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Salini v. Morocco

Type of decisionDecision on Jurisdiction
Date of decision16 July 2001
Tribunal
Robert Briner (President)
Bernardo M. Cremades
Ibrahim Fadlallah
Legal instrumentBIT between Italy and Morocco (1990)
Further information

Statements from this decision

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“Investment” does not need to be interpreted according to national law
Based on a functional/structural test, the actions of private juridical persons can in principle be attributed to a state
“Investment” does not need to be interpreted according to national law
Certain investments need specific approval
The state must conclude the contract; the state has to be the named party
The requirements for a request of amicable settlement should include the existence of grounds for complaint and the desire to resolve these matters out-of-court. It need not be complete or detailed.
While contracts can fall within the applicable scope of a wide dispute settlement clause, the state, must be a named party
Wide dispute settlement clauses cannot be interpreted so as to exclude claims arising outside of the IIT
The right to ICSID arbitration under the Treaty cannot be waived through a contractual clause providing for mandatory administrative courts
The right to ICSID arbitration under the Treaty cannot be waived by way of a contractual clause providing for administrative courts which cannot be opted for
In defining “investment” according to Article 25 ICSID Convention, it would be inaccurate to consider that the requirement that a dispute be “in direct relation to an investment” is diluted by the consent of the contracting parties
A construction contract of 32-month duration fulfils the requirement of an investment
Investments imply contributions, a certain duration of performance of the contract, participation in the risk of transaction, and contribution to economic development (so called Salini Test)
The Contracting State is the correct defendant even where the violations were committed by a state entity

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