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The US-Iran Conflict and breach of international law

Research Objective: With International Law's aim to minimize global war and foster predictable procedures for the conduct of political and economic affairs among countries, the major focus of the research is to understand the relationship which US and Iran share with each other and the implications of this ongoing conflict between the two nations which has been further aggravated by the killing of Iranian general, Qassem Soleimani in 2020 on International Law. Off lately, the nations have only pulled themselves back from the brink of war where the leaders of both the nations are left evaluating what have been there gains and losses from this conflict that has been waged for years now, particularly last few months.

The study has explored in depth the strained relation which the two nations have shared from over 65 years which reached its peak with the 1979 hostage crisis and how these strained relations over time have affected the international front at large in terms of trade and global peace. The study has also deeply analyzed how the international laws have been violated keeping in mind the treaties and conventions which exist between the two nations and proposed an option for redressal by way of arbitration by the IRAN - UNITED STATES CLAIMS TRIBUNAL under the international arbitration laws.

Methodology: The study was carried out by the method of secondary research and sources. The data collected has a combination of both qualitative and quantitative data.

Us - Iran History

The two nations, US and Iran have been at odds since the time they shared interests back in 1951. This was the first time when a tension was witnessed amongst the Iranians and the foreign powers. Over the years, the points of contention for this long prevailing conflict have included issues such as US and British taking control over Iran's oil resources, the political influence of US in Tehran, the growing desire of Iran to acquire nuclear power, and the mutual growing influence which both the concerned nations started to have in the Middle East. The strained relations between both the nations date back to over 65 years which has ranged from the CIA-orchestrated overthrowing of the Prime Minister of Iran to the ongoing tension and confrontation under President Trump.

In 1951, there was a tension over the British influence in Iran. The British Government has an influence in Iran from the early 1900s where through the Anglo Iranian Oil Company, the British Government had retained control over the oil resources of Iran. This act of asserting control over the oil resources of the nation resulted in a hue and cry with the Iranians wanting to regain control over their natural resources. By this time, Mohammad Mossadegh was appointed as the 35th Prime Minister of Iran and held office from 1951-1953.

Following this, in 1953, Mossadegh was overthrown by the CIA and Iran witnessed a situation where its democracy was overthrown by a coup to which US extended its help. The development of the conflict between the two nations started from this period in the history of both the nations as following this act, the Iranians started to develop anti-American sentiments. This action was carried out by US in support of Iran's monarch, Mohammad Rese Pahlavi to rule as the Shah of Iran. Such a foreign intervention was resented by the Iranians resulting in the start of the history of US - Iran conflict.

In 1957, the US and Iran had jointly signed a cooperation which was concerning the civil uses of atoms. This cooperation was seen to be a civilian nuclear cooperation signed through the atoms for peace program.
Ahead of this cooperation by the two nations, the nations saw a period from 1959-1968 which was concerned with nuclear research and nuclear non-proliferation. They saw the opening of the Tehran Nuclear Research Center at the university of Tehran by Reza Shah Pahlavi as he began seeking materials and technology form the US. Later during these years Iran became a signatory to the treaty on non-proliferation of the nuclear weapons. Iran was allowed to maintain a civil nuclear program in exchange for a commitment to not acquire any nuclear weapon.

After the phase of nuclear research and nuclear non-proliferation, Iran saw a decade from 1963-1973 which has been seen as a time when Iran enjoyed impressive economic growth. While Iran enjoyed its economic growth, in the background, Shah's autocracy could be seen at a rise too. As this continued to happen, there was a resentment against Shah and US which as building through mosques with the help of Ayatollah Ruhollah Khomeini. In 1964, Khomeini was forcefully sent to exile but his resentment continued.

Following this decade came one of the turning points in the history of the two nations. In 1979, Iran saw a revolution which is knowing as the Iranian Revolution. This period in the history of Iran saw people taking to the streets to protest against Shah's regime. His regime was largely seen as corrupt and illegitimate by the people of Iran. Shah on January 16, 1979 announced that he is leaving Iran to go on a vacation which was seen as the end of his regime by the people of Iran.

From 1979-1981, the history of the nations saw the Iran Hostage Crisis which took place after the revolution where Shah fled the country and Ayatollah took over as the Prime Minister. Dozens of Americans were taken hostage after the Iranian students took to the US embassy in Tehran. Their reason behind doing this was to demand US to send back Shah who had been admitted there for cancer to stand trial for crimes against the Iranian people.

The two nations had already been in terms of conflict when during the Iran - Iraq war in 1980, US backed Iraq in its invasion of neighboring Iran which further strained the relation between US and Iran. This was the time when Qassem Soleimani joined the Iran Revolutionary Guard Corps. Even today, we see that US claims the Islamic Republic a state sponsor of terrorism. This was first declared by US under the administration of Reagan in the year 1984.

In 1986, president Reagan started to look for ways to improve its strained relations with Iran while continuing to back Iraq in its war with Iran. During this time, Americans were held hostage in Lebanon by Hezbollah, a militia which had close ties with Iran.

In 1988, US shot down a civilian airline, Iran Air Flight 655 where everyone on board is killed. US claims this act to be an accident whereas Iran sees it to be intentional.

After Soleimani was appointed as the head of the Quds Force in 1997, George Bush declared Iran as a part of an ‘Axis of Evil' in 2002. This followed after the 9/11 attacks where Iran extended its help to the US forces in its war against the Taliban which is a mutual enemy of both the nations. But President George Bush turned its back towards Iran in a State of the Union Axis.

In 2003, US started to voice its concerns alleging that Iran had been attempting to develop nuclear weapons and that the inspectors from the International Atomic Energy Agency have found traces of highly-enriched uranium at a nuclear plant in Iran. Even though Tehran agrees to stop the production, this a short-lived as soon after President Mahmoud Ahmadinejad came into power and restarted the production.

The final phase in the history of the two nations before Trump took over the office in 2017 is when Iran signed nuclear deal in 2013 years after negotiations with the then president of the US, Barack Obama. This deal has been a massive breakthrough for both the nations which have long been at odds with each other.

Current Relation Between Us And Iran

As already explained above the US and Iran have had a long-drawn history of war, premised on Saudi Arabia being the ally of USA and the proxy war between Iran and Saudi Arabia.

in the contemporary world the issue between the two countries can be dated back to the year 2015, when after almost two years of deliberation president Obama signed the Joint Comprehensive Plan of Action (hereinafter cited as JCPOA), which Iran had signed with a group of world powers (P5 +1). Under the accord Iran agreed to limit its sensitive nuclear activities and allow international inspectors in return of removing economic sanctions against it.

Just after 3 years on 8th may 2018 United states finally withdrew from the agreement after president Donald Trump signed a presidential memorandum ordering reinstatement of harsher sanctions.

This stunt of USA strikes animosity between the two countries. An oil tanker was shot down in Saudi Arabia, which US states was done by Iran, which was nothing more than a mere pretense. After this US drones were shot by Iran sating that they were in Iranian territory. Post this on 8th April 2019, Donald trump declared Islamic revolutionary Guard Corps that is a regulated army of Iran as a terrorist organization, in response to this Iran declared USA as a state sponsor of terrorism

The tensions consummated on December 27 2019, when a rocket attack on Iraqi military base, killed a US contractor and injured several other US service men, in defense to this US carried out strikes on sites in Iraq and Syria belonging to Kata'ib Hezbollah.

On December 31 2019, Pro-Iranian protestors in Iraq broke into the heavily fortified US embassy, and the final retaliation to this was the barbaric act of US killing Qassem Soleimani on 3rd January 2020, the head of Iran's elite quads force.

This left the whole world in a frenzy, because of the fact that general Soleimani was a sought of national hero for Iran, and his death could have long term ramifications for the world as a whole.

Political And Economical Implications Of The Us - Iran Conflict

The recent escalation in the US - Iran tension after the January 2020 event has had implications for both the nations. The crisis which followed after US killed the Iranian general Qassem Soleimani in an airstrike had seen retaliatory missile strike against 2 of US's airbuses from Iran's side. Even though this crisis has been seen to be short-lived with a war being avoided, these dangerous precedents established by both the nations have resulted in political implications.

Following the distress from the death of Soleimani, US has seen its persuasion in the Middle East declining and being taken over by influential great powers such as Russia, Turkey, Saudi Arabia, Iran, and China. While Iran continues to grow its influence outside its borders with its extra territorial operation capabilities, the international actors who are acting as the periphery players in this situation are taking advantage of the increased and recent tension between the two nations. One of such periphery players is Russia which has come out in support of its ally Iran to save it from US by sending forces and selling arms in the middle east. It has also been seen that the growing conflict between both the nations would result in a disaster for the Gulf countries.

We see that this conflict has a huge international impact. Keeping in mind the international impact of this conflict, the 2020 elections in both the nations, even though a domestic matter, could be a turning point in the international impact this conflict has had for over 65 years now. The 2020 elections can either bring a greater risk for both the nations and the international community at large or an opportunity for both the nations to settle their dispute and bring in peace. All along the 20th century it has been observed that Iran's strategic location and its noteworthy energy assets has had nations like British, Russia, and the US in acquiring interest to compete with each other to gain control over Iran.

The increased tension between the two nations has also resulted in trade barriers and a decline in economy not just in respect to these nations but also worldwide. The strict sanctions on Iran's oil trade has always been a reason for the path of Iran's economic downfall. In the year 2018, the reinstated sanctions started to be a reason for the further downfall of Iran's economy which was already deteriorating. It has been seen that President Trump's main motive behind nullifying foreign investments in Iran has been to hamper the primary source of Iran's revenue generation. These sanctions have barred trading relations with Iran which is leading to economy inflation, worsening with each day.

Analyzing the trends in the relation of US and Iran, it is seen that the oil prices in America witness a surge every time there is conflict situation in the middle east as there is a decrease in the supply of oil and gasoline. The demand of oil and gasoline increases while the supply becomes stagnant due to heavy prices of import.

However, the recent developments in the history of US suggest that it is not as dependent on the middle east as it used to be in the 20th century, leaving US in a better place than before with such rise in oil prices currently. At present, US is seen to be the world's largest producer of crude oil which makes the situation optimistic looking for the nation. The US economy will not be at the receiving end of the economy downfall as much as Iran even if the oil prices continue to rise due to the heated tension in the middle east. The US economy will see a benefit if the oil prices face an increase as it is the largest supplier of crude oil.

This would also result in US being able to call off the agreements which the nation's government had signed with the middle east nations in desperation of oil. If US is able to thrive in the present situation, it will not require the help from the middle east nations in the coming years. This move by the US has been seen to be a compelling economic theory being taken up the US government which would soon prove to be a game-changer for the American economy.

While US and Iran continue to have its share of ups and downs in the economy due to the ongoing conflict and tension prevailing in the middle east countries post the move of the US government to kill Soleimani, it is also the world's economy which has been impacted due to this. The present turmoil in the middle east seems to not be able to resolve by itself which will result in the entire world seeing the rates of oil reach new heights. With an increase in the tension, we see that the security in the transportation of oil from the middle east to other is increased.

The stringent security results as a barrier in the export which in turn results in increased prices. Along with US and Iran, if we consider the situation of India at present with the declining GDP, India is at the end of facing a major blow due to the increased prices as India is greatly dependent on the middle east for oil imports.
The tension between the two nations have also threatened the safety of the world ships which are moving in the Strait of Hormuz.

The Strait of Hormuz is a narrow body of water which connects the Persian Gulf to the Gulf of Oman, feeding into the Arabian Sea and is the most important point for the world's oil supply as 21 million barrels pass through that strait every day which amounts to $1.2 billion worth of oil. Iran in one of its possible retaliatory moves as is seen can close the strait which would stop the oil tanker traffic, disrupt global oil supply, and send the prices to surge drastically.
Thus, the US - Iran conflict is an eminent threat to the oil industry of the world as it will hamper the prevailing trade relations, leaving the economy of lot of nations in shock.

International Law Violation

There have been a plethora of international law violations over the span of half a century of animosity between both the countries, whereas some of these are such that even go as far as violating the UN charter.

The violations have been divided into there issues:

  1. Whether USA violated international law while unilaterally withdrawing from the Joint comprehensive plan of action?

    Deducing whether there was international law violation on part of USA while withdrawing from this accord is a complex task. From the initial stages it was clear that the JCPOA was not a treaty and therefore was not based upon the principle of pacta sunt servanda upon which treaties are based and made binding. However, it was an agreement between the parties, and at the international level such agreements are only political in nature and the parties can withdraw unilaterally, without inviting any international law violations.

    The point of contention in the current agreement lies in the fact that the JCPOA was endorsed by and incorporated into the UN security council Resolution 2231 (2015)[1]. Here Articles 25 and 48[2] of the UN charter state that the UN member states agree to carry out the decisions of the UN charter in accordance with the present charter, which would, mean that such decisions are binding under international law , whereas mere recommendations of the United Nations Security Council (hereinafter cited as UNSC) don't hold any binding power which was also held by the International Court of Justice. Now whether a provision has to be understood as a nonbinding recommendation or a binding decision, depends upon the precise language of the resolution.

    Resolution 2231 calls upon all UN member states to take such steps as would help in the implementation of the JCPOA, now the interpretation of this is varied and some may only take this to Hortatory, that is a non-binding expression in the security council parlance. Although an advisory opinion of the ICJ in 1971, that a security council resolution, calling upon the UN member states to refrain any dealings with the government of South Africa was held as binding under the UN charter. But herein the ICJ based its judgement upon the historical context of the provision, rather than in the categorical sense of the word.

    Now even though the International Atomic Energy Agency (hereinafter cited as IAEA) confirmed Iranian compliance with the JCPOA, the Trump administration withdrew from it. Not only this, the trump administration is now targeting countries around the world for re engaging with Iran economically, with this act, what the US has done is weaponize its economy. It is a clear rejection of diplomacy and multilateralism, a clear call for confrontation rather than cooperation; an invitation to restoring to the logic of force, rather than the force of logic. Although the act of USA might seem wrong on a political level, the law still remains equal and without bias and therefore to determine whether US is in any breach of its obligations, the relevant authority (ICJ) will have to determine the context in which the act has been made and put into force.
     
  2. Whether USA's act of killing Qassem Soleimani, was arbitrary and against the laid down provision self-defense under International Law?

    The US Iran issue is just more than just mere geopolitical and economic animosity. There are a plethora of norms and laws under the domain of international law that have been violated by both the nations. The first and the most prominent being the killing of Qassem Soleimani, head of Iran's elite Quads force.

    International law has been a vide subject from the very start and covers under its ambit both codified laws (treaties, accords) and customs, evidence of general practice accepted as law[3].

    Article 51 of the UN charter talks about self-defense-

    Nothing in the present Charter shall impair the inherent right of individual or collective self-defence if an armed attack occurs against a Member of the United Nations, until the Security Council has taken measures necessary to maintain international peace and security. Measures taken by Members in the exercise of this right of self-defence shall be immediately reported to the Security Council and shall not in any way affect the authority and responsibility of the Security Council under the present Charter to take at any time such action as it deems necessary in order to maintain or restore international peace and security.[4]

    Besides article 51, another important source with regards to self-defence is the Caroline case[5], wherein the British had seized and destroyed a vessel in an American port , because it had been supplying American nationals, which had been conducting raids into Canadian territory Post this the US secretary of state in correspondence with the British authorities, laid down the essentials of self-defence, a necessity of self-defence, instant, overwhelming, leaving no choice of means, and no moment for deliberation. This was held in consonance with the belief that not only these were the essentials of self-defence, but also the harm that is inflicted in exercise of such right should not be excessive or unreasonable but proportionate[6].

    In the issue in hand the right of self-defence has to been seen from a pre-emptive perspective. US president Donald Trump, said, after the attack, that the US expected an imminent attack, that would cause harm and danger to American nationals. USA had shot down the Irani general in Baghdad, thus an important contention that arises of this is that did this act of US , violate any international norms.

    The Issue of pre-emptive or anticipatory self-defence has seen quite the conundrum over the years. This concept dates back to when Israel in 1967 launched a strike upon its Arab neighbours, upon the blocking of its port in Eilat and the consummation of a military pact between Egypt and Jordan, which was followed by mobilisation of Egyptian troops on Israel's border, the eviction of United Nations Peace keeping forces by Egypt's President[7]. This was regarded as a valid case of anticipatory self-defence. The major issue with this is that it involves fine calculations of the various moves by the other party, that is that a pre-emptive strike embarked upon too early may lead to aggression. Drawing the line between what might be proportionate and aggression is difficult.

    One other suggestion is to distinguish anticipatory self-defence, where an armed attack is foreseeable from interceptive self-defence, where an armed attack is imminent, so that there are no evidential problems and the nation do not suffer in making a choice between violating international norms and facing the actual assault.

    US in its statements made to the United Nations is justifying its killing of the Iranian Commander Qassem Soleimani as an act of self-defence. It has also in its statement said that US would be willing to take additional actions which it will feel is necessary to protect the US. Iran in its statement says that their act is a proportionate measure under Article 51 of the United Nations Charter.

    While both the nations are justifying their acts under the UN charter, US has shown an interest in wanting to engage in negotiations with Iran without any preconditions to uphold the international peace and security and eliminate further aggravation of the matter. To conclusively determine whether USA attacked under genuine self- defence or ,is just taking the garb if it, is a difficult question of fact and law that can only be determined upon seeking judicial intervention.
     
  3. Whether Iran has violated the Non-proliferation treaty and which provisions of international law have been breached by it?

    The Non-prefiltration Treaty (hereinafter cited as NPT) is an international treaty whose objective is to prevent the spread of nuclear weapons and weapons technology. The NPT defines Nuclear weapon states as those states that have built and tested a nuclear explosive device before 1st January 1967; these are USA, China, France, Russia and UK. The objective upon which the NPT is that the nuclear weapon states agree to share peaceful benefits of Nuclear technology and pursue their Nuclear disarmaments and ultimate elimination of their nuclear arsenals, the non-nuclear states in exchange agree t never acquire Nuclear weapons.

    Iran has been a part to the NPT after its ratification, but a sought of rhetoric has been played by Iran in outright denying any /all allegations of it violating provision soft the NPT. In the year 2002, 2003, under intense international pressure, Iran's leadership made a decision to issue extensive declarations to the IAEA about its nuclear program.

    It enlisted a string of provision that it had violated and also proposed corrective action for the same. Besides this the Iranian Atomic Energy Organisation (hereinafter cited as AEOI) tried to hide many of its nuclear activities and sites, which the IAEA found out in the summer of 2003. Over the years IAEA has found out and reported plethora of such provisions that have been violated by Iran but have met with little or no success.

    Specifically Iran has violated provisions with respect to Uranium imports i.e. it had purchased Uranium from China in 1991 and subsequently transferred it for further processing, hidden sites i.e. Iran did not declare to the IAEA the existence of a pilot enrichment facility at the Kalaye Electric Company Workshop, and laser enrichment plants at the Tehran Nuclear Research Centre and at Lashkar Ab'ad[8]. Besides this there are a plethora of other provisions that have been violated by Iran.

    Therefore, on this front it is per se clear that the treaty was violated by Iran and the provisions of the treaty were not followed in letter and spirit and therefore proper judicial redressal mechanisms should be opted for.

Option For Redressal
The increasing conflict between the two nations has arisen a need for the international community to work towards settling the dispute to bring peace and harmony and restore normalcy of political relations as well as trade relations between US and Iran and other nations as well. International Arbitration is seen as an effective method during such times. International Arbitration is seen to be the most effective way of resolving a conflict which helps the parties by offering them a final and binding solution when they are unable to agree upon settlement and this is done without taking the parties to the court.

The long prevailing conflict history of US and Iran resulted in the establishment of the Iran - United States Claims Tribunal (hereinafter cited as IUSCT) on 19th January, 1981. The main motive behind the establishment of the IUSCT was to resolve the crisis in relations between the two nations arising out of the November 1979 hostage crisis at the United States Embassy in Tehran, and the subsequent freezing of Iranian assets by the United States of America.[9]

The IUSCT was established when Democratic and Popular Republic of Algeria started to look for a mutually acceptable solutions while serving as an intermediary. After extensively consulting with both the governments as to what commitments each of them was ready to make in order to resolve the ongoing crisis, these commitments were recorded into two declarations after which the IUSCT was established. These declarations were known as the General Declaration and the Claims Settlement Declaration which was collectively referred to as the Algeris Declaration which was to be followed by both Iran and United States.

The question before us is why should the nations resort for international arbitration as a means to resolve the conflict. As it has been seen that the IUSCT was established after the Hostage Crisis in 1979, this, thus makes the purpose of the establishment of the tribunal exclusive. The tribunal is seen to be different from other international arbitral tribunals as it is not an ad-hoc body which has been established for a single case, but it has been established to resolve the various issues which arise out of a particular event. Seeing the history that both the nations share; it can be ruled out that the strained relation between the two nations had its starting point even before 1979 but reached its peak with the hostage crisis that year. Thus, a lot of the problems which the nations share today has arisen out the 1979 hostage crisis.

A better understanding of the reason behind the creation of the tribunal has been explained in the following commentary:
Historically, international claims tribunals have been created at the end of a period of conflict... with the goal of resolving outstanding disputes between the participating governments, in the context of resumed diplomatic and commercial relations. In contrast, this Tribunal was established in the midst of intense political confrontation by governments which had (and continue to have) neither diplomatic relation nor the … objective of reestablishing such relations.[10]

By going into a voluntary arbitration, the participating governments as per the rules established by the ISUCT would presenting the case in front of a tribunal consisting of nine members, three of which would be appointed by both the governments each and the remaining three would be appointed by the already appointed arbitrators of the two nations. Herein, the place of arbitration would be decided by means of Article 17 of the United Nations Commission On International Trade Law Rules (hereinafter cited as UNITRAL Rules) as it is expressed in Article 16 of the Tribunal Rules and Procedures.

If the parties have not through an arbitration clause in the contract agreed upon the place of arbitration, the place of arbitration will be decided by the arbitral tribunal within the country mutually agreed upon by the parties, where the award would be made.

Previously as well, the tribunal has made settlements between the nations which have been unique and signification in the arbitration history of these nations as well. One of the most significant settlements which the tribunal has made has been in the year 1996 when Iran witnessed a tragic drowning of its flight Iran Air Flight 655 on 3rd July, 1988. Post this, Iran sought condemnation from the International Civil Aviation Organization (hereinafter cited as ICAO). Iran further moved to the International Court of Justice (hereinafter cited as ICJ) after it was unhappy with the response which the ICAO gave.

However, it was on 8th August, 1994 when the two nations jointly advised the ICJ to hold the hearing of the case and settlements were executed between the two nations in 1996. International Arbitration, if seen from the procedural perspective and that of international dispute resolution, is beneficial to the individuals who are the parties to the arbitration as well.

The next logical step after the statement made by US in the United Nations Security Council stated its intentions to enter into negotiations with Iran without any preconditions is to consider entering into an arbitration process. The arbitration process would be a speedier process that moving to the ICJ to settle the dispute and would effectively bring positive change in the relationship between the two nations.

Conclusion
The US - Iran conflict is one that has been going on for more than half a century and has had a major part in shaping the way in which geopolitical diplomacy and relations work all around the world. The conflict is also the main reason for the involvement of US in the middle east, which has been lambasted by different world leaders. The exit of US from the JCPOA and rhetoric of both countries against each other have again given rise to intense tensions between both the countries as well as their allies, accompanying this are the innumerable violations of NPT committed by Iran.

All this forms a complex web , which is entangling more and more countries with the passage of time. Some have also gone as far as saying that this conflict will bring the advent of World War III, statements like these make us repose our faith in judicial mechanisms at the international level. Thus, diplomats around the world should focus on cooperation rather than conflict, and should focus their efforts on resolving this issue.

End-Notes:
  1. Stephen P. Mulligan , Withdrawal from the Iran Nuclear deal: Legal authorities and implications ,Congregational Research Service , May 17, 2018 , 11:19 A.M , https://fas.org/sgp/crs/nuke/LSB10134.pdf
  2. Charter of the United Nations, Article 25 , Article 48
  3. Statute of the International Court of Justice, Article 38(1)(b)
  4. Charter of the United Nations, Article 51
  5. 29 BFSP, p 1137 and 30 BFSP, p.195
  6. 6, MANCLOLM N SHAW, INTERNATIONAL LAW, 1131, (6th e.d 2008)
  7. 3, J.N. MOORE, THE ARAB ISRAELI CONFLICT (3rd ed. 1974)
  8. Jacqueline Shire and David Albright , Iran's NPT violations - Numerous and Possibly whats going on ? , ISIS ,( Sept 29 2006 , 2:08 P.M ) , https://www.isis-online.org/publications/iran/irannptviolations.pdf
  9. IRAN UNITED STATES CLAIMS TRIBUNAL, Jan 19 1981 ,http://www.iusct.net/
  10. Selby & Stewart, practical aspects of arbitrating claims before the Iran-united states claims tribunal, 18 INT'L LAW. 211 (1984)
Written By:
  1. Samarth Suri - Symbiosis Law School, NOIDA, BA. LLB., 1st year, B-802, Shipra Neo, Indirapuram, Ghaziabad - 201014, Uttar Pradesh
    Email: [email protected], Ph no: +91 8727803499
  2. Yashassvi Periwal - Symbiosis Law School, NOIDA, BA. LLB., 1st year, V-1801, Hyde Park, Sector 78, Noida - 201301, Uttar Pradesh
    Email: [email protected], Ph no: +91 9073115936

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