN Charter’s principle of non-interference in the internal affairs of sovereign nations. The absence of clear evidence of weapons of mass destruction, which was used as a primary justification, further complicates the legal basis for the intervention.

• Humanitarian Intervention vs. Sovereignty:

The debate over the intervention’s justice or violation of law is closely tied to the balance between humanitarian intervention and the sovereignty of nations. Proponents of humanitarian intervention argue that protecting human rights supersedes sovereignty in cases of severe abuse. However, opponents stress the importance of respecting state sovereignty and the potential precedent set by intervening without clear international consent.

• Unintended Consequences and Regional Instability:

The aftermath of the invasion led to unintended consequences that undermined arguments for justice. The power vacuum left by Saddam’s removal fueled sectarian violence and the rise of extremist groups, most notably ISIS. This instability not only created immense human suffering but also exacerbated regional tensions. Critics contend that these outcomes demonstrate a failure to consider the long-term consequences of intervention, ultimately challenging the intervention’s justification.

• Geopolitical Motivations:

Another dimension of the debate involves geopolitical motivations behind the US involvement in Iraq. Skeptics argue that the presence of oil reserves, regional influence, and broader strategic interests played a significant role in the decision to invade. This raises concerns about ulterior motives that may overshadow claims of justice and legal justification.

LEGAL ARGUMENTS AND PRINCIPLES:

Several relevant case laws and legal arguments have been discussed in the context of the US involvement in Iraq. Some of these cases and principles include:

1. United Nations Charter (Article 2(4)) and Nuremberg Principles: The United Nations Charter prohibits the use of force against the territorial integrity or political independence of any state, except in cases of self-defense or when authorized by the UN Security Council. This principle is in line with the Nuremberg Principles, which establish that aggressive war is a crime against peace. Critics of the US invasion argue that it violated these principles, as it lacked explicit UNSC authorization.
2. Customary International Law on Use of Force: The Caroline Case (1837)[2] and the Nicaragua Case (1986)[3] have contributed to the development of customary international law regarding the use of force. These cases emphasize the necessity of self-defense as an immediate response to an armed attack. The argument that Iraq posed an imminent threat based on weapons of mass destruction was met with skepticism, raising questions about the legitimacy of the invasion under these principles.
3. Prosecution of Aggressive War: The Nuremberg Trials after World War II established the principle that individuals can be held accountable for crimes against peace, including the planning and initiation of aggressive war. Critics of the Iraq intervention argue that key officials involved in the decision-making process could potentially be held accountable under this principle for initiating an aggressive war without proper legal justification.
4. International Criminal Court (ICC) Jurisdiction: While the US is not a party to the Rome Statute that established the ICC, the court’s jurisdiction extends to crimes committed on the territory of states that are party to the Statute. Iraq is a party to the Rome Statute, which raises the question of whether actions taken during the invasion and subsequent occupation could be subject to ICC jurisdiction, especially if deemed to be war crimes or crimes against humanity.
5. Opinio Juris and Customary International Law: Customary international law evolves through the consistent and general practice of states, coupled with a belief that such practice is legally required (opinio juris). The debate over the legality of the Iraq invasion highlights the importance of these elements in determining whether the international community recognizes certain actions as lawful or not.
6. International Humanitarian Law (IHL) and Geneva Conventions: The treatment of detainees, use of force, and other aspects of the Iraq conflict raise questions about compliance with international humanitarian law. Allegations of abuses at Abu Ghraib prison and elsewhere have drawn attention to potential violations of the Geneva Conventions and other IHL norms.

These case laws and principles underscore the complexity of the legal arguments surrounding the US involvement in Iraq. The debate continues to shape discussions on the balance between state sovereignty, humanitarian intervention, and the responsibility of states under international law.

EXPERT’S OPINION ON US INVOLVEMENT:

Opinions on the US involvement in Iraq vary widely, reflecting the complexity of the issue and the diverse perspectives of individuals, experts, and governments. Here are some common opinions:

1. Support for Humanitarian Intervention: Some argue that the US intervention was necessary to remove Saddam Hussein’s oppressive regime, which committed egregious human rights abuses. They believe that the intervention aimed to bring justice to the Iraqi people by liberating them from tyranny and creating the conditions for democracy and stability.
2. Opposition to Unilateral Action: Many critics contend that the US intervention violated international law by being conducted without explicit UN authorization. They see the invasion as a breach of the principle of non-interference in the affairs of sovereign nations, and they question the credibility of the intelligence used to justify the war.
3. Concerns about Geopolitical Motivations: Skeptics often point to the presence of oil reserves, regional influence, and broader strategic interests as underlying motives for the intervention. They view the US involvement as driven by geopolitical considerations rather than a genuine commitment to justice or humanitarian concerns.
4. Unintended Consequences and Destabilization: Some argue that the intervention’s aftermath, including the rise of extremist groups and prolonged instability, contradicts claims of justice. The unintended consequences, such as sectarian violence and the emergence of ISIS, demonstrate a failure to fully anticipate the potential negative outcomes.
5. Debate Over Just War Theory: The Iraq intervention has ignited discussions about the principles of just war theory, which include criteria for a morally justifiable use of force. The application of these principles to the invasion has led to disagreements about whether the intervention met the requirements of a just war, such as having a just cause, proportionality, and a reasonable chance of success.
6. Impact on International Norms: Some argue that the Iraq intervention weakened international norms governing the use of force and respect for state sovereignty. They worry that the lack of clear UN authorization and the subsequent instability in the region set a precedent that could be exploited by other nations in the future.
7. Shift in Focus to Diplomacy: A prevailing sentiment post-Iraq intervention is the emphasis on diplomacy and multilateral cooperation to address global conflicts. Many advocates for diplomatic solutions and international consensus rather than unilateral military actions, citing the lessons learned from the Iraq experience.
8. Mixed Assessment of Outcomes: Opinions on the overall outcome of the intervention differ. Some believe that despite the challenges and mistakes, Iraq is better off without Saddam Hussein’s regime. Others argue that the costs, both in terms of human lives and geopolitical consequences, outweigh any potential benefits.

These opinions highlight the complexity of assessing the US involvement in Iraq, as well as the ongoing debates over justice, international law, and the broader implications for global security and stability.

LEGALITY OF US INVOLVEMENT IN IRAQ:

The legality of the US involvement in Iraq, particularly the 2003 invasion, has been a subject of intense debate among legal scholars, experts, and international observers. Here are some key points that reflect the differing opinions on its legality:

1. UN Security Council Authorization: The invasion of Iraq was conducted without explicit authorization from the United Nations Security Council (UNSC). Critics argue that this absence of UN approval violated the UN Charter, which generally prohibits the use of force against the territorial integrity or political independence of any state, except in cases of self-defense or with UNSC authorization.
2. Self-Defense and Imminent Threat: The Bush administration argued that Iraq posed an imminent threat due to its alleged possession of weapons of mass destruction (WMDs). They contended that the invasion was a preemptive measure to protect national security and that it fell under the principle of self-defense. However, this argument was met with skepticism as no concrete evidence of WMDs was found.
3. Humanitarian Intervention: Some legal scholars argue that the intervention could be justified under the doctrine of humanitarian intervention, which allows for the use of force to prevent or halt grave human rights abuses. However, this doctrine is not universally accepted in international law, and its application is highly debated.
4. Precedent of Nuremberg Trials: Critics of the intervention invoke the Nuremberg Trials and the Charter of the International Military Tribunal, which established the principle that aggressive war is a crime against peace. They argue that the invasion could be seen as violating this principle by initiating an aggressive war without sufficient legal justification.
5. Customary International Law: Supporters of the intervention point to customary international law and state practice that suggests a shift toward accepting humanitarian intervention as a legitimate basis for the use of force. However, there is no universally agreed-upon standard for when and how humanitarian intervention can be invoked.
6. War Crimes and Accountability: Some critics allege that actions taken during the occupation of Iraq, such as detainee abuse at Abu Ghraib prison, could amount to war crimes and violations of international humanitarian law. This raises questions about accountability and the adherence to legal norms during the conflict.
7. Challenges to the Legal Framework: The Iraq intervention has highlighted challenges in applying existing international legal frameworks to contemporary conflicts. The evolving nature of warfare, combined with differing interpretations of legal principles, has led to ongoing discussions about the adequacy of current international laws governing the use of force.

In summary, the legality of the US involvement in Iraq is a complex and contentious issue. While proponents of the intervention argue that it was justified based on self-defense, humanitarian concerns, and evolving norms, critics emphasize the lack of explicit UN authorization and the questionable intelligence that was used as a primary justification. The debate underscores the challenges of interpreting international law in the context of complex geopolitical situations.

VIOLATION OF LAW:

The US involvement in Iraq, particularly the 2003 invasion, has raised several allegations of violations of international law. It’s important to note that legal interpretations can vary, and the following points reflect some of the main concerns raised by critics:

1. Breach of UN Charter: One of the most significant criticisms is that the invasion of Iraq without explicit authorization from the United Nations Security Council (UNSC) violated the UN Charter. The Charter prohibits the use of force against the territorial integrity or political independence of any state, except in cases of self-defense or when authorized by the UNSC. The absence of a UNSC resolution specifically authorizing the invasion is a key point of contention.
2. Lack of Just Cause: Critics argue that the invasion did not meet the criteria of a “just cause” under international law. The alleged threat posed by Iraq’s weapons of mass destruction (WMDs) was used as a primary justification, but no conclusive evidence of such weapons was found. As a result, the use of force based on this premise is questioned as lacking a legitimate basis.
3. Preemptive War and Self-Defense: The Bush administration justified the intervention as a preemptive measure to protect national security. However, the legal validity of preemptive self-defense has been debated. The International Court of Justice has stated that preemptive self-defense is only lawful when an armed attack is imminent and no other options are available.
4. Violation of International Humanitarian Law: Allegations of abuses and violations of international humanitarian law (IHL) emerged during the conflict. The mistreatment and abuse of detainees at facilities like Abu Ghraib prison raised concerns about adherence to the Geneva Conventions and other IHL norms, which outline the treatment of prisoners of war and civilians in armed conflict.
5. Destabilization and Sectarian Conflict: The aftermath of the invasion resulted in significant instability, including sectarian violence and internal conflicts. Critics argue that the invasion’s unintended consequences, such as the rise of extremist groups like ISIS, contributed to violations of human rights and destabilization of the region.
6. Occupation and Responsibility: The legality of the subsequent occupation and administration of Iraq also came into question. Under international law, an occupying power has specific responsibilities toward the occupied population, including ensuring security, providing basic services, and respecting human rights.
7. Responsibility to Rebuild: Some argue that the failure to effectively rebuild Iraq after the invasion could be seen as a violation of the responsibility to restore order and infrastructure after a military intervention.

It’s important to recognize that discussions about violations of law in relation to the US involvement in Iraq are nuanced and can vary based on legal interpretations, perspectives, and specific aspects of the conflict.

THE LEGALITY OF INVASION UNDER UN CHARTER:

The question of whether the US involvement in Iraq violated any United Nations (UN) laws or regulations is a subject of debate and interpretation. The primary reference point for assessing the legality of the invasion is the United Nations Charter, which outlines the rules governing the use of force and international relations.

1. UN Charter Violation: Critics of the US involvement in Iraq argue that the invasion without explicit authorization from the United Nations Security Council (UNSC) violated the UN Charter. Article 2(4) of the Charter prohibits the use of force against the territorial integrity or political independence of any state, except in cases of self-defense or with UNSC authorization. As the invasion lacked a UNSC resolution specifically authorizing the use of force, it is viewed by some as a violation of the Charter.
2. Self-Defense Interpretation: Proponents of the intervention point to the concept of self-defense as a potential justification. They argue that the perceived threat posed by Iraq’s alleged possession of weapons of mass destruction (WMDs) justified preemptive action to protect national security. However, this interpretation is debated, as the International Court of Justice has clarified that preemptive self-defense is lawful only in cases of an imminent armed attack.
3. Humanitarian Intervention Debate: The concept of humanitarian intervention, using military force to prevent or halt severe human rights abuses, is also relevant to the discussion. Some argue that the intervention was aimed at ending the oppressive rule of Saddam Hussein’s regime and preventing further human rights violations. However, the legality of humanitarian intervention is not universally agreed upon under international law.
4. Customary International Law: Whether the US intervention violated customary international law is a point of contention. Customary international law develops through consistent state practice and opinio juris (belief that a practice is legally required). Critics argue that the invasion without UNSC approval challenges the established norms of non-interference in the affairs of sovereign states.

In summary, whether the US involvement in Iraq violated UN laws depends on the legal interpretations applied to the situation. Critics point to the absence of explicit UNSC authorization and the lack of imminent threat as evidence of a violation of the UN Charter. Supporters argue that the perceived threat and humanitarian concerns provided a legal basis for the intervention. Legal perspectives vary, making the issue complex and debated within the realm of international law.

RELATED CASE LAWS:

The International Court of Justice (ICJ) has dealt with various cases involving issues related to armed conflicts, international law, and sovereignty. While there might not be direct parallels to the US involvement in Iraq, several cases have raised similar legal questions and principles. Here are a few relevant cases:

1. Nicaragua v. United States (1986)[4]: This case revolved around the United States’ support for the Contras in Nicaragua and its mining of Nicaraguan harbors. The ICJ ruled that the US had violated international law by using force against Nicaragua and by interfering in its internal affairs. The case addressed issues of state sovereignty, non-intervention, and the prohibition of the use of force.
2. Democratic Republic of the Congo v. Uganda (2005)[5]: This case concerned Uganda’s actions in the Congo during the Second Congo War. The ICJ ruled that Uganda had violated international law through its military intervention, plundering of resources, and human rights abuses. The case touched upon issues of sovereignty, the prohibition of aggression, and the obligation not to violate the territorial integrity of other states.
3. Genocide Case (Bosnia and Herzegovina v. Serbia and Montenegro, 2007)[6]: This case dealt with allegations of genocide during the Bosnian War. The ICJ ruled that Serbia had not committed genocide, but it did find that Serbia had failed to prevent and punish genocide. The case addressed issues of state responsibility for preventing genocide and the interpretation of the Genocide Convention.
4. Oil Platforms Case (Iran v. United States, 2003)[7]: This case centered on the destruction of Iranian oil platforms by the United States. The ICJ ruled that the destruction violated international law and awarded Iran compensation. The case dealt with issues related to the use of force, state responsibility, and reparations.
5. Certain Expenses Case (UN v. US, 1986)[8]: This case involved the question of whether the United States was obligated to pay assessed contributions to the United Nations. The ICJ ruled that the US was under a legal obligation to pay. Although not directly related to armed conflicts, this case demonstrated the ICJ’s role in interpreting international obligations and enforcing compliance.

These cases showcase the ICJ’s role in addressing complex legal issues arising from conflicts and interventions, such as state responsibility, sovereignty, the prohibition of the use of force, and violations of international law. While they may not mirror the exact circumstances of the US involvement in Iraq, they provide insights into how international legal principles have been applied to similar situations.

The International Criminal Court (ICC) primarily deals with cases involving war crimes, crimes against humanity, genocide, and other serious violations of international law. While there may not be direct parallels to the US involvement in Iraq, several situations investigated by the ICC share similarities in terms of alleged violations and accountability for international crimes. Here are a few relevant situations:

1. Sudan (Darfur): The ICC issued arrest warrants for individuals, including high-ranking government officials, in connection with crimes committed during the conflict in Darfur. The situation involves allegations of war crimes, crimes against humanity, and genocide, and highlights issues of accountability for state and non-state actors.
2. Uganda: The ICC was involved in cases related to the Lord’s Resistance Army (LRA) insurgency in Uganda. The Court indicted LRA leaders for crimes including child soldier recruitment, sexual slavery, and killings. The situation raised questions about holding non-state actors accountable for serious international crimes.
3. Central African Republic: The ICC’s involvement in the Central African Republic has focused on crimes committed during conflict and sectarian violence. The situation underscores the challenges of addressing impunity in conflict-ridden environments.
4. Libya: The ICC issued arrest warrants for individuals connected to the conflict in Libya, including former government officials. The situation highlights the ICC’s role in addressing crimes committed during political upheaval and the challenges of executing arrest warrants.
5. Georgia (South Ossetia): The ICC investigated crimes committed during the 2008 conflict between Georgia and Russia over South Ossetia. The situation raised questions about the application of international law in conflicts involving multiple states and non-state entities.

While these ICC situations may not directly mirror the complexities of the US involvement in Iraq, they demonstrate the Court’s role in addressing allegations of serious international crimes in various conflict contexts. They also underscore the challenges of establishing accountability, upholding international law, and ensuring justice in the aftermath of conflicts.

SIMILAR historical and contemporary cases:

Several historical and contemporary cases share similarities with the US involvement in Iraq in terms of international intervention, legal debates, and the use of force. Here are a few examples:

1. Kosovo Intervention (1999): The NATO intervention in Kosovo raises questions similar to those surrounding the US involvement in Iraq. The intervention aimed to prevent widespread human rights abuses and ethnic cleansing. While lacking explicit UN Security Council authorization, some argue that it could be seen as a form of humanitarian intervention, while others view it as a violation of sovereignty.
2. Libya Intervention (2011): The international intervention in Libya, authorized under UN Security Council Resolution 1973, aimed to protect civilians during the conflict between government forces and rebels. The debate focuses on the extent of the intervention’s mandate, whether it shifted from protecting civilians to regime change, and the consequences of intervention on stability and governance in Libya.
3. Syrian Civil War (Ongoing): The Syrian conflict has prompted discussions about international intervention and the Responsibility to Protect (R2P) principle. The absence of robust international action to address the humanitarian crisis raises debates about the implementation and limits of R2P, as well as the complexities of balancing intervention and sovereignty.
4. Ukraine and Crimea (2014): The annexation of Crimea by Russia in 2014 and the ongoing conflict in Eastern Ukraine have raised questions about territorial integrity, sovereignty, and international law. The situation highlights the tension between state sovereignty and international norms, including those related to the use of force and the protection of minority populations.
5. Yugoslav Wars (1990s): The conflicts in the former Yugoslavia led to international intervention, including NATO airstrikes in Bosnia and Herzegovina and the NATO intervention in Kosovo. These cases prompted debates about the legality of military actions, the role of the UN Security Council, and the protection of human rights during armed conflicts.
6. Rwanda Genocide (1994): The failure of the international community to effectively intervene during the Rwandan genocide raised discussions about the Responsibility to Protect and the obligation of the international community to prevent mass atrocities.

These cases demonstrate the complexities surrounding international interventions, sovereignty, human rights, and the interpretation of international law. Similar to the US involvement in Iraq, each case has generated debates about the legality, ethics, and consequences of using military force for humanitarian, political, or strategic reasons.

CONCLUSION:

In conclusion, the question of whether the US involvement in Iraq provided justice or violated international law remains a contentious and nuanced issue that reflects the complexities of modern geopolitics and ethical dilemmas. The invasion’s aftermath and the various legal arguments surrounding the intervention demonstrate the challenges of interpreting and applying international law in complex situations.

While proponents argue that the intervention aimed to liberate the Iraqi people from an oppressive regime and potentially prevent further human rights abuses, critics contend that the invasion lacked explicit UN authorization and clear evidence of imminent threats. The unintended consequences of the conflict, including prolonged instability, sectarian violence, and the rise of extremist groups, have cast doubts on the intervention’s justifiability and the extent to which it upheld international law.

The US involvement in Iraq highlights the evolving nature of international relations and the delicate balance between sovereignty, humanitarian concerns, and the global responsibility to maintain peace and security. As the world grapples with lessons learned from this intervention, it underscores the need for continued discourse on the legal and ethical dimensions of international interventions, the protection of human rights, and the pursuit of justice in an ever-changing global landscape. Ultimately, the question of whether the US involvement in Iraq provided justice or violated international law remains a subject that invites ongoing reflection and analysis.

REFERENCES:

1. “Iraq war illegal, says Annan”. BBC News. 16 September 2004.
2. Kramer, Ronald C.; Michalowski, Raymond J. (1 July 2005). “War, Aggression and State Crime”. The British Journal of Criminology. 45 (4): 446–469. doi:10.1093/bjc/azi032. ISSN 0007-0955
3. Christine Gray (15 September 2008). International Law and the Use of Force (Foundations of Public International Law). Oxford University Press. pp. 162–164.
4. Case Note – Was the war on Iraq Illegal? – The Judgment of the German Federal Administrative Court Archived 2007-09-27 at the Wayback Machine of 21 June 2005 in the German Law Journal No. 1 (1 January 2006), citation from section “C. The Court’s Reasoning”
5. Jurist, Legal News and Research, University of Pittsburgh School of Law, 9 Nov, 2006, Forum: Op-ed, “Donald Rumsfeld: The War Crimes Case,”
6. Prescott, John (10 July 2016). “Guilt at the ‘illegal’ Iraq War will haunt Prescott for the rest of his life”. Daily Mirror.
7. The Sunday Times (UK), 17 Jan, 2010, “Revealed: Jack Straw’s Secret Warning to Tony Blair on Iraq,” http://www.timesonline.co.uk/tol/news/politics/article6991087.ece

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[1] See for example, WikiLeaks, http://www.collateralmurder.com/, and Deformed Iraqi babies caused by USA use of depleted uranium: http://www.aztlan.net/du_deformed_iraqi_babies.htm, The Abu Ghraib Prison Photos http://www.antiwar.com/news/?articleid=2444, Time Report Shows Torture Is Widespread in Iraq Friday, http://www.time.com/time/world/article/0,8599,1892038,00.html,

[2] The Caroline v. United States, 11 U.S. 7 Cranch 496 496 (1813)

[3] Case Concerning Military and Paramilitary Activities In and Against Nicaragua (Nicaragua v. United States of America); Merits, International Court of Justice (ICJ), 27 June 1986, available at: https://www.refworld.org/cases,ICJ,4023a44d2.html [accessed 24 August 2023]

[4] Ibid

[5] https://www.icj-cij.org/case/116

[6] Case Concerning Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Bosnia-Herzegovina v. Yugoslavia), International Court of Justice (ICJ), 11 July 1996, available at: https://www.refworld.org/cases,ICJ,4040ba0c4.html [accessed 24 August 2023]

[7] ICJ GL No 90, [2003] ICJ Rep 161, ICGJ 74 (ICJ 2003), 6th November 2003, International Court of Justice [ICJ]

[8] International Court Of Justice Advisory Opinion 1962 ICJ 151