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Maritime Delimitation and Territorial Questions (Qatar v. Bahrain)

International Court of Justice
1994 I.C.J. 112


Facts

Qatar (plaintiff) brought suit against Bahrain (defendant) in the International Court of Justice (ICJ) to determine whether two exchanges of letters between the countries constituted international agreements establishing a jurisdictional basis for the ICJ to hear all disputes between Qatar and Bahrain. The first letter was drafted by the Amirs of Qatar and Bahrain through the mediation of the King of Saudi Arabia in 1987. The second document, titled “Minutes” had been signed in Qatar by the Ministers of Foreign Affairs of Bahrain, Qatar, and Saudi Arabia. Qatar argued that the two documents were international agreements creating an obligation for Qatar and Bahrain to submit to the ICJ the whole of their dispute involving sovereignty over certain islands, sovereign rights over certain sholas, and the delimitation of a maritime boundary between the two States. Bahrain argued that the two documents did not constitute international agreements, and that Qatar did not have a jurisdictional basis for bringing a unilateral suit in the ICJ. The ICJ found that both the 1987 and 1990 exchanges and their resulting documents constituted international agreements. Thus, the ICJ concluded that it had jurisdiction to hear the sovereignty and boundary disputes between Qatar and Bahrain.

Rule of Law

Issue

Holding and Reasoning

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