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Compañía de Aguas del Aconquija, S.A. and Compagnie Générale des Eaux v. Argentina

Type of decisionDecision on Annulment
Date of decision3 July 2002
Tribunal
Yves Fortier (President)
James R. Crawford
José Carlos Fernández Rozas
Legal instrumentBIT between Argentina and France (1991)
Related decision(s)
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Statements from this decision

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A state is not liable for the performance of contracts entered into by territorial subdivisions possessing a separate legal personality
Wide dispute settlement clauses cannot be interpreted so as to exclude claims arising outside of the IIT
A waiver must be explicit
Whether there has been a breach of an IIT and whether there has been a breach of a contract are different questions; a state cannot rely on an exclusive jurisdiction clause in a contract to avoid the characterization of its conduct as internationally unlawful under a treaty
Whether there has been a breach of an IIT and whether there has been a breach of a contract are different questions; a state cannot rely on an exclusive jurisdiction clause in a contract to avoid the characterization of its conduct as internationally unlawful under a treaty
Parts of the award which are not subject to the annulment decision are to be regarded as res iudicata
A “counterclaim” for annulment is inadmissible; however, the respondent may present its own arguments on questions of annulment inasmuch as they concern specific matters pleaded by the party requesting annulment
Regarding the allocation of costs, the same considerations apply to annulment proceedings as to general proceedings
The exhaustion of local remedies rule does not apply to claims under an IIT if the state did not qualify its consent
Where a ground for annulment is established, the ad hoc committee must determine the extent of the annulment (in whole or in part); the ad hoc committee is not bound by the pleadings of the party having initiated annulment proceedings
A “counterclaim” for annulment is inadmissible; however, the respondent may present its own arguments on questions of annulment inasmuch as they concern specific matters pleaded by the party requesting annulment
An ad hoc committee has a discretion as to whether to annul an award, even if an annullable error is found
General remarks regarding the role of annulment in the ICSID system
An ICSID tribunal commits an excess of powers not only if it exercises a jurisdiction which it does not have, but also if it fails to exercise a jurisdiction which it possesses
The “Rule of procedure” requires at least a full and fair opportunity to be heard at every stage of the proceeding
Annullment under Article 52(1)(e) ICSID Convention requires a clear case in which the tribunal failed to state any reasons for a particular point, although the point is necessary to the tribunal’s decision

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