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Mondev v. USA

Type of decisionAward
Date of decision11 October 2002
Tribunal
Ninian Stephen (President)
James R. Crawford
Stephen M. Schwebel
Legal instrumentNorth American Free Trade Agreement
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Statements from this decision

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The phrase “in accordance with international law” does not necessarily refer to anything other than customary international law
International law does not place emphasis on merely formal considerations
On assessing an act, which took place before the IIT entered into force, one must distinguish between an act of continuing character and an already completed act continuing to cause loss or damage
The compensation does not need to be paid at the exact same time as the taking; for the taking to be lawful, however, the obligation to compensate must be recognized by the state or an appropriate procedure for compensation must be provided
There is no abstract definition of what is fair and equitable; whether treatment was fair and equitable depends on the facts of the particular case
The protection from denial of justice does not turn tribunals into courts of appeal for decisions of local courts
Article 1122 NAFTA does not distinguish between jurisdiction and admissibility; however, there may be a distinction between the conditions in Article 1122 NAFTA and other procedures referred to in Chapter 11
There is no principle of extensive or restrictive interpretation of jurisdictional provisions in treaties
International law does not require the initiation of new proceedings where a mere procedural defect is involved
A claimant does not need to maintain a continuing status as an investor under the law of the host state at the time the arbitration is commenced
On assessing an act which took place before the IIT entered into force, one distinguishes between an act of continuing character and an already completed act continuing to cause loss or damage
By its reference to “international law”, Article 1105(1) NAFTA incorporates the contemporary international customary law
Article 1105(1) NAFTA protects intangible property interests
The protection from denial of justice does not turn tribunals into courts of appeal for decisions of local courts
Test of a decision being arbitrary as a form of denial of justice
Immunity from suit for conduct of a public authority may amount to a breach of Article 1105(1) NAFTA
The compensation need not be paid at the exact same time as the taking; for the taking to be lawful, however, the obligation to compensate must be recognized by the state or an appropriate procedure for compensation must be provided
Due to the detailed scheme laid down by Articles 1116 and 1117 NAFTA, there is no room for the application of rules of international law regarding the piercing of the corporate veil
A tribunal should not allow recovery to be paid directly to an investor in a claim falsely brought under Article 1116 NAFTA instead of Article 1117 NAFTA
For the time bar of Article 1116(2) and 1117(2) NAFTA, it is sufficient that the claimant knows that loss or damage occurred, even the extent of such is unclear
For the time bar of Article 1116(2) and 1117(2) NAFTA, the decisive point in time is the date the measure caused loss and damage; it does not matter at what date loss or damage was confirmed by a local court decision
Due to the detailed scheme laid down by Articles 1116 and 1117 NAFTA, there is no room for the application of rules of international law regarding the piercing of the corporate veil
A tribunal should not allow recovery to be paid directly to an investor in a claim falsely brought under Article 1116 NAFTA instead of Article 1117 NAFTA
For the time bar of Article 1116(2) and 1117(2) NAFTA, it is sufficient that the claimant knows that loss or damage occurred, even the extent of such is unclear
For the time bar of Article 1116(2) and 1117(2) NAFTA, the decisive point in time is the date the measure caused loss and damage; it does not matter at what date loss or damage was confirmed by a local court decision
There is no principle of extensive or restrictive interpretation of jurisdictional provisions in IITs
Article 1122 NAFTA does not distinguish between jurisdiction and admissibility; there may, however, be a distinction between the conditions in Article 1122 NAFTA and other procedures referred to in Chapter 11

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