He holds the following degrees: Bachelor's degree in law (1965), University of Madagascar, Antananarivo; diplôme from Madagascar National School of Administration (1966); trainee in the Judicial Division of the Conseil d'Etat, Paris (1965–1966); diplôme d'études supérieures de sciences politiques, University of Paris, Faculty of Law and Economic Science (1966); diplôme d'études supérieures de droit public, University of Madagascar (1967); Doctorate of Law, Panthéon-Assas University (thesis: "La succession d'organisations internationales en Afrique"); agrégé of the Faculties of Law and Economics, Public Law and Political Science section, Paris (1972).
He served as Vice President of the ICJ from 2003 until 2006 and has been a Member of the Court since 1991, having won reelection in 2000. Prior to his election to the Court, he was a Professor of Law at the University of Madagascar from 1981 to 1991, the same university he earned a B.A. from in 1965. In addition, he served as a Lecturer at the Hague Academy of International Law in 1987 and 1997.