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Toto v. Lebanon

Type of decisionDecision on Jurisdiction
Date of decision11 September 2009
Tribunal
Hans van Houtte (President)
Fadi Moghaizel
Alberto Feliciani (dissenting)
Legal instrumentBIT between Italy and Lebanon (1997)
Related decision(s)Award, 7 June 2012
Further informationFull text of the decision

Statements from this decision

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If an IIT deems international law applicable, it covers breaches of any rule of international law, e.g. the customary standard of denial of justice; in elucidating such a standard, a tribunal may seek guidance in international treaties signed by the host state
If an IIT deems international law applicable, it covers breaches of any rule of international law, e.g. the customary standard of denial of justice; in elucidating such a standard, a tribunal may seek guidance in international treaties signed by the host state
Conduct of state organs and of entities exercising governmental authority is attributable to the host state if the requirements of the ILC Draft Articles on State Responsibility are met
If an IIT's applicability is restricted to disputes that have arisen before its entry into force, it does not matter whether the subject-matter of the claim concerns conduct before the IIT's entry into force
Indirect expropriation requires a radical deprivation and a taking of property; a mere breach of contract is not sufficient
The disruption of negotiations and the refusal to resume them does not necessarily amount to a breach of the FET standard
Overcharged dockets are an explanation, but not an excuse for judicial delays
The fact that an investor was aware of the length of procedures before domestic courts when concluding a contract is not relevant when assessing whether a judicial delay constitutes a denial of justice
Whether a judicial delay constitutes a denial of justice has to be evaluated on the circumstances and the context of the case; the complexity of the matter, the need for celerity of the decision and the diligence of the claimant are relevant factors
Exhaustion of local remedies (i.e. judicial finality) is a required substantive element of a claim for denial of justice; it is different from the traditional rule of exhaustion of local remedies, which is a procedural prerequisite
An umbrella clause does not elevate pure contractual claims into treaty claims; in case a contract contains an exclusive forum selection clause referring to domestic courts, an IIT based tribunal has no jurisdiction over these contractual claims
A fork-in-the-road-clause requires identity of object, parties and cause of action; contractual claims do not have the same cause of action as IIT claims
An exclusive jurisdiction clause in a contract cannot prevent an IIT based tribunal from examining the violations of the IIT
An exclusive jurisdiction clause in a contract cannot prevent an IIT based tribunal from examining the violations of the IIT
An obligation to create and maintain favourable economic and legal conditions does not prohibit changes in legislation
Distinction between violation of a contract and a treaty
A tribunal has jurisdiction over a dispute under the ICSID Convention even if the Convention was not applicable at the time the IIT entered into force, provided that the ICSID Convention was applicable at the time the investor accepted the state's offer to arbitrate
Whether there is an investment is subject to a two-part test in treaty-based ICSID proceedings
A construction contract in which the execution of the works extends over a substantial period of time involves by definition an element of risk as required by the Salini criteria
A construction contract in which the execution of the works extends over a substantial period of time involves by definition an element of risk as required by the Salini criteria
The underlying concept of investment in the ICSID Convention implies an economical operation initiated and conducted by an entrepreneur using its own financial means and at its own financial risk, with the objective of making a profit within a given period of time
A tribunal has jurisdiction over a dispute under the ICSID Convention even if the Convention was not applicable at the time the IIT entered into force, provided that the ICSID Convention was applicable at the time the investor accepted the state's offer to arbitrate

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