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Fraport v. Philippines

Type of decisionDecision on the application for annulment of Fraport AG
Date of decision23 December 2010
Tribunal
Peter Tomka (President)
Campbell McLachlan
Dominque Hascher
Legal instrumentBIT between Germany and Philippines (1997)
Related decision(s)Award, 16 August 2007
Further information

Statements from this decision

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When examining whether an investment was in accordance with domestic law, a tribunal should give particular consideration to municipal decisions
An instrument of ratification expresses a state's consent to be bound by a treaty; although it allows the treaty to enter into force, this effect provides no basis for attaching a particular importance to the instrument of ratification and the instrument does not modify the legal effect of the treaty
IITs must be interpreted using the rules of interpretation laid down in the VCLT
A tribunal manifestly excesses its powers if it does not apply the relevant rules of interpretation governing its competence properly
When determining its jurisdiction, a tribunal should consider and analyse the factual records only to the extent necessary to make a decision regarding its jurisdiction
When examining whether an investment was in accordance with domestic law, a tribunal should give particular consideration to municipal decisions
When determining its jurisdiction, a tribunal should consider and analyse the factual records only to the extent necessary to make a decision regarding its jurisdiction
"In dubio pro reo" is not applicable in an investor-state-arbitration
The right to be heard includes the right to make submissions on evidence presented by the opponent
An instrument of ratification expresses a state's consent to be bound by a treaty; although it allows the treaty to enter into force, this effect provides no basis for attaching a particular importance to the instrument of ratification and the instrument does not modify the legal effect of the treaty
A tribunal manifestly excesses its powers if it does not apply the relevant rules of interpretation governing its competence properly
IITs must be interpreted using the rules of interpretation laid down in the VCLT
When determining its jurisdiction, a tribunal should consider and analyse the factual records only to the extent necessary to make a decision regarding its jurisdiction
An annulment committee has to consider the original award in light of the evidence, submissions and record available to the original tribunal, and not on the basis of new materials
When examining whether a tribunal committed a manifest excess of power by not exercising its jurisdiction, an annulment committee will intervene only where the tribunal's decision was unreasonable
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
A tribunal manifestly excesses its powers if it does not apply the relevant rules of interpretation governing its competence properly
It is not for an annulment committee to decide whether an interpretation by the original tribunal is correct as long as the interpretation in question is a tenable one
Article 52 ICSID Convention was inspired by Article 35 of the Model Rules on Arbitral Procedure
The requirement that the parties be heard does not preclude the tribunal from setting reasonable limits on the timing and scale of the submissions, as long as the tribunal treats the parties equally
"In dubio pro reo" is not applicable in an investor-state-arbitration
The requirement that the parties be heard is a fundamental rule of procedure
A party forfeits its right to seek annulment under Article 52(1)(d) ICSID Convention if it fails to raise its objection to the tribunal's procedure upon becoming aware of it
Object and purpose of the power to annul an award for a serious departure from a fundamental rule of procedure is to control the integrity of the arbitral procedure
"Fundamental rule of procedure" refers to procedural rules constituting general principles of international arbitral procedure
"Nullum crimen sine lege" is not a rule of procedure, but a determination of the scope of the substantive law
The annulment ground of "failure to state reasons" relates to the obligations of the tribunal expressed in Article 48(3) ICSID Convention; stating the reasons legitimizes the tribunal's decision and prevents arbitrary decisions
A party forfeits its right to seek annulment under Article 52(1)(d) ICSID Convention if it fails to raise its objection to the tribunal's procedure upon becoming aware of it

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