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Bosh et al. v. Ukraine

Type of decisionAward
Date of decision25 October 2012
Tribunal
Gavan Griffith (President)
Donald McRae
Philippe Sands
Legal instrumentBIT between Ukraine and USA (1996)
Further informationFull text of the decision

Statements from this decision

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While different tribunals should seek to act consistently with one another, there is no doctrine of precedent
Res judicata as a principle of general international law
Provisions establishing a positive obligation to ensure that any state enterprise acts in accordance with the IIT have to be distinguished from rules concerning the attribution of acts
A university remains an entity that is empowered by state law to exercise governmental authority, even if it is a separate legal entity and has a large degree of autonomy
Provisions establishing a positive obligation to ensure that any state enterprise acts in accordance with the IIT have to be distinguished from rules concerning the attribution of acts
An expropriation requires a certain degree of interference with the investment; a substantial deprivation of the investor is necessary
A violation of the FET standard requires that the state's actions trespass a certain standard of propriety
An umbrella clause is breached if a state fails to observe (contractual) commitments; it does not, however, convert the extent or content of such obligations into an issue of international law
An umbrella clause stipulating an obligation for "each party" extents to separate entities only insofar as their conduct can be attributed to the state
A contractual dispute settlement clause should be respected
A tribunal has to differentiate between questions of jurisdiction and admissibility
Res judicata as a principle of general international law
Even if claimants fail to articulate their claim in a precise and consistent way until the substantive hearing, the claim is not made in an untimely fashion and principles of fairness do not require its rejection
An IIT without a choice of law-clause does not constitute an agreement on the applicable rules within the meaning of Article 42(1)(1) ICSID Convention
Article 61(2) ICSID Convention grants a tribunal a discretionary power to award costs

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