Corfu Channel case
|The Corfu Channel Case|
|Court||International Court of Justice|
|Full case name||Corfu Channel (United Kingdom of Great Britain and Northern Ireland v. People's Republic of Albania)|
|Decided||9 April 1949
15 December 1949 (compensation)
Bohuslav Ečer (ad hoc)
|Judges sitting||José Gustavo Guerrero (Acting President)
Jules Basdevant (President)
Charles de Visscher
Sir Arnold McNair
Abdel Badawi Pasha
Bohuslav Ečer (ad hoc)
The Corfu Channel case (French: Affaire du Détroit de Corfou) was a public international law case concerning state responsibility for damages at sea, as well as the doctrine of innocent passage. It was a contentious case, and the first case of any type brought before the International Court of Justice (ICJ) following its establishment in 1945.
Following a series of encounters in the Corfu Channel between the Royal Navy and the People's Republic of Albania—one of which resulted in two ships damaged and significant loss of life—the United Kingdom brought suit in the ICJ seeking reparations. Following an initial ruling on jurisdiction, the ICJ issued separate merits and compensation judgments in 1949. The ICJ awarded the United Kingdom £843,947. This amount remained unpaid for decades, and British efforts to see it paid led to another ICJ case to resolve competing Albanian and Italian claims to more than 2,000 kilograms (4,400 lb) of Nazi gold. In 1996, Albania and the United Kingdom settled the judgment along with Albania's outstanding claim to the gold.
The Corfu Channel case has had a lasting impact on the practice of international law, especially the law of the sea. The concept of innocent passage discussed in the merits decision was ultimately adopted in a number of important law of the sea conventions. The stance adopted by the Court on the use of force has been of importance in subsequent decisions, such as Nicaragua v. United States.
- 1 Corfu Channel incident
- 2 Case history
- 3 Outcome
- 4 Satisfaction of debt
- 5 Legacy
- 6 See also
- 7 Notes
- 8 References
- 9 Further reading
- 10 External links
Corfu Channel incident
In 1946, a series of three encounters between Royal Navy ships and the armed forces of the People's Republic of Albania in the Corfu Channel took place. The Corfu Channel, considered an international strait, passes through Albanian territorial waters. During the Greek civil war, the Royal Navy was engaged in intelligence-gathering activities, and their vessels regularly passed through the Corfu Channel.
On 15 May, the cruisers HMS Orion and HMS Superb passed through the northern part of the Corfu Channel. Albanian shore batteries opened fire on the two ships, striking neither, though coming as close as 200 yards (180 m) to the squadron. The United Kingdom formally protested, and demanded an apology from Albania. In response, the Albanian government claimed that the two ships had trespassed in Albanian territorial waters, and asserted that future passage through the Corfu Channel required the permission of Albania. A United Kingdom diplomatic note dated 2 August stated that Royal Navy ships would return fire in the future. Later in September, a cable to fleet command requesting information on planned naval activities in the North Corfu Channel triggered the dispatching of four ships in October.
On 22 October, a Royal Navy flotilla composed of cruisers HMS Mauritius and HMS Leander, and destroyers HMS Saumarez and HMS Volage entered the Corfu Channel. At around 2:53 p.m., Saumarez struck a naval mine and was heavily damaged; thirty-six were killed. Volage took her in tow, only to strike a mine herself at 4:16 p.m.; eight were killed. In the end, forty-four died and forty-two were injured between the two ships, and Saumarez was damaged beyond repair. Shore batteries in the vicinity were observed from the ships, but they took no action. At one point, a boat flying an Albanian ensign and white flag approached Volage to ask what the ships were doing.
From 12 to 13 November, the Royal Navy undertook a mine clearance operation in the Corfu Channel. Called Operation Retail, this activity took place in Albanian territorial waters, but without the advance permission of the Albanian government. Following this operation, the Albanian government formally complained to the United Nations, describing the Royal Navy's operation as an incursion into Albanian territorial waters.
On 9 December, the United Kingdom formally demanded reparations from Albania. In response, Albania denied its involvement in the laying of mines, blaming Greece. Following this, in January 1947, the United Kingdom attempted to involve the Security Council. Russia objected to this, but the Security Council heard the British complaint nonetheless. A fact-finding committee consisting of Poland, Australia and Colombia reached no conclusions despite ten meetings. A Soviet veto, supported only by Poland, blocked a resolution that would have accused Albania of being indirectly responsible for the minefield. The Security Council passed a resolution on 9 April 1947, Russia and Poland abstaining, calling for the United Kingdom and Albania to resolve the dispute in the ICJ. On 22 May, the United Kingdom brought suit against Albania in the International Court of Justice. This was captioned as the Corfu Channel case. The ICJ, being in permanent session, was available to begin promptly. Despite a long backlog of matters for consideration, the case was given priority and considered first.
Lead counsel for Albania was Pierre Cot, then a Radical Deputy in the French National Assembly. During the preliminary objections portion of the case, Albania's team consisted of Professors Vochoč and Lapenna of the University of Prague and University of Zagreb, respectively. They were replaced by Joë Nordmann, Marc Jacquier and Paul Villard following the decay of Albanian-Yugoslav relations in 1948. These three were respected members of the French bar and affiliated with the French Communist Party. Nordmann had also been involved in the French prosecutorial team during the Nuremberg trials.
Representing the United Kingdom initially was then-Attorney General Hartley Shawcross, who had been chief prosecutor for the United Kingdom at the Nuremberg trials. After initial statements, Shawcross left, and was replaced by then-Solicitor General Frank Soskice. Eric Beckett, legal counsel for the Foreign Office, was also a major member of the legal team. Additional support came from Hersch Lauterpacht, Humphrey Waldock, Richard Wilberforce, J. Mervyn Jones and M. E. Reed. At one point, H. V. Evatt, then Australian Minister of External Affairs, offered his assistance. Jean-Pierre Cot stated that this offer was a problem for the British Foreign Office, as Evatt could only have served as lead counsel; instead it was suggested that he represent the United Kingdom in a different case, which he declined.
The United Kingdom submitted its application with the ICJ on 22 May 1947. This application was brought unilaterally, without any negotiation with Albania to form a special agreement to submit the matter to the ICJ. Jurisdiction was claimed under Article 36, Paragraph 1 of the ICJ Statute. Albania submitted a letter on 2 July 1947, which in part accepted the Security Council's recommendations. Bancroft and Stein noted that the Albanian letter dated to when the Albanian application for admission to the UN was before the Security Council. Shortly after 23 July, the President of the ICJ issued an order setting the deadlines for each party's submission of memorials. The United Kingdom was to submit its memorial by 1 October, and Albania by 10 December. The memorial for the United Kingdom was filed by its deadline.
On 9 December, Albania submitted an objection to the application of the United Kingdom, arguing that a special agreement was the only way the case could validly be brought. Specifically, Albania argued that Articles 26(1) and 40(1) of the ICJ Statute only allowed proceedings to be instituted by special agreement where at least one party was a state not otherwise bound to submit to the Court's jurisdiction, and that no such agreement had been formed between the United Kingdom and Albania. In contesting the United Kingdom's claims, the Albanian objection argued that the Security Council resolution was not itself sufficient to compel Albania to accept ICJ jurisdiction; that Albania's acceptance of the obligations of a UN member state did not constitute the requisite due and express acceptance of ICJ jurisdiction under the ICJ Statute; and that the Security Council resolution had no binding force.
On 10 December, the ICJ President set the United Kingdom's deadline to respond to the objection as 20 January 1948. The ICJ delivered its judgment on the objection on 25 March, voting fifteen-to-one, with Igor Daxner—Albania's designated ad hoc judge—as the sole dissenter. In its judgment, the ICJ upheld its jurisdiction on the grounds that Albania's 2 July 1947 letter constituted Albania's voluntary submission to its jurisdiction. After the judgement, the parties submitted a special agreement certifying two questions to the ICJ. These questions were: Whether Albania was responsible for the incidents, and whether the United Kingdom violated Albanian sovereignty. The ICJ accepted the special agreement as the basis for all further proceedings in the case on 26 March.
Deciding the merits
At one point during the merits case, the Socialist Federal Republic of Yugoslavia desired to submit evidence, but without invoking Article 62 of the ICJ Statute to join the case as an intervening state. This was in response to the United Kingdom's arguments that Yugoslavia and Albania had worked together in mining the Corfu Channel, and the presentation of evidence from a former officer of the Yugoslav Navy, Karel Kovacic, to that effect. On 8 November 1948, Yugoslavia published and transmitted to the ICJ a communiqué arguing against the witness's credibility and denying the claim that it was complicit in the mining of the Corfu Channel. Yugoslavia also passed documentary evidence to Albania, which the Agent for Albania filed; while these were not admitted as evidence, an agreement with the United Kingdom permitted them to be used to examine a witness. Yugoslavia's participation in the case also went to giving assistance to the committee of experts that subsequently visited the Corfu Channel.
In a 1948 order, the ICJ called for the assembly of a committee of experts in accordance with Article 50 of the ICJ Statute. This committee consisted of one naval officer each from the Royal Danish Navy, Royal Norwegian Navy and Swedish Navy. They were formally appointed in an ICJ order of 17 December. These officers were Commodore S. A. Forshell, Lieutenant Commander S. J. W. Elfferich and Commodore J. Bull, respectively. They were accompanied by the Deputy-Registrar of the ICJ, as well as Commander E. R. D. Sworder of the Royal Navy and Captain Barnimir Ivanov Ormanov of the Albanian Naval Force. After the committee gave its first written report, the ICJ decided to request an on-the-spot enquiry.
One important matter that arose during the merits case were two Royal Navy documents, referred to as XCU and XCU1, which comprised the sailing orders for the flotilla to sail on 22 October. XCU was a memorandum dated 5 October 1946, and signed by then-Rear Admiral Harold Kinahan. XCU1 was a memorandum dated 13 October 1946. In an admiralty document submitted as part of a United Kingdom memorial to the ICJ, there was a reference to XCU. As a result of this reference, Albania requested the ICJ order the production of XCU, which the ICJ supported. According to Anthony Carty, this support came as a surprise, and the British Attorney General had not at that point examined the sailing orders. The document posed a problem for the Attorney General, which he believed worked to harm the argument that the Royal Navy's actions constituted innocent passage. The consensus of the advisers was that the document might be interpreted by the ICJ as evidence of hostile intent towards Albania. The argument of the Admiralty, which was adopted by the British legal team, was that the ICJ should look to the actions of the flotilla on the day in question, rather than, as Carty describes, "the confused and contradictory expressions of the British Administration through such documents as XCU". At this point, citing national security, the Agent for the United Kingdom refused to produce XCU. In its merits judgment, the ICJ's ruling generally followed the Admiralty argument, holding that the refusal could not lead to "any conclusions differing from those to which the actual events gave rise". In the decades since the case, XCU and related documents were declassified.
While 9 April 1949 order of the ICJ called for further proceedings to determine compensation, which permitted experts to be appointed should the United Kingdom and Albania reach an agreement as to the nature of experts opinions. Such agreement could not be reached, however, because Albania refused to participate in the compensation proceedings. Ultimately, the ICJ itself appointed a committee of experts consisting of two officers of the Royal Netherlands Navy. This committee examined data relevant to the calculations of compensation, which was ultimately annexed to the compensation judgment of the ICJ.
In 1949, the ICJ issued its merits judgment, finding partly for Albania and partly for the United Kingdom. The Court held that the United Kingdom did not violate Albanian territorial waters on 22 October 1946 when the four-ship flotilla transited the parts of the Corfu Channel that were within Albanian territorial waters. The Court's decision rested on its determination that an international strait's character was determined by the fact that it connected two parts of the high seas and that the strait was used for international navigation.
Notably, the Court affirmed that a right of innocent passage existed during times of peace through straits like the Corfu Channel, which connected two parts of the high seas. With respect to the situation that existed between Albania and the United Kingdom at that point, the Court accepted that some Albanian regulation of passage through the Channel would have been acceptable, but not to the extent of demanding prior authorization of or outright barring passage of warships. This served to clarify the 1930 Hague Conference with respect to international straits. Bing Bing Jia stated that this decision means that in peacetime, a country could not prohibit the passage of all vessels, or otherwise require authorization. Jia goes on to argue, however, that because Albania was unable to rapidly distinguish between the passage of Greek and other vessels during times of high political tensions, the requirement of prior notification could be lawful. On the question of innocent passage, the Court found in favor of the United Kingdom fourteen to two.
With respect to the minefield itself, the Court rejected the British contention that Albania had laid it, insofar as such a claim was not credible: at the time Albania lacked the capacity for such operations. The Court also rejected the Albanian contention that Greece might have been responsible as nothing more than conjecture, as well as the claim that the mines had been laid after 22 October. The Court did not need to conclude as to who had laid the mines: given they were in Albanian territorial waters, and the evidence placed the minelaying at a recent time, during which Albania was known to have high levels of security. Thus, the government would have knowledge of any minelaying operations in the Corfu Channel, and as such, Albania had a responsibility to notify other states of the navigational hazard they presented. One commentator has noted the Court's approach to the British claims illustrates how the standard of proof in the ICJ differs for claims of acts versus claims of omissions. The United Kingdom had alleged that Albania had laid the mines, or in the alternative, that Albania and Yugoslavia had colluded in laying the mines. They also alleged that Albania's failure to warn ships of the danger of the minefield constituted an omission that affected the rights of other states. With respect to the claim of Albanian-Yugoslav collusion, the United Kingdom could provide direct evidence neither of collusion nor of who had actually laid the mines. For the Albanian-Yugoslav collusion, the Court demanded "a degree of certainty", while to establish the Albanian omission, the Court demanded that there be "no room for reasonable doubt" that Albania had knowledge of the minefield. While the latter standard seems like it should be higher, it was capable of being satisfied by indirect evidence.
In his separate opinion, Judge Alejandro Álvarez argued that warships were not entitled to make innocent passage except where such passage was to take part in a UN enforcement action. Judge Sergei Krylov's dissent argued that there was no customary international law allowing passage, and that straits could be regulated by the coastal state. Judge Philadelpho Azevedo dissented, arguing that territorial seas within international straits were treated the same as any other territorial seas, but that a special regime was needed for international straits.
Albania's non-participation in the compensation phase of the case was the result of its challenging the ICJ's jurisdiction to award damages. In pleadings, the United Kingdom argued that the ICJ's jurisdiction was a matter of res judicata—it had already been decided by the ICJ—and Article 36, paragraph 6, and Article 60 of the ICJ Statute, taken with the merits judgment, served to grant the ICJ jurisdiction. Because Albania did not participate any further in the compensation proceedings, the United Kingdom was awarded judgment by default on 15 December 1949, accepting the argument that the question of its jurisdiction was res judicata under Article 60. Shabtai Rosenne remarked on the ICJ's non-reliance on Article 36, paragraph 6 of the ICJ Statute was not explained in its judgment. He suggested that the ICJ did not wish the question of jurisdiction to award damages to be decided as a matter of its statutory jurisdiction under Chapter II—which contains Article 36—but instead wanted it to be judged as a matter of procedure, under Chapter III—which contains Article 60. That is, the ICJ wanted it clear that its judgment was because Albania defaulted and because the merits decision was res judicata, rather than the matter of whether the ICJ had jurisdiction to award damages at all being res judicata.
The ICJ ordered Albania to pay the UK£843,947 in compensation. This is equivalent to £22.4 million in present-day terms. As of 2012, it was the only case in which the ICJ made an award in the form of liquidated money to a state applicant.
Satisfaction of debt
The Albanian debt resulting from this case sat unsettled for decades. In negotiations that took place during the summer of 1950, Albania offered £40,000 to settle the claim of the United Kingdom. This is equivalent to £1.06 million in present-day terms. In January 1951, the United Kingdom rejected the Albanian offer of settlement. Settlement talks subsequently broke off. Authorities in the United Kingdom then looked to the possibility of seizing Albanian property in the United Kingdom. This failed because there was no such property under United Kingdom jurisdiction.
The United Kingdom then sought to settle the debt by looking to an Albanian claim for 2,338.7565 kilograms (5,156.075 lb; 75,192.77 ozt) of Nazi gold that had been looted from an Italian vault in 1943, which had been recovered subsequently in Germany. The Tripartite Commission for the Restitution of Monetary Gold, of which the United Kingdom is a member, formed an agreement on 25 April 1951 in Washington, D.C. whereby it requested the President of the ICJ to appoint an arbitrator to resolve the competing claims between Italy and Albania as to the status of the gold. In requesting arbitration, the Tripartite Commission issued the Washington Statement, in which it stated that should the arbitrator grant Albania's claim under Part III of the Final Act of the Paris Conference on Reparations, the gold would be granted to the United Kingdom to partially satisfy the Corfu Channel case debt. On 20 February 1953, the arbitrator granted Albania's claim. This did not end the issue, however, because Italy asserted claims to the gold that were not covered by Part III of the Final Act. Italy's independent claims ultimately gave rise to a new ICJ case, Monetary Gold Removed from Rome in 1943, which Italy commenced on 9 May 1953. This case was ultimately dismissed on jurisdictional grounds on 15 June 1954, and the gold sat in a vault in London under the Tripartite Commission's name.
Final settlement of the debt did not take place until the 1990s, after the end of socialism in Albania. The United Kingdom and Albania reached an agreement on 8 May 1992 whereby the United Kingdom would grant to Albania some 1,574 kilograms (3,470 lb) of Tripartite Commission gold, and Albania would pay $2 million to the United Kingdom. The settlement was finally approved in 1996, following the settlement of claims between Albania and the other Tripartite Commission powers. At this point, Albania asserted that it was unable to pay the $2 million. Later in 1996, however, Albania paid the $2 million, and the judgment was considered settled. This is equivalent to $3.01 million in present-day terms.
One of the major reasons the Corfu Channel case has continued to be of importance in current public international law, according to Aristotles Constantinides, has to do with the standards it established in evidentiary and fact-finding portions of the case.
Law of the sea
The Corfu Channel case has been described as a "landmark" case in the law of the sea. At the 1930 Hague Conference on International Law, no consensus had emerged as to whether the right to innocent passage through territorial seas existed for warships. Corfu Channel heralded the change of this regime.
Corfu Channel was relevant at the seventh session of the International Law Commission (ILC), held in 1955, as well as the 1950s dispute over the Gulf of Aqaba and Straits of Tiran. The ILC ultimately submitted a draft provision to the 1958 United Nations Conference on the Law of the Sea (UNCLOS I), providing that the right of innocent passage through international straits should not be suspended. The ILC attributed their draft to the Corfu Channel merits judgment. The provision was adopted almost verbatim at UNCLOS I into Article 16(4) of the Convention on the Territorial Sea and the Contiguous Zone, but not without significant debate as to how the merits judgment should be interpreted with respect to warships. The Convention's provision contained no reference to "warships", but Jia argues that the remainder of Article 16 make it clear that Article 16(4) could not be read to allow the coastal state to require prior authorization, and that otherwise UNCLOS I aligned with the merits judgment.
After UNCLOS I, when some states began to extend their territorial sea claims to 12 nautical miles (14 mi; 22 km), disputes over straits that narrowed to 24 nautical miles (28 mi; 44 km) began to increase. These included the Balabac Strait, Sunda Strait, Vilkitsky Strait and Strait of Malacca, typically where one state demanded prior authorization. The states bordering the Strait of Hormuz and the Bab-el-Mandeb, on the other hand, recognized the right to innocent passage. In the 1970s, Spain and Morocco in essence recognized the right of innocent passage through the Strait of Gibraltar.
Innocent passage, along with transit passage, was integrated into the 1982 United Nations Convention on the Law of the Sea (UNCLOS), which supserseded the Convention on the Territorial Sea and the Contiguous Zone.
Use of force
As of 2013, the ICJ's jurisdiction over cases involving the use of force, even of ongoing armed conflict, was without doubt. Prior to the development of the United Nations, cases involving the use of force would likely have been considered unsuitable for adjudication. As of 2013, the Court had rendered merits judgments in three cases aside from the Corfu Channel case: Nicaragua v. United States in 1986, the Oil Platforms case in 2003, and Armed Activities on the Territory of the Congo in 2005. Many others have been brought before the Court, though not resulting in decisions. Historically, the ICJ's stance has been to strictly enforce the prohibition on the use of force, which has proved controversial.
In deciding the matter of Albania's counterclaim—that the United Kingdom violated Albanian sovereignty with Operation Retail—the Court rejected the United Kingdom's contention that its activities in Albanian territorial waters were justified as necessary to obtain evidence of the minefield in the Corfu Channel, as well as the alternative argument that it was justified as self-help or self-protection. The United Kingdom did not meet its burden to establish justification. Some controversy surrounded the majority's decision, which did not specifically reference the UN Charter's prohibition on the use of force, but simply held that the United Kingdom violated the sovereignty of Albania. In subsequent cases involving use of force, Christine Gray has noted that the Court has similarly avoided specifically referencing the UN Charter in its final pronouncements.
In subsequent cases, the Court has held that the UN Charter prohibition on the use of force constituted customary international law. In fact, in the Nicaragua case, the parties were in agreement that the prohibition constituted a peremptory norm, or jus cogens. The practice of states has generally conformed to the Court's approach in the Corfu Channel case. The United States has criticized the Court's approach to the use of force.
As to law of war, or jus in bello, the Corfu Channel case merits decision made reference to the concept, but only when the Court decided Nicaragua did the ICJ give a significant treatment to the topic. The Permanent Court of International Justice had never dealt with jus in bello. In both cases, the ICJ dealt with situations involving force, but which did not rise to the level of a formal state of war.
International environmental law
While on its face a decision on matters of law of the sea and use of force, scholars such as Malgosia Fitzmaurice have remarked on the impact the Corfu Channel case has had on the development of international environmental law. Specifically, it has been noted that the case, along with the 1930s arbitration from the Trail Smelter dispute, and the subsequent ICJ case involving Barcelona Traction, articulated basic principles used extensively in subsequent cases and conventions dealing with the environment. In the Corfu Channel case, the Court articulated the principle that every state is obligated not to knowingly allow its territory to be used to commit acts against the rights of any other state. This meant, with respect to the Corfu Channel, that Albania was obligated to warn others that its territorial waters were mined. The specific language generally came from the Trail Smelter case, and ultimately was adopted into the Stockholm Declaration and Rio Declaration.
- List of International Court of Justice cases
- 1985 Polar Sea controversy, a subsequent controversy involving the Northwest Passage
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- Delgado 2014, pp. 38–39.
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- "U.N. to Hear Complaint Against Albania: Mr. Gromyko's Objections Overruled". Manchester Guardian. 21 January 1947. p. 5.
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