The obligation of States to not use force against other States is now well established in international law both on land and at sea. Unless authorized by the Security Council or based on self-defence, non-compliance with this rule is a breach of international law and may give rise to State responsibility for wrongful act. The same cannot be argued about States’ behaviour towards non-State actors. An example comes from the area of contested waters, where private oil companies authorized by one of the disputing States may be forcibly evicted or have their personnel detained by the other disputant with acts which exceed the limits of law enforcement. International law of the sea fails to determine the legality of such behaviour and the means by which the affected private actor may respond. But insofar as the law does not explicitly oblige States to respect private actors and prevents the latter from submitting personal claims to international fora, private interests in contested waters will remain unprotected against unlawful State acts.
Application of the Convention on the Prevention and Punishment of the Crime of Genocide, Preliminary Objections (1996) ICJ Rep 595 [31-32].
Arbitral Tribunal Constituted Pursuant to Article 287, and in Accordance with Annex VII of UNCLOS. Arbitration between Guyana and Suriname (Guyana/Suriname) Award (PCA 2007) ICGJ [151]; [433].
Barcelona Traction, Light and Power Company, Limited Judgment (Belgium v Spain) (1970) ICJ Rep 3 [33-34].
Brilmayer, Lea and Natalie Klein, ‘Land and Sea: Two Sovereignty Regimes in Search of a Common Dominator’ (2001) 33 Yale Law School Faculty Scholarship Series 703; 717.
Brown, Edward. ‘Maritime Zones: A Survey of Claims’, in Robin Churchill et al (eds), New Directions in the Law of the Sea Vol III (British Institute of International and Comparative Law 1973) 159.
Brownlie, Ian. Principles of Public International Law (3rd ed, Oxford University Press 1979) 691.
Burke, William. The New International Law of Fisheries: UNCLOS 1982 and Beyond (Clarendon Press 1994) 303; Klein, (2011).
Byers, Michael. ‘Terrorism, the Use of Force and International Law After 11 September’ (2002) 51 International and Comparative Law Quarterly 401; 407-409.
Case Concerning Delimitation of the Maritime Boundary in the Gulf of Maine Area (Canada/United States) (1984) ICJ Rep 294 [94].
Case Concerning the Continental Shelf (Tunisia/Libyan Arab Jamahiriya) (1982) ICJ Rep 33 [34].
Charney, Jonathan. ’Third State Remedies in International Law’, in Rene Provost (ed), State Responsibility in International Law (Ashgate 2002) 213.
Churchill, Robin, and Alan Lowe, The Law of the Sea (3rd edn, Manchester University Press 1999) 447-448.
Commentary to Art 50 of its Draft Articles on the Law of Treaties, ILC Yearbook, 1966-II, 247.
Convention on the Continental Shelf, signed on 29 April 1958, and entered into force on 10 June 1964, 499 UNTS 311. Arts 1-2.
Crawford, James. ‘The ILC’s Articles on Responsibility of States for Internationally Wrongful Acts: A Retrospect’ (2002) 96 The American Journal of International Law 874; 886-888.
Crawford, James. The International Law Commission’s Articles on State Responsibility: Introduction, Text and Commentaries (Cambridge University Press 2002) 41.
de Vattel, Emmerich. Law of Nations or the Principles of Natural Law, Applied to the Conduct and to the Affairs of Nations and of Sovereigns (translation of the 1758 ed by Charles Fenwick) (Carnegie Institution of Washington 1916) Book II, Ch VI [71].
Declaration of the Maritime Zone of Chile, Ecuador, and Peru (Santiago Declaration), 18 August 1952.
Dinstein, Yoram. The Conduct of Hostilities Under the Law of International Armed Conflict (Cambridge University Press 2004) 102-103.
Donaldson, John. ‘Oil and Water: Assessing the Link between Maritime Boundary Delimitation and Hydrocarbon Resources’ in Clive Schofield et al, The Limits of Maritime Jurisdiction (Brill, 2014) 138.
South China Morning Post <https://www.scmp.com/news/asia/article/1506633/ships-collide-vietnam-tries-stop-china-oil-rig-deployment-disputed-waters> accessed 14 August 2018.
Draft Articles on Diplomatic Protection 2006 with Commentaries, ILC Yearbook (2006) Vol II, Part Two.
Draft Articles on State Responsibility for Internationally Wrongful Acts.
Dupuy, Rene-Jean and Daniel Vignes (eds). A Handbook on the New Law of the Sea Vol I (Martinus Nijhoff 1991) 3-4.
East Timor (Portugal v Australia) (1995) ICJ Rep 90 [29].
Ebbin, Syma, et al. A Sea Change: The Exclusive Economic Zone and Governance Institutions for Living Marine Resources (Springer 2005) xi.
Fitmaurice, Malgosia and Cees Flinterman (eds), Interaction between International Law and Municipal Law – A Comparative Case Law Study (Asser) 1993.
Green, James. ‘Questioning the Peremptory Status of the Prohibition of the Use of Force’ (2011) Michigan Journal of International Law 32(2) 215-257.
Grotius, Hugo. in Mare Liberum Siue de Jure Quod Batavis Competit ad Indicna Commercia Dissertatio (The Freedom of the Seas or The Right which Belongs to the Dutch to Take Part in the East Indian Trade) (1609) (Oxford University Press 1916).
Helmersen, Sondre Torp. ‘The Prohibition of the Use of Force as Jus Cogens: Explaining Apparent Derogations’ (2014) Netherlands International Law Review, LXI, 167; 170-171.
Hossain, Kamrul. ’The Concept of Jus Cogens and the Obligation Under the UN Charter’ (2005) Santa Clara Journal of International Law 3(1) 72; 90-92.
Hurle, M. ‘Brunei-Malaysian Foreign Minister to Address Maritime Boundary with Brunei,’ IHS Daily Insight, July 7, 2003.
Ibid. ILC Report on the Work of its Twenty-Eighth Session 3 May-23 July 1976, ILC Yearbook 1976-II, 102.
Islamic Republic of Iran v United States of America, 2003 ICJ Rep, 161.
Kennedy, David. International Legal Structures (Nomos 1987) 26-27.
Klein, Natalie. Maritime Security and the Law of the Sea (Oxford University Press 2011) 63.
Kwast, Patricia Jimenez. ‘Maritime Law Enforcement and the Use of Force: Reflections on the Categorisation of Forcible Action at Sea in the Light of the Guyana/Suriname Award’ (2008) Journal of Conflict and Security Law 13(1) 49; 50-52; 69-72.
Legality of the Threat or Use of Force of Nuclear Weapons, Advisory Opinion 1996, ICJ Rep 245 [41].
M/V Saiga (No 2) (Saint Vincent and the Grenadines v Guinea), Judgment ITLOS Rep 1999, 7.
Military and Paramilitary Activities in and against Nicaragua (Nicaragua v United States of America) 1986, ICJ Rep, 94 [176].
Monte Confurco (Seychelles v France), Judgment, ITLOS Rep 2000 [71].
Mortensen v Peters (1906) 8 F (J) 93.
Nicaragua v United States of America (n31) [174-194].
Nordquist, Myron, et al (eds). United Nations Convention on the Law of the Sea 1982: A Commentary, (Virginia Commentary (Martinus Nijhoff 1985) Vol V, 67.
North Sea Continental Shelf Cases (Germany/Denmark; Germany/ Netherlands) (1969) ICJ Rep 51 [19].
Pappa, Marianthi. ’Private Oil Companies Operating in Contested Waters and International Law of the Sea: A Peculiar Relationship’ (2018) OGEL 16(1) 1; 7-9.
Proclamation of Argentina on the Epicontinental Sea, 05 December 1946.
Proclamations of US President Harry Truman with Respect to the Natural Resources of the Subsoil and the Seabed of the Continental Shelf and with Respect to Coastal Fisheries in Certain Areas of the High Seas, 28 September 1945.
Randelzhofer, Albrecht. ’Article 2(4)’, in Bruno Simma (ed), The Charter of the United Nations: A Commentary (Oxford University Press 1995) 121.
Red Crusader (Commission of Enquiry, Denmark-United Kingdom), 35 ILR 199.
Rome Statute.
S.S “I’m Alone” (Canada/United States) RIAA Vol 3, 1615.
Saiga No 2 (Saint Vincent and the Grenadines v Guinea), Judgment ITLOS (1990) Rep 10 [153], [157-158].
Saint Vincent and the Grenadines v Guinea, Judgment, ITLOS Rep 1997.
Schofield, Clive. ‘Parting the Waves: Claims to Maritime Jurisdiction and the Division of Ocean Space’ (2012) Penn State Journal of Law and International Affairs 1(1) 40; 46.
SS Lotus case (France v Turkey) (1927) PCIJ Series A No 10, 25.
The Mavrommatis Palestine Concessions (Greece v Britain) (1924) PCIJ (Ser A) No. 2.
United Nations Charter.
United Nations Convention on the Law of the Sea, signed on 10 December 1982.
United Nations Convention on the Law of the Sea.
Vienna Convention on the Law of Treaties.
Walker, Wyndham. ‘Territorial Waters: The Cannon Shot Rule’ (1945) 22 British Yearbook of International Law 210; 211-213.
Wegelein, Florian. ’The Rules of the Tribunal in the Light of Prompt Release of Vessels’ (1999) 30 Ocean Development & International Law 255; 276-277.
Weiss, Edith Brown. ’Invoking State Responsibility in the Twenty-First Century’ (2002) 96 American Journal of International Law 798-816.
2 Arts 42 and 51 UN Charter; Art 1 of Draft Articles on State Responsibility for Internationally Wrongful Acts.
3 Such events have been reported in the East and South China Seas, in the West Atlantic Ocean and elsewhere. For example, in June 2003 a Malaysian patrol boat chased away a Bruneian-contracted survey vessel of Total from an area of overlapping claims. M. Hurle, ‘Brunei-Malaysian Foreign Minister to Address Maritime Boundary with Brunei,’ IHS Daily Insight, July 7, 2003, cited in John Donaldson, ‘Oil and Water: Assessing the Link between Maritime Boundary Delimitation and Hydrocarbon Resources’ in Clive Schofield et al, The Limits of Maritime Jurisdiction (Brill, 2014) 138. In 2014, a series of collisions occurred between Vietnamese patrol boats and Chinese oil vessels close to the disputed Spratly Islands. Source: South China Morning Post <https://www.scmp.com/news/asia/article/1506633/ships-collide-vietnam-tries-stop-china-oil-rig-deployment-disputed-waters> accessed 14 August 2018. Another example is the threat extended by the Surinamese navy to Guyana’s contractor in the contested waters between the two States, analysed below.
4 United Nations Convention on the Law of the Sea, signed on 10 December 1982, and entered into force on 16 November 1994, 1833 UNTS 3.
5 Under the so-called ‘freedom of the high seas.’ This doctrine introduced by Hugo Grotius, in Mare Liberum Siue de Jure Quod Batavis Competit ad Indicna Commercia Dissertatio (The Freedom of the Seas or The Right which Belongs to the Dutch to Take Part in the East Indian Trade) (1609) (Oxford University Press 1916). According to Grotius, the sea is ‘not susceptible of occupation’ because it can ‘neither easily be built upon nor enclosed’. 28–31.
6 This rule has been attributed to Cornelius van Bynkershoek in 1702, and remained valid for the next two centuries. Wyndham Walker, ‘Territorial Waters: The Cannon Shot Rule’ (1945) 22 British Yearbook of International Law 210; 211–213; Lea Brilmayer and Natalie Klein, ‘Land and Sea: Two Sovereignty Regimes in Search of a Common Dominator’ (2001) 33 Yale Law School Faculty Scholarship Series 703; 717.
7 Rene-Jean Dupuy and Daniel Vignes (eds), A Handbook on the New Law of the Sea Vol I (Martinus Nijhoff 1991) 3–4.
8 Only between 1943 and 1973 about 70 States achieved independence, 55 of which are coastal. Edward Brown, ‘Maritime Zones: A Survey of Claims’, in Robin Churchill et al (eds), New Directions in the Law of the Sea Vol III (British Institute of International and Comparative Law 1973) 159.
9 E.g., Proclamations of US President Harry Truman with Respect to the Natural Resources of the Subsoil and the Seabed of the Continental Shelf and with Respect to Coastal Fisheries in Certain Areas of the High Seas, 28 September 1945; Proclamation of Argentina on the Epicontinental Sea, 05 December 1946; Declaration of the Maritime Zone of Chile, Ecuador, and Peru (Santiago Declaration), 18 August 1952.
10 Convention on the Continental Shelf, signed on 29 April 1958, and entered into force on 10 June 1964, 499 UNTS 311. Arts 1–2.
11 Arts 3; 57 and 76, respectively. An additional maritime belt established under Art 33(1) UNCLOS is the Contiguous Zone, which extends within 24 M from the State’s baselines. This is a buffer zone as it serves the State’s controlling rights of preventing and punishing any infringement of its customs, fiscal, immigration or sanitary laws and regulations. This zone is part of the EEZ (when the latter is claimed by the coastal State) or the high seas (in the opposite occasion). The TS, CS, EEZ are now parts of customary international law. This means that every littoral State is entitled to them, even the States which have not signed UNCLOS. See, Fisheries Case (United Kingdom v Norway) (1951) Dissenting Opinion of Judge McNair 48; North Sea Continental Shelf Cases (Germany/Denmark; Germany/Netherlands) (1969) ICJ Rep 51 [19]; Case Concerning the Continental Shelf (Tunisia/Libyan Arab Jamahiriya) (1982) ICJ Rep 33 [34]; Case Concerning Delimitation of the Maritime Boundary in the Gulf of Maine Area (Canada/United States) (1984) ICJ Rep 294 [94].
12 It is estimated that 87% of the world’s known submarine oil deposits fall within States’ CS. Clive Schofield, ‘Parting the Waves: Claims to Maritime Jurisdiction and the Division of Ocean Space’ (2012) Penn State Journal of Law and International Affairs 1(1) 40; 46. Also, 90–95 per cent of the world’s fisheries are now under national jurisdiction, pursuant to the EEZ. Syma Ebbin et al, A Sea Change: The Exclusive Economic Zone and Governance Institutions for Living Marine Resources (Springer 2005) xi.
13 Natalie Klein, Maritime Security and the Law of the Sea (Oxford University Press 2011) 63.
14 William Burke, The New International Law of Fisheries: UNCLOS 1982 and Beyond (Clarendon Press 1994) 303; Klein, (2011). See also Arts 27; 73; 105; 110; 220; 224–227 UNCLOS.
15 Art 111 UNCLOS, as exception to the rule that vessels on the high seas are subject to no other authority than their flag State, affirmed in SS Lotus case (France v Turkey) (1927) PCIJ Series A No 10, 25. This exceptional right exists insofar as the pursuit has commenced in any of the State’s maritime zones and ceases as soon as the foreign vessel enters the Territorial Sea of its own State or of a third State. Art 111 (1–3).
16 Klein (n14) 62.
17 Art 2(4) UN Charter; Art 301 UNCLOS.
18 Under Art 1 of Draft Articles on State Responsibility for Internationally Wrongful Acts.
19 Arbitration between Guyana and Suriname (Guyana/Suriname) Award (PCA 2007) ICGJ [151]; [433].
20 Ibid., [151].
21 Arbitral Tribunal Constituted Pursuant to Article 287, and in Accordance with Annex VII of UNCLOS.
22 Guyana/Suriname (n20) [445], citing S.S. “I’m Alone” (Canada/United States) RIAA Vol 3, 1615; Red Crusader (Commission of Enquiry, Denmark–United Kingdom), 35 ILR 199; M/V Saiga (No 2) (Saint Vincent and the Grenadines v Guinea), Judgment ITLOS Rep 1999, 7.
23 Guyana/Suriname (n20) [445]; [488].
24 According to the judges, Suriname had breached collectively its obligations under Arts: 2(4) UN Charter; 301 UNCLOS; 74(3) and 83(3) UNCLOS. Award (n20) [452]. Also see, Patricia Jimenez Kwast, ‘Maritime Law Enforcement and the Use of Force: Reflections on the Categorisation of Forcible Action at Sea in the Light of the Guyana/Suriname Award’ (2008) Journal of Conflict and Security Law 13(1) 49; 50–52; 69–72.
25 Saiga No 2 (Saint Vincent and the Grenadines v Guinea), Judgment ITLOS (1990) Rep 10 [153]; [157–158].
26 Ibid., [155–156].
27 Ibid., citing I’m Alone (n23) 1609; and Red Crusader (n23) 485.
28 Islamic Republic of Iran v United States of America, 2003 ICJ Rep, 161. Although this case does not involve disputed waters.
29 Ibid., [25–26].
30 Ibid., [74–78], citing Legality of the Threat or Use of Force of Nuclear Weapons, Advisory Opinion 1996, ICJ Rep 245 [41]; Military and Paramilitary Activities in and against Nicaragua (Nicaragua v United States of America) 1986, ICJ Rep, 94 [176].
31 [120]. Kwast (n25) 59; 85.
32 E.g. Guyana/Suriname (n20) [423–424]; Saiga No 2 (n26) [159].
33 Art 2(4) UN Charter.
34 Art 301 UNCLOS.
35 Nicaragua v United States of America (n31) [174–194]. For a historic analysis of this customary rule see, Kamrul Hossain, ‘The Concept of Jus Cogens and the Obligation Under the UN Charter’ (2005) Santa Clara Journal of International Law 3(1) 72; 90–92.
36 Albrecht Randelzhofer, ‘Article 2(4)’, in Bruno Simma (ed), The Charter of the United Nations: A Commentary (Oxford University Press 1995) 121.
37 Source, the United Nations <www.un.org>; <http://www.un.org/depts/los/reference_files/chronological_lists_of_ratifications.htm> both accessed 10 December 2016.
38 Ian Brownlie, Principles of Public International Law (3rd ed, Oxford University Press 1979) 691.
39 Art 2(6) UN Charter.
40 Nicaragua v USA (n31) [190] and Separate Opinion of Judge Sette-Camara 199; ILC Commentary to Art 50 of its Draft Articles on the Law of Treaties, ILC Yearbook, 1966-II, 247. cf James Green, ‘Questioning the Peremptory Status of the Prohibition of the Use of Force’ (2011) Michigan Journal of International Law 32(2) 215–257.
41 Art 53, Vienna Convention on the Law of Treaties. Other recognized examples of jus cogens are the prohibition of genocide, slavery, and racial discrimination.
42 Hossain (n36) 73–74; David Kennedy, International Legal Structures (Nomos 1987) 26–27.
43 According to Arts 53 and 64 Vienna Convention, and Arts 20 and 26 Draft Articles on State Responsibility for Internationally Wrongful Acts. Also see, Sondre Torp Helmersen, ‘The Prohibition of the Use of Force as Jus Cogens: Explaining Apparent Derogations’ (2014) Netherlands International Law Review, LXI, 167; 170–171.
44 ILC Report on the Work of its Twenty-Eighth Session 3 May–23 July 1976, ILC Yearbook 1976-II, 102; Jonathan Charney, ‘Third State Remedies in International Law’, in Rene Provost (ed), State Responsibility in International Law (Ashgate 2002) 213.
45 Barcelona Traction, Light and Power Company, Limited Judgment (Belgium v Spain) (1970) ICJ Rep 3 [33–34]. The same approach was followed in East Timor (Portugal v Australia) (1995) ICJ Rep 90 [29]; Nuclear Weapons (n31) [83]; Application of the Convention on the Prevention and Punishment of the Crime of Genocide, Preliminary Objections (1996) ICJ Rep 595 [31–32].
46 Under Art 51 UN Charter. See US military operations against Al-Qaeda and Taleban forces. Also see, Michael Byers, ‘Terrorism, the Use of Force and International Law After 11 September’ (2002) 51 International and Comparative Law Quarterly 401; 407–409; Green (n41) 237–238; Klein (n14) 268.
47 This would only be the case if that entity has acted on behalf of a State. Also, it is a different issue whether a non-State entity (e.g., terrorist group) can be prosecuted to the International Criminal Court for conducting an international crime (e.g., a crime against humanity, under Art 7 of the Rome Statute).
48 E.g., Saiga No. 2; Oil Platforms case; Guyana/Suriname.
49 James Crawford, The International Law Commission’s Articles on State Responsibility: Introduction, Text and Commentaries (Cambridge University Press 2002) 41.
50 Ibid.
51 Ibid., 40.
52 Art 33(1) Draft Articles on Responsibility of States for Internationally Wrongful Acts.
53 Crawford (n50) 127.
54 Perhaps a State might also receive authorization by the UN Security Council to respond to such attack, under Art 42 UN Charter.
55 See Oil Platforms case (n29) [74-78].
56 Klein (n14) 289; Yoram Dinstein, The Conduct of Hostilities Under the Law of International Armed Conflict (Cambridge University Press 2004) 102–103.
57 Insofar as these entities make no effective contribution to interstate attacks. Klein (n14) 290.
58 Arts 279; 286; 291(1).
59 Guyana/Suriname (n20) [401].
60 Ibid., [402].
61 Guyana/Suriname (n20) [401].
62 Although that claim was eventually dismissed by the tribunal in favour of a declaratory relief [452].
63 Arts 30–31 Draft Articles.
64 Art 304 UNCLOS.
65 Art 42 Draft Articles.
66 Art 48(1)(a) and (b) Draft Articles respectively.
67 Art 48(2) Draft Articles.
68 E.g., Guyana in Guyana/Suriname; St. Vincent and the Grenadines in Saiga 2.
69 That has not yet occurred by the time of this writing.
70 For a critical analysis see, Edith Brown Weiss, ‘Invoking State Responsibility in the Twenty-First Century’ (2002) 96 American Journal of International Law 798–816. Also see James Crawford, ‘The ILC’s Articles on Responsibility of States for Internationally Wrongful Acts: A Retrospect’ (2002) 96 The American Journal of International Law 874; 886–888.
71 Crawford (n50) 209–210.
72 Art 292(1) UNCLOS; Art 1 Draft Arts. To this day, eighteen cases concerning arrested vessels/crews have been submitted to ITLOS, nine of which requesting prompt release under Art 292.
73 A ship with every person or thing on it is considered as a unit that is under the jurisdiction and control of its flag State. Art 94 UNCLOS.
74 Myron Nordquist et al (eds), United Nations Convention on the Law of the Sea 1982: A Commentary, (Virginia Commentary (Martinus Nijhoff 1985) Vol V, 67.
75 Monte Confurco (Seychelles v France), Judgment, ITLOS Rep 2000 [71].
76 Saint Vincent and the Grenadines v Guinea, Judgment, ITLOS Rep 1997.
77 Ibid., [26–30].
78 Ibid.
79 See Dissenting Opinion of Judges: Park, Nelson, Rao, Vukas and Ndiaye.
80 Arts 286–287; 290; 295. See ARA Libertad (Argentina v Ghana); Arctic Sunrise (the Netherlands v Russian Federation).
81 Judgment (n77) [63–64].
82 Signed on 29 November 1989, and entered into force on 17 May 1991. 29 ILM 1449. Art 1.
83 Judgment (n77) 64.
84 Dissenting Opinions of Vice-President Wolfrum and Judges Yamamoto and Anderson. Also see Florian Wegelein, ‘The Rules of the Tribunal in the Light of Prompt Release of Vessels’ (1999) 30 Ocean Development & International Law 255; 276–277.
85 Emmerich de Vattel, Law of Nations or the Principles of Natural Law, Applied to the Conduct and to the Affairs of Nations and of Sovereigns (translation of the 1758 ed by Charles Fenwick) (Carnegie Institution of Washington 1916) Book II, Ch VI [71].
86 Part XV UNCLOS; Art 292 UNCLOS.
87 That is mostly the case in civil law countries. Robin Churchill and Alan Lowe, The Law of the Sea (3rd edn, Manchester University Press 1999) 447–448; Malgosia Fitmaurice and Cees Flinterman (eds), Interaction between International Law and Municipal Law – A Comparative Case Law Study (Asser 1993).
88 Mostly, in common law countries. Ibid.
89 For example, in the UK the doctrine of parliamentary sovereignty may prevail over international conventions or custom. See Mortensen v Peters (1906) 8 F (J) 93. Although a domestic statute which convicted the foreign captain of a fishing ship was contrary to international law, the court enforced it giving full effect to the intention of the Parliament. Churchill and Lowe (n89) 447.
90 The Mavrommatis Palestine Concessions (Greece v Britain) (1924) PCIJ (Ser A) No. 2; Barcelona Traction (n46). The effectiveness and the challenges associated with the international mechanisms offered by human rights law, investment law, and diplomatic protection have been analysed in a previous publication by the author. See, Marianthi Pappa, ‘Private Oil Companies Operating in Contested Waters and International Law of the Sea: A Peculiar Relationship’ (2018) OGEL 16(1) 1; 7–9.
91 ILC, Draft Articles on Diplomatic Protection 2006 with Commentaries, ILC Yearbook (2006) Vol II, Part Two.
92 Ibid.
* Email: r01mp14@abdn.ac.uk.
(2019). Forcible Acts by States towards Non-State Actors Operating in Disputed Waters: Beyond the Limits of International Law?. Legal issues Journal, 7 (1), https://www.legalissuesjournal.com/article/07-01-10012019/
