With the advent of technological advancement, the deep-sea exploration was facilitated. Due to this progress in exploration ability, the laws regulating the conduct of the men at sea were also progressively changed.
Earlier, the Principle of Mare Liberum was effective, as opposed to the present Common Heritage of the Mankind now. This shift in dynamics has brought substantial change in the law of the sea, and has opened new avenues of legal concepts and research.
This article discussed 22 Research Topics on the Law of the Sea, ranging from Basic, to Intermediate and ultimately Complex questions.
- Transit Passage v. Innocent Passage
Due to contemporary global interaction, it has become imperative to allow foreign vessels in one’s own territory. Trade, military collaborations, and foreign travel have grown manifold since the end of last millennium. Due to these modern developments, the need for innocent and transit passages arose.
However, elementary LOS learners often confuse the two forms of passages. There is a difference of proximity and liabilities[1] between the two. A comparative study will help understand associated concepts under the LOS.
- Bodies within the UNCLOS
The UN Convention on the Law of the Sea (UNCLOS) is the single most important legal framework of the modern Law of the Sea. The aforementioned concepts also find their mention in this Convention. It also forms various bodies and authorities such as: the International Tribunal for the Law of the Sea (ITLOS), concerned with adjudicating the matters related to LOS disputes and interpretation of UNCLOS. Then, the International Seabed Authority (ISA) which is responsible for all matters related to the seabed beyond the national jurisdiction of a country[2]. Lastly, there is the Commission on the Limits of the Continental Shelf (CLCS), established for scientific, geological determination of Continental Shelves and associated activities[3].
- SS Lotus Case[4] (France v. Turkey)
SS Lotus Case is a classic case of the law of the sea regarding the territorial jurisdiction in high seas. The case is popularly named after the French steamer ship which was involved in the collision that led to the death of Turkish mariners onboard a Turkish ship: SS Bouz-Kourt. Two important principles of jurisdiction of states were evolved through this case (popularly known as the Lotus Principles:
- The principle of outside its territory
- The principle of within its territory
It was held that both France and Turkey enjoyed concurrent jurisdiction[5]. This case is an interesting research topic as a comparative analysis of criminal jurisdiction and customary law.
- North Sea Continental Shelf Case[6] (Germany v. Denmark & the Netherlands)
This is another classic case of the law of the sea, concerned with the delimitation of the continental shelf of these three concerned states in the North Sea. The delimitation was done according to the Equidistance Principle[7], which was provided for in the Geneva Continental Shelf Convention, ratified by Denmark and the Netherlands.
Germany, due to the shape of its coasts was at significant disadvantage if this principle was to be applied. The court in this case applied the equity praeter legem principle to settle the dispute. Germany was granted additional continental shelf.
This case is also a great starting point to initiate research into the concept of continental shelf, as well as the contemporary continental shelf disputes.
- Corfu Channel Case[8] (United Kingdom v. Albania)
This is yet another classic case of the law of the sea pertaining the Principle of Freedom of Maritime Communication. It related to the duties levied by the law of the sea on a coastal state to keep the passage around its territory safe, and warn the passing vessels of any possible dangers. The case concerned two British warships sailing through the Corfu Channel which were stuck my sea mines laid down by the Albanian government, since the Channel was part of the Albanian territorial waters. The British government later undertook an action to mine-sweep the area, which was alleged to be a violation of the Albanian sovereignty. This case laid down a concept of innocent passage for warships in certain conditions through a sovereign’s territorial waters. However, the minesweeping action undertaken by the British government was held to be a violation of the sovereignty of Albania[9].
- Revisiting the Enrica Lexie Case
The famous case between India and Italy was in light once again since its conclusion before the Supreme Court of India this year. The SC quashed all the criminal proceedings for a sum of multi-million compensation offered to the two deceased’s families in the case[10].
The trajectory of this whole case, the activation of various jurisdiction along the way of 9 years of proceedings is surely a good research topic to understand the complexity of the concept of criminal jurisdiction under the law of the sea regime. It is one of the most hotly debated cases of modern times, with many political angles attached to it. The whole narrative of international relations can also be ventured into through this case.
- The Cod Wars (United Kingdom v. Iceland)
This is not to be confused with the Cold War, which was a whole different event. These were a series of “almost wars” of naval nature between the UK and Iceland[11]. The subject matter of the dispute was the Atlantic “Cod” fish, hence the name. This historic event between Iceland and the UK was the foundation stone for the development of the Exclusive Economic Zone (EEZ) limitation range of 200 Nautical Miles. It also involved a parallel legal proceeding before the ICJ, known as the Fisheries Jurisdiction Case[12]. This is one of the most interesting cases of diplomacy and exploitation of strategic value by a smaller nation to exert pressure on a bigger one.
- Shrinking coastlines of Western Europe
Due to the irregular elevation of landmasses, the effects of rising sea level are not uniform across the globe. This poses a serious danger to the coasts of Western Europe. The shrinking shorelines of Portugal, Ireland, and France[13], the flash floods in Germany this year[14], the contingency plans of the Netherlands[15] and Denmark to build dams across water channels, etc. are proofs of the fact that Europe is moving towards a change in geography. What these changes will entail for the already fragile maritime borders of these countries remains a question to be answered. A collaborative research can be undertaking by conjoining the sciences of geology, geography, and the law of the sea.
- The plight of island nations
With the threats of rising sea levels as a result of the steady global warming, sea-surrounded island nations are at a far graver danger that other littoral states. However, sea level rise is not equal in all places. The ice melting from glaciers and ice concentrated areas does not settle into the areas of origin but drifts away. It is also due to geographic phenomena of submergence and alleviation of lands and difference in gravity concentration across the globe. Countries such as Tuvalu, Kiribati and the Marshal Islands are already experiencing sea level rise where ocean flooding has washed saltwater onto agricultural lands and inundated sources of drinking water[16].
This also causes the problem of relocation of these potential climate refugees. What would be the obligations of the accepting states towards these refugees awaits a research.
- South China Sea judgment
South China Sea dispute is the epitome of the need for a framework like the law of the sea, and UNCLOS in particular. This region is a total blunder of maritime borders overlapping with each other. In 2016, an independent arbitral tribunal set up under the UNCLOS ruled against China’s claims of maritime boundaries in the South China Sea.
However, China rejected[17] this ruling and not much has changed in the disputant area. From China’s point of view, the South China Sea is the busiest route and for its trade, creating a monopoly in the region will benefit the country manifold by avoiding to pay any transit charges through the waters of other countries. However, the Chinese construction of artificial islands to strengthen the claim, and use a group of unhabituated islands as a reference point remains a moot point for the legality of claims so made.
- Case study of Bolivia-Chile Dispute
Law of the sea is not applicable to littoral states alone. It also provides for the rights of landlocked states, in the sea. Therefore, landlocked states have the freedom of access to the sea. This is because the modern law of the sea is based on the principle of common heritage of mankind. An interesting case study of the rights of landlocked state is presented by the dispute between Bolivia and Chile[18]. Chile is a littoral state, whereas Bolivia is a landlocked state. However, Bolivia had a coast before Chile annexed after winning a war against Bolivia in the late 19th Century. The right of access to sea is not an absolute right, but a general one. It is widely dependent upon the agreements between the littoral/transit state and the landlocked state. This case study will present the opportunity to gather practical knowledge about the rights of landlocked states under the law of the sea regime.
- The Peanut Hole Case
This case is one of the most interesting contemporary development related to the Continental Shelf concept under the law of the sea. This case revolved around a hole in the EEZ of Russia. This marine area right in the middle of the Sea of Okhotsk, surrounded by the Russian EEZ by all sides was actually an area of International Waters, because it was beyond 200 nautical mile range from all landmasses. Thus, other countries started exploiting this situation by means of fishing in this area. As a result of excessive exploitation of the region, fisheries collapsed in the region. Russia contested that the Peanut whole was a part of its EEZ due to the continental shelf lying beneath it. The Russian Federation petitioned the same before the United Nations. In 2014, the United Nations Commission on the Limits of the Continental Shelf ruled in favor of the Russian Federation[19].
A somewhat similar case lies in the Bering Sea as well, known as the Donut Hole[20], and the Barents Sea fisheries loophole[21].
- Artificial islands: legal and geological questions
While many believe that artificial islands are a marvel resulted by the modern construction technology, the truth is, they have been constructed since ancient times[22]. Today, there are many artificial islands that are being constructed in the seas. Their construction started as residential requirements, real estate ventures, and tourism-centric venues. Some notable examples are: the Palm Jumeirah in the UAE, the Pearl in Qatar, etc. However, now their construction is also centered towards a strategic placement. In the South China Sea, China has been constructing military bases on artificially-constructed islands to strengthen their claim in the Sea[23]. The effects on the marine biology, and structural integrity of coasts, coupled with their legality under the law of the sea are definitely a few questions worth working on.
- Overseas territories
Many European nations maintain overseas territories. Even though the colonization has abolished, and most former colonies are independent states now, but a few islands here and there are directly or indirectly maintained by the erstwhile colonial powers. They serve as locations of strategic value, in military, geographical and political essences. An interesting fact is that, France is the country with the largest overseas territory in the world. This is because of its many island territories in the Pacific, the Atlantic and the Indian Ocean[24]. These are remotely offshore territories from mainland France. The United Kingdom, the Netherlands, Denmark, Norway, Australia, and the United States also maintain few to several overseas territories[25]. These territories aggregate towards the marine territory of these countries. As a result, France has the biggest marine territory and the greatest number of time-zones in the world.
The position of the law of the sea on this aspect is definitely a good research and interesting fact-finding venture.
- Eastern Pacific Continental Shelf
The coasts in the Eastern Pacific Ocean (the West coast of Americas) have a peculiar feature. Unlike most coastlines, whose continental shelves submerge eventually into the water ahead, here the situation is rather sudden. Due to many mountain ranges along the West American coasts, the continental shelf is subducted into the sea. Therefore, instead of a shore-like coast, these are wall-like standing tall against the sea[26]. Due to the limited, narrow[27] extent of the shelves, resultantly there are limited maritime territorial stretches. The situation applies to both North America and South America. How the fisheries and other marine exploration activities are undertaken by unanimity amongst various state-stakeholders is a rather interesting research undertaking.
- Fish Stock Agreements
One insurmountable problem within the sea is the regulation of fish concentration. Since fish do not confine themselves to any nation’s coast, maritime zones or territory, it is important to make their access equitable. While fisheries seem a minute matter before the complex issues dealt under the law of the sea, it is important to understand that fisheries make a large share of the marine resources exploited worldwide. They fulfill 30% of the world’s protein requirement.
Therefore, while the law of the sea provides primarily for the delimitation of coastal boundaries and zones, under which a coastal state can exercise sovereignty to exploit resources, it also deals with the associated activities, such as fisheries. Within the regime, there are multiple fish stock agreements. Most of these agreements are region-specific. Thus, complexity arises when different nations obligated under different fish stock agreements have contentions.
- Arctic Sunrise Case[28] (Netherlands v. Russia)
In 2013, an environmentalist group named Greenpeace breached a Russian oil installation in the Pechora Sea, to protest against the said installation. The protesters were accused to have committed an act of piracy, and were arrested by the Russian authorities and the vessel they were onboard, the Arctic Sunrise, which was flying a Dutch flag.
Netherlands initiated arbitral proceedings against the Russian arrest. Russia contested that it had the right to protect safety zone around the installation. The award of the Arbitral Tribunal held that the boarding and seizure of the Arctic Sunrise by the Russia was illegal, and ordered to compensate the Netherlands for the damage caused to the Arctic Sunrise and its crew[29].
The Arctic Sunrise case raises a number of interesting legal questions concerning the phenomenon of acts of protest at sea, questions that have not been adequately explored to date[30].
- Chagos Archipelago sovereignty dispute (Mauritius v. United Kingdom/ Maldives)
Mauritius gained independence from the United Kingdom in 1968. Before the independence, the British declared Chagos Archipelago as a part of the British Indian Ocean Territory[31]. This area was then further leased by the UK to the US to build and operate an airbase. As a result, many inhabitants of this region were forcibly displaced. Upon Mauritian independence, they claimed the Archipelago and proposed an agreement with UK to continue the lease to the US until their requirements are fulfilled. This was denied. Since then, there has been a constant removal of native population in the region by US and UK, constituting violations of human rights.
Proceedings were initiated before the Permanent Court of Arbitration, which ruled in favour of Mauritius. In 2019, the ICJ through its UNGA mandated advisory opinion ordered the UK to return the islands to Mauritius. This was ignored by the UK[32]. There is an overlapping dispute over the same region between Mauritius and Maldives. A Special Chamber of the International Tribunal of the Law of the Sea has decided in favour of Mauritius[33]. This is an interesting historic, politico-legal study, with a human rights dimension.
- Sir Creek Dispute (India & Pakistan)
Kashmir is not the only territory that is a matter of contention between India and Pakistan. There is another border dispute by the coasts of State of Gujarat in India, and the Province of Sindh in Pakistan. This area is called Sir Creek. It is a stretch of water that lies in the Rann of Kutch marshlands. It serves as a rough border between the two nations. The dispute is centered around the interpretation of a rather ambiguous maritime boundary line verdict. It provides for two overlapping boundary lines, hence the dispute. The area holds little to no military-strategic importance. However, it is a big source of fisheries and potential reserve of oil and gas.
The Sir Creek dispute was first brought before a tribunal in 1965, which gave a verdict providing Pakistan 10% of its claimed territory. Many rounds of discussions have followed, but no solution has been reached[34]. Many principles can be applied to reach to an equitable settlement. These principles can be ventured into via research.
- Territorial claims in the Arctic Ocean
The Arctic Ocean encapsulates the North Pole of the planet. It remained for a long time, a highly remote and difficult to access region due to extreme climate conditions. However, with the rise in the global temperature, the icecaps have been melting from this region, which has caused navigability to be easier[35].
The following states are identified as the Arctic coastal states- Canada, Denmark, Norway, Russia, United States[36]. All of these states lay claim in the Arctic Ocean, and mostly their claimed territories are overlapped with one another. The UNCLOS has exclusive provisions for the Arctic Coastal States.[37] The dispute is around the same old anticipation of undiscovered natural resources in the region, every state wants excess to prior others. A research study can be conducted with the principle of Common Heritage of all Mankind in light to determine whether this region should be subject to the sovereignty of a few nations.
- Ghana-Ivory Coast maritime border dispute[38]
The border scaling of West Africa was done during the colonial rule, and these borders were retained by the modern-day West African nations upon their independence from their colonizers. However, as much as the land-borders, the maritime borders were not given much attention to by the colonizing states. Such is the border situation between Ghana and Ivory Coast (Côte d’Ivoire). The border dispute arose when the oil excavation and extraction projects were initiated. The Tago Lagoon between the two nations was never properly demarcated[39], which remains the central point of the dispute between the two. The focal point of the dispute is the discovery of oil in the region by Ghana, which Ivory Coast also laid claim to. The matter went before a Special Chamber of the ITLOS. The Tribunal in 2017 ruled in favour of Ghana, by extending the 200 nautical mile range according to the extent of the continental shelf[40]. This is yet another peculiar case under the UNCLOS regime, underlying the fact that generalization of disputes under the law of the sea is not possible.
- Convention on the Legal Status of the Caspian Sea
In 2018, the five states surrounding the Caspian Sea- Azerbaijan, Iran, Kazakhstan, Russia and Turkmenistan have concluded and signed the Convention on the Legal Status of the Caspian Sea. It is an exclusive framework for the region, and the states have agreed that it will not be regulated by the law of the sea, however, it is based on the principles of international law. Due to the peculiar nature of the Caspian Sea, the states concerned have agreed to inculcate different regimes of law of the sea, as well as inland lakes. The Convention largely concerns itself with the water column, than seabed and subsoil, which are subject to independent agreements between the states for their delimitation. This Convention is a living document[41].
A comparative study of this Convention with the UNCLOS will derive a great analysis from a research point-of-view. The analysis may as well help fill in some existing loopholes in the UNCLOS.
CONCLUSION
It is evident from the vast topics enlisted here that the Law of the Sea is not limited to the matters of marine delimitation and regulating rights and duties at the high seas. It is a science in itself that is concerned with scientific matters, such as- fisheries, geological aspects of continental shelves, seabed, subsoil, marine conservation, regulation of unwarranted activities, settling disputes, etc.
At the same time, it is also faced with the challenges of the 21st century, such as: construction of artificial islands, eroding coastlines, rise in sea level, threats of submerging landmasses, potential changes in maritime borders etc.
Law of the Sea might appear quite straightjacketed on the face, but it does deal and further faced with newer, more complex issues sailing its way.
[1] The Fletcher School, Tufts University, Law of the Sea: A Policy Primer, Chapter 3: Freedom of Navigation, Right of Transit Passage (2021). Accessed at: https://sites.tufts.edu/lawofthesea/chapter-three/
[2] International Seabed Authority, Home page note. (August 29, 2021), https://www.isa.org.jm/
[3] Commission on the Limits of the Continental Shelf (CLCS), Purpose, functions and sessions. (August 29, 2021), https://www.un.org/depts/los/clcs_new/commission_purpose.htm
[4] S.S. Lotus (Fr. v. Turk.), 1927 P.C.I.J. (ser. A) No. 10 (Sept. 7). Publications of the Permanent Court of International Justice, Series A – No. 10; Collection of Judgments, A.W. Sijthoff’s Publishing Company, Leyden, 1927.
[5] Dakshinie Ruwanthika Gunaratne, Lotus Case (Summary), WordPress, (July 27, 2012). Accessed at: https://ruwanthikagunaratne.wordpress.com/2012/07/27/lotus-case-summary/
[6] (1969) ICJ Rep 3/ ICGJ 150 (ICJ 1969)
[7] Dakshinie Ruwanthika Gunaratne, North Sea Continental Shelf Case (Summary), WordPress, (February 28, 2014). Accessed at: https://ruwanthikagunaratne.wordpress.com/2014/02/28/north-sea-continental-shelf-cases-summary/
[8] ICJ GL No 1 ICJ Rep 4/ICGJ 199 (ICJ 1949)
[9] Aarti Goyal, The Corfu Channel Case, Academike (December 7, 2014). Accessed at: https://www.lawctopus.com/academike/the-corfu-channel-case/
[10] Anil S., Enrica Lexie: Trouble that sailed in 9 years ago from across seas in Kerala killing its fishers, The New Indian Express, June 16, 2021. Accessed at: https://www.newindianexpress.com/states/kerala/2021/jun/16/enrica-lexie-trouble-that-sailed-in-9-years-ago-from-across-seas-in-kerala-killing-its-fishers-2316810.html
[11] Walker D. Mills, THE COD WARS AND TODAY: LESSONS FROM AN ALMOST WAR, Center for International Maritime Security, JULY 28, 2020. Accessed at: https://cimsec.org/the-cod-wars-and-today-lessons-from-an-almost-war/
[12] ICJ, 1973, ICJ 3
[13] Rudy Ruitenberg, From Ancient Syracuse to Trump’s Golf Course, Europe Is Shrinking, Bloomberg Green, (March 6, 2020). Accessed at: https://www.bloomberg.com/news/features/2020-03-06/europe-is-shrinking-as-the-sea-encroaches-on-its-coastline
[14] Phillip Oltermann, Germany floods: 155 still missing as hopes of further rescues fade, The Guardian, July 21, 2021. Accessed at: https://www.theguardian.com/world/2021/jul/21/germany-floods-one-hundred-fifty-five-still-missing-hope-further-rescue-fade
[15] John Henley and Alan Evans, Giant damns enclosing North Sea could protect millions from rising waters, The Guardian, February 12, 2020. Accessed at: https://www.theguardian.com/environment/2020/feb/12/giant-dams-could-protect-millions-from-rising-north-sea
[16] Saber Salem, Climate Change and the Sinking Island States in the Pacific, E-International Relations, (January 9, 2020). Accessed at: https://www.e-ir.info/2020/01/09/climate-change-and-the-sinking-island-states-in-the-pacific/
[17] Bill Hayton, Two Years On, South China Sea Ruling Remains a Battleground for the Rules-Based Order, Chatham House, (July 11, 2018). Accessed at: https://www.chathamhouse.org/2018/07/two-years-south-china-sea-ruling-remains-battleground-rules-based-order
[18] Gideon Long, Bolivia-Chile land dispute has deep roots, BBC News-Latin America, April 24, 2013. Accessed at: https://www.bbc.com/news/world-latin-america-22287222
[19] United Nations Commission on the Limits of the Continental Shelf, SUMMARY OF RECOMMENDATIONS OF THE COMMISSION ON THE LIMITS OF THE CONTINENTAL SHELF IN REGARD TO THE PARTIAL REVISED SUBMISSION MADE BY THE RUSSIAN FEDERATION IN RESPECT OF THE SEA OF OKHOTSK ON 28 FEBRUARY 2013, United Nations. (March 14, 2014)
[20] Kevin M. Bailey, An Empty Donut Hole: The Great Collapse of a North American Fishery, Ecology and Society, Vol. 16, No. 2 (Jun 2011), Resilience Alliance Inc.
[21] Olav Schram Stokke, The Loophole of the Barents Sea Fisheries Regime, Chapter 9 in O. S. Stokke (ed.), Governing High Seas Fisheries: The Interplay of Global and Regional Regimes. Oxford University Press, 2001, pp. 273-301
[22] Laura Geggel, Neolithic People Made Fake Islands More Than 5,600 Years Ago, Live Science, (June 17, 2019). Accessed at: https://www.livescience.com/65728-neolithic-human-made-islands.html
[23] Scott N. Romaniuk and Tobias Burgers, China’s Next Phase of Militarization in the South China Sea, The Diplomat, (March 20, 2019). Accessed at: https://thediplomat.com/2019/03/chinas-next-phase-of-militarization-in-the-south-china-sea/
[24] Rebecca Staudenmaier, Europe’s overseas territories: What you need to know, DW, (November 3, 2018). Accessed at: https://www.dw.com/en/europes-overseas-territories-what-you-need-to-know/a-46145298
[25] One World Nations Online, Overseas Territories, Dependent Areas, and Disputed Territories, Territories and dependencies (31 August, 2021). Accessed at: https://www.nationsonline.org/oneworld/territories.htm
[26] Britannica, The Editors of Encyclopaedia. “Continental shelf”. Encyclopedia Britannica, 3 Feb. 2012, https://www.britannica.com/science/continental-shelf. Accessed 31 August 2021.
[27] How Stuff Works, Why are the waves on the U.S. West Coast larger than the waves on the East Coast? (April 26, 2001). Accessed at: https://science.howstuffworks.com/environmental/earth/oceanography/question623.htm
[28] PCA Case No 2014-02 /ICGJ 511 (PCA 2015)
[29] Paula de Castro Silveira and Grace Ladeira Garbaccio, Protest at Sea: the Arctic Sunrise Case and the clarification of Coastal States Rights, Scielo Brazil (June 3, 2019). Accessed at: https://www.scielo.br/j/seq/a/SfSvBCnb7M5DCtSXRvtdTJn/?lang=en
[30] Maria Chiara Noto, The Arctic Sunrise Arbitration and Acts of Protest at Sea, Maritime Safety and Security Journal, ISSN 2464-9724, Issue 2 (2016). Accessed at: https://www.marsafelawjournal.org/contributions/the-arctic-sunrise-arbitration-and-acts-of-protest-at-sea/
[31] Neha Banka, Explained: What is the Chagos Islands dispute about? The Indian Express, (November 30, 2019). Accessed at: https://indianexpress.com/article/explained/explained-why-mauritius-is-calling-uk-an-illegal-colonial-occupier-over-a-tiny-set-of-island-6142821/
[32] Patrick Wintour, UN court rejects UK claim to Chagos Islands in favour of Mauritius, The Guardian, (January 28, 2021). Accessed at: https://www.theguardian.com/world/2021/jan/28/un-court-rejects-uk-claim-to-chagos-islands-in-favour-of-mauritius
[33] Natalie Klein, Chagos: A boundary dispute tips over a sovereignty ruling, The Interpreter, (February 8, 2021). Accessed at: https://www.lowyinstitute.org/the-interpreter/chagos-boundary-dispute-tips-over-sovereignty-ruling
[34] Maninder Dabas, Everything You Need To Know About The Dispute Over Sir Creek Between India And Pakistan, India Times, (August 16, 2016). Accessed at: https://www.indiatimes.com/news/everything-you-need-to-know-about-the-dispute-over-sir-creek-between-india-and-pakistan-260071.html
[35] The Organisation for World Peace (OWP), Arctic Circle Territorial Conflicts. Accessed at: https://theowp.org/crisis_index/arctic-circle-territorial-conflicts/
[36] The Fletcher School, Tufts University, Law of the Sea: A Policy Primer, Chapter 8: The Arctic and the LOSC (2021). Accessed at: https://sites.tufts.edu/lawofthesea/chapter-eight/
[37] Article 234: Special Rights for Arctic Coastal States, UNCLOS
[38] ITLOS Case No. 23
[39] Raymond Bagulo Bening, The Ghana-La Côte D’Ivoire maritime boundary dispute, Ghana Journal of Geography Vol. 6, 2014. Accessed at: https://www.ajol.info/index.php/gjg/article/view/111136/104521
[40] Ismail Akwei, Ghana wins three-year maritime boundary dispute case against Ivory Coast, Africa News, (September 23, 2017). Accessed at: https://www.africanews.com/2017/09/23/ghana-wins-three-year-maritime-boundary-dispute-case-against-ivory-coast//
[41] Rizal Abdul Kadir, INTRODUCTORY NOTE TO CONVENTION ON THE LEGAL STATUS OF THE CASPIAN SEA, The American Society of International Law, (August 12, 2018). Accessed at: https://www.academia.edu/50381953/Convention_on_the_Legal_Status_of_the_Caspian_Sea
YLCC would like to thank Tanmay Dhiman for his valuable insights in this article.
