There are also compulsive or coercive means of settlement of International

disputes:
Retorsion is retaliation. If a state behaves in unequal or in courteous way with
the other State, then the other state gets the right of retorsion. 
Reprisal. If the problem is not solved by Retorsion the States have the right
resort to Reprisal that is. In Retaliation the state can initiate such a proceeding that
violator of the problem may be solved. The reprisal can be resorted against a State
when it has indulged in some illegal or inappropriate activity. 
Embargo. Embargo is also a kind of Reprisal. If the ship belongs to a State
which has committed international tort or has committed some other international wrong
and is available in the territorial waters of the State against which tort or wrong has
been committed then such vessels can be restrained from travelling through that area
as a matter of right by the other State.
Intervention. International Law does not prohibit intervention in all
circumstances, meaning thereby that in certain circumstances intervention is valid and
legal.
Pacific Blockade. The outer boundary of a State is blocked peacefully. 

XXX

The engagement in war is still a relevant action of the States under the present
norms of International Law.

The United Nations was created for maintaining peace and order among its
members. Among its principles is that All members of UNO should refrain from the use
of force or threat of force against the territorial integrity or political independence of any
State, and that All the international disputes are to be settled by peaceful means with
the results that peace and security and justice of any region may not endanger.

The use of force is needed for the purpose of self-defense. The use of force
however, should be proportional with the kind of attack of the other States. War is
necessary sometimes to preserve life and human rights.
 “The use of force in Rwanda would have prevented the single most monstrous
act of disregard of human suffering that has happened since the Cambodian mass
murders. President Clinton went to Africa and apologized to the African people for what
he had failed to do. Allowing those people to die without using force to protect them was
disgraceful, even though it was clear that acting without Security Council approval to
stop that genocide would have violated the Charter,” (Abraham, 2004)

The ‘primary responsibility’ of the UNSC is the ‘maintenance of international peace and
security’. 18 This responsibility is the premise for the need of the Council to be able to take
‘prompt and effective action’. 19 To that end, the UN members agreed that when acting the
Council ‘acts on their behalf’. 

Under Article 39 of the UN Charter, it is for the UNSC to determine whether a threat to, or
breach of, the peace, or act of aggression, exists that would justify its intervention under Chapter
VII. 23 Once it has made such a determination, its options for action have been described as ‘carte
blanche’. 24 While Chapter VII does contain a hier archy of actions that the Council can consider
when dealing with situations, namely (i) calling upon the parties to comply with provisional
members, 25 (ii) implementing ‘measures not involving the use of armed force’ 26 and, ultimately,
(iii) implementing measures involving the use of armed force, 27 there is no need for the Council
to ‘adopt the measures … in any particular order’. 28 Rather the Council has broad discretion not
only in relation to when it may act but also in relation to what types of action it can
take. 29 Indeed, the only explicit UN Charter limitation on Council action is in Article 24(2),
which states that ‘the Security Council shall act in accordance with the Purposes and Principles
of the United Nations’. 30 This provision has been central to many attempts to limit the Council’s
powers.

Article 24(2) is the starting point of much analysis of restraints on the UNSC. These restraints
usually attempt to ascertain what legal rules apply to the Council and then to determine how the
validity of Council conduct could be adjudicated in light of those rules. 31 For example, David
Schweigman reads Article 24(2) as requiring compliance with norms such as human rights, self-
determination and the principle of good faith. 32 Similarly, Erika de Wet recognizes the Council’s
broad powers but argues that it is still bound by ius cogens and the purposes and principles of the
UN. 33 While there can be little doubt that the UN Charter itself creates a bare framework of the
limits of Council action, 34 it also delivers ‘scant clarity concerning the specific contours of those
limits’. 35 The UN Charter’s text is notoriously vague, making it difficult to use it to construct a
meaningful regime to constrain the Council. 36
The other main avenue to ground legal limits to UNSC action is ius cogens . 37 As Alexander
Orakhelashvili has argued, as states can never derogate from the peremptory norms of
international law, this limitation must also carry over to institutions created by states. 38 Thus, it
is argued, all international organizations are limited by ius cogens norms such as the prohibition
on the use of force 39 and certain fundamental universal rights. 40 While, again, it seems clear that
the Council cannot act contrary to ius cogens , 41 ascertaining which norms fall within this
rarefied category is difficult. Even if a hard core of peremptory norms were established, the
extent of such a legal regime would be limited or at least contested. 42 Thus, the project of
binding the Council with hard legal rules is still very much in nascent form. 43 While these
attempts have real merit and potential, it may be some time before they are sufficiently
sophisticated to realize their theory in practice.
Even if the limits of Council action were clear, the more difficult question then becomes what
body could adjudicate on the validity of Council action. As Jeremy Farrall notes, the ‘key
question … is how to ensure that the Security Council observes and respects those legal
limits’. 44 To many scholars, the ‘favoured mechanism is judicial review’. 45 However, a proposal
for institutionalized judicial review of the Council – for example, by the ICJ – was rejected
during UN Charter negotiations. 46 Thus, attempts to subject the Council to judicial review face
jurisdictional issues, particularly if the decision is to bind the Council. The ICJ is still the most
promising candidate for institutionalized judicial review of the Council; 47 however, its
contentious jurisdiction could, at best, decide upon the legality of a Council action as it applied
between states party to a dispute. 48 Its advisory opinions, though they carry substantial weight,
would not be binding, 49 and it is politically difficult to have such opinions requested from the
ICJ. 50 Domestic and regional courts have become more emboldened to review Council
resolutions or, at least, their implementation by states and bodies such as the European Union
(EU). 51 Thus, they may also provide a judicial forum for review. However, again, jurisdictional
issues here mean that the decisions of these municipal courts cannot bind the Council. 52 Further,
the fragmented nature of municipal oversight and rules being applied may also prove
problematic if such courts become more interventionist in their review of Council
action. 53 Finally, in addition to courts, states themselves may rely on legal arguments to justify
non-compliance with Council decisions; although whether or not they would be legally justified
in doing so is controversial. 54
This summary of the dominant approaches to restraining the UNSC is critical; however, the
overall project is institutionally helpful and will likely bear fruit. 55 Indeed, legal language
already plays a role in current debates over the legitimacy of Council action and is an important
factor in Council decision making. 56 At the same time, however, history shows an aversion by
states to institutionalizing the legal oversight of the Council. 57 Further, attempts at reform face
stiff opposition. 58 Thus, while accepting the value of legal rules to restrain the Council, this
article suggests that (at least in relation to its Chapter VII powers), the Co
=== https://www.mpil.de/files/pdf3/mpunyb_02_weiss_12.pdf
Article 24(2) is the starting point of much analysis of restraints on the UNSC. These restraints
usually attempt to ascertain what legal rules apply to the Council and then to determine how the
validity of Council conduct could be adjudicated in light of those rules. 31 For example, David
Schweigman reads Article 24(2) as requiring compliance with norms such as human rights, self-
determination and the principle of good faith. 32 Similarly, Erika de Wet recognizes the Council’s
broad powers but argues that it is still bound by ius cogens and the purposes and principles of the
UN. 33 While there can be little doubt that the UN Charter itself creates a bare framework of the
limits of Council action, 34 it also delivers ‘scant clarity concerning the specific contours of those
limits’. 35 The UN Charter’s text is notoriously vague, making it difficult to use it to construct a
meaningful regime to constrain the Council. 36
The other main avenue to ground legal limits to UNSC action is ius cogens . 37 As Alexander
Orakhelashvili has argued, as states can never derogate from the peremptory norms of
international law, this limitation must also carry over to institutions created by states. 38 Thus, it
is argued, all international organizations are limited by ius cogens norms such as the prohibition
on the use of force 39 and certain fundamental universal rights. 40 While, again, it seems clear that
the Council cannot act contrary to ius cogens , 41 ascertaining which norms fall within this
rarefied category is difficult. Even if a hard core of peremptory norms were established, the
extent of such a legal regime would be limited or at least contested. 42 Thus, the project of
binding the Council with hard legal rules is still very much in nascent form. 43 While these
attempts have real merit and potential, it may be some time before they are sufficiently
sophisticated to realize their theory in practice.
Even if the limits of Council action were clear, the more difficult question then becomes what
body could adjudicate on the validity of Council action. As Jeremy Farrall notes, the ‘key
question … is how to ensure that the Security Council observes and respects those legal
limits’. 44 To many scholars, the ‘favoured mechanism is judicial review’. 45 However, a proposal
for institutionalized judicial review of the Council – for example, by the ICJ – was rejected
during UN Charter negotiations. 46 Thus, attempts to subject the Council to judicial review face
jurisdictional issues, particularly if the decision is to bind the Council. The ICJ is still the most
promising candidate for institutionalized judicial review of the Council; 47 however, its
contentious jurisdiction could, at best, decide upon the legality of a Council action as it applied
between states party to a dispute. 48 Its advisory opinions, though they carry substantial weight,
would not be binding, 49 and it is politically difficult to have such opinions requested from the
ICJ. 50 Domestic and regional courts have become more emboldened to review Council
resolutions or, at least, their implementation by states and bodies such as the European Union
(EU). 51 Thus, they may also provide a judicial forum for review. However, again, jurisdictional
issues here mean that the decisions of these municipal courts cannot bind the Council. 52 Further,
the fragmented nature of municipal oversight and rules being applied may also prove
problematic if such courts become more interventionist in their review of Council
action. 53 Finally, in addition to courts, states themselves may rely on legal arguments to justify
non-compliance with Council decisions; although whether or not they would be legally justified
in doing so is controversial. 54
This summary of the dominant approaches to restraining the UNSC is critical; however, the
overall project is institutionally helpful and will likely bear fruit. 55 Indeed, legal language
already plays a role in current debates over the legitimacy of Council action and is an important
factor in Council decision making. 56 At the same time, however, history shows an aversion by
states to institutionalizing the legal oversight of the Council. 57 Further, attempts at reform face
stiff opposition. 58 Thus, while accepting the value of legal rules to restrain the Council, this
article suggests that (at least in relation to its Chapter VII powers), the Co
https://www.mpil.de/files/pdf3/mpunyb_02_weiss_12.pdf
According to Article 39, the Security Council shall determine, shall make
recommendations, or decide the measures to be taken. The Security Council
may decide about certain measures un- der Article 41, and if it considers them
inadequate it may take such ac- tion as may be necessary to maintain or restore
international peace and security (Article 42). Indeed, the powers of the Security
Council to deal with international conflicts are constitutive and almost
exclusive (as it has the primary responsibility for the maintenance of peace
and secu- rity according to Article 24 UN Charter and the sole enforcement
power under Chapter VII) so that the Security Council must enjoy the
capability and the power to decide on the necessary steps for the set- tlement
of a given conflict and on the restoration of international peace and security
thereafter, irrespective of the pre-history of that conflict. The powers of the
Security Council have to be interpreted against the need for effective
protection of basic values like international peace. Ef- fectiveness underpins
the Charter regime, at least as regards mainte- nance of peace and security
(see the first words of Article 24 UN Char- ter). The ICJ once affirmatively
cited the Secretary-General stating that the Security Council powers were not
restricted to those specific grants of authority contained in Chapter VI, VII,
VIII and XII, but the Mem- ber States conferred on the Security Council
powers commensurate with its responsibility for the maintenance of peace
and security. The only limitations that were mentioned there were the
fundamental prin- ciples and purposes found in Chapter I of the Charter. 12
The broad, purpose-oriented interpretation of the Security Council Chapter
VII powers is endorsed by the more or less undisputed power of the Secu- rity
Council to authorise the use of force by Member States although

XXXXX

Spain, A.. (2013). International dispute resolution in an era of globalization. International Law in the New
Age of Globalization. 41-70. 10.1163/9789004228818_004.

https://lawweb.colorado.edu/profiles/pubpdfs/spain/IntlDispRes-EraGlobalization.pdf

Efforts to resolve these disputes through traditional forms of adjudication have become increasingly
ineffective because resolution requires the broader participation of the international community. As
former ICJ Judge Christopher Weeramantry has stated, '[ w ]hen we enter the arena of obligations which
operate erg a omnes rather than inter partes, rules based on individual fairness and procedural
compliance may be inadequate. Thus, the nature of many international disputes today requires the IDR
system to provide the international community with a venue for collective problem solving. It also
necessitates dispute resolution options for cases where legal rights have yet to be established or remain
unclear.

n-State actors are playing an increasingly powerful role in shaping the treaty-making process. For
example, during the 15th session of the Conference of the Parties to the UN Framework Convention on
Climate Change in Copenhagen in 2009, individuals and civil society groups far outnumbered State
delegates, using their numbers to make up for the power their non-State delegate status lacked.33 IDR
embraced participation by individuals early in its history. For example, under the International Prize
Court proposed to be established by the 1907 Hague Convention XII, individuals would have been able
to lodge appeals against the decisions of national prize courts, although States could forbid nationals
from using this option (ultimately the Convention never entered into force). 34 Individuals enjoyed
standing to bring claims before the Central American Court of Justice (1907-1918) against foreign States
without consent of their home country. 35 Individuals have brought claims against foreign States for war
damages and mass claims before tribunals such as the Anglo-German Mixed Arbitral Tribunal in 1924.36
Despite these early developments, individuals still have limited rights and access to international
adjudication.37

What are the rights of people to resolve their own disputes and where are the limits? What recourse do
individuals and their representative organizations have for resolving international disputes? Should
individuals be granted standing before the ICJ and other adjudicative bodies? Should jurisdiction be
expanded in this manner? For example, in the Arrest Warrant case, ICJ Judge ad hoc Van den Wyngaert
criticized the court for ignoring the statements of NGOs offering the opinion of civil society and noting
that opinion's importance in the formation of international customary law today.44 Questions such as
these, about the rights and obligations of individuals with regard to international dispute resolution,
shape the discourse on how IDR should evolve and whom international law should serve.
One concern is that the proliferation of international courts and the judicialization' of international
disputes have led to a multiplicity of dispute resolution options that are uncoordinated. In the
adjudication realm, a system where multiple courts may exert jurisdiction over the same subjects and/
or issues presents concerns about fragmentation, legitimacy and authority. 57 Inconsistent findings by
different judicial bodies create multiple sources of international law that can lead to fragmentation of
international legal jurisprudence. 58 For example, the decision of the International Criminal Tribunal for
the former Yugoslavia in Tadic was interpreted by some to be a departure from the earlier standard of
effective control used by the I CJ in the Case Concerning Military and Paramilitary Activities in and
against Nicaragua. 59

Sovereignty challenges IDR in the following ways. First, as the PCIJ established in Eastern Carella, 'no
State can, without its consent, be compelled to submit its disputes with other States either to mediation
or to arbitration, or to any other kind of pacific settlement.' As States have created the rules, practices
and institutions for engaging in IDR, they have built in doctrines that protect their sovereignty. The
doctrine of justiciability, which provides a way to limit the scope of judicial review for international
courts, is one example. 83 Former US Secretary of State Dean Acheson relied on this doctrine in arguing
after the Cuban Missile Crisis that there are certain political-legal situations that are so vital to States
that the ICJ should not interfere.84 If sovereignty is interpreted in a manner that allows States the
option of not participating in any form of IDR it frustrates the fundamental purpose for the creation of
IDR, to ensure pacific resolution of disputes in order to prevent the recourse to war.

A second challenge occurs when a nation's sovereign right to territorial integrity is the cause of an
international legal dispute. This challenge occurs in environmental disputes. Early on, Trail Smelter
established the rule that States enjoy permanent sovereignty.85 States may use their own natural
resources as they wish, as long as they do not cause serious harm to another nation.86 However, this
guidance is not helpful for addressing disputes, like those arising from climate change, the origins of
which are not confined within territorial boundaries or which are subject to any one nation's legal
jurisdiction.
Addressing these disputes through the IDR system demands a new relationship with sovereignty, which
itself is evolving. For example, the development of the Responsibility to Protect Doctrine has established
an emerging norm that State sovereignty is a limited right, not an absolute one. 87 Actions taken by the
UN Security Council in Libya and, more recently, in Syria support this view.88 As globalization shapes
new understandings of sovereignty, its relationship to IDR must also evolve. The challenge is to figure
out what this means for IDR.

due to the State-centric nature of the IDR system. Historically, IDR practices and institutions, such as the
PCA, PCIJ and ICJ, have been established by States. Thus, their interests are negotiated into the rules and
structure of these forums. International law granted supreme legal status to States, designating them as
the primary subjects of internationallaw.89 Non-State actors were commonly treated as the objects of a
State based on territorial or other forms of control. These actors had no standing under international
law to contest a State's action or territory and thus often resorted to violent means to establish
'effective control' over the area of territory if they wanted to make a case for international
recognition.90 This Statecentric focus made sense at that time because the purpose of establishing
pacific dispute resolution was to prevent war between nations. The challenge today is that a State-
centric international legal system limits the capacity of IDR. Effective IDR requires the inclusion of all
relevant stakeholders, including non-State actors, in the process. Yet many forums either do not provide
for this or strictly limit the type and role of non-State actor participation. Despite these formal rules, IDR
is becoming increasingly porous as new actors pierce through the old veil. NonState actors are behaving
more and more like subjects, not objects, of international law. Corporations and individuals are pursuing
international dispute resolution independent of their governing State. NGOs are influencing the
development of norms. This opening up of the system results in more actors and wider participation.
However, without formal recognition and organization under the international legal regime, it also
contributes to lack of clarity and confusion about the extent of State power and governance and the
rights and responsibilities of everyone else.

However, adjudication has its limits.93 States are reluctant to submit important matters to a third-party
decision-making authority.94 For example, in the Indus River Treaty case, both India and Pakistan chose
not to utilize arbitration and opted to engage in facilitation by the Permanent Indus Commission instead.
95 In the Mekong River Dispute between Thailand and Laos, the parties rejected adjudication as a
dispute resolution option in the Mekong Agreement stating that disputes that are 1 not first resolved by
the Mekong River Committee are to be referred to the

governments for negotiation, possible mediation or eventual settlement according to principles of

internationallaw.'96 In the Amur River Dispute between China and Russia, the parties decided against
adjudication and chose to resolve the problem through a joint field-mapping exercise of the disputed
area in which they agreed to divide the islands in half. 97 A court may issue an opinion that fails to
resolve key issues in the case. 98 For example, despite the ICJ's decision in GabCikovo-Nagymaros
Project regarding Slovakia and Hungary's dispute over a project to build barrages in the Danube River,
99 the matter remains unresolved.l0

A court may issue an opinion that fails to resolve key issues in the case. 98 For example, despite the ICJ's
decision in GabCikovo-Nagymaros Project regarding Slovakia and Hungary's dispute over a project to
build barrages in the Danube River, 99 the matter remains unresolved.l0 other international disputes as
well. Mediation can assist parties in resolving disputes in ways that offer promise in an era of
globalization. It promotes subsidiarity, inclusion of non-State stakeholders, consideration of extralegal
issues, flexibility and the ability to work independent of constrictive legal frameworks. Furthermore,
States have demonstrated a preference for nonbinding guidelines and flexible procedures over binding
legal instruments.l09 Adjudication is less effective than non-legal, collaborative methods of IDR
(mediation, negotiation) for resolving international environmental disputes because States are reluctant
to submit their sovereignty and control to a court or tribunal and because the issues are technically
complex and politically sensitive.I10 There is some institutional support for mediation for international
conflicts. Historically, the UN Secretary-General has offered good offices to States on the brink of, or
engaged in, war. In addition, the UN Department of Political Affairs houses the UN Mediation Support
Unit, a centre that provides educational and operational support for mediation_III In zooS, a five-person
Mediation Support Standby Team was developed to allow for the deployment of mediators to conflict
areas on short notice to lend expertise in areas including power sharing, constitution formation,
security, human rights and justice.l12 International institutional support for mediation of international
disputes remains lacking. There is no standing body equivalent to the ICJ to provide mediation services
to States for international disputes. Although the PCA and ICSID provide conciliation, they do not offer
mediation. Second, the use of mediation in the international context remains. ad-hoc.l13 Third,
mediation lacks formal enforcement mechanisms under international law, so compliance is voluntary or
coerced through political pressure and other means. Mediation lacks the institutional power and
support associated with adjudicatory forums that have a place in the international legal regime.
Furthermore, there are no universally accepted procedural rules governing the use and practice of
mediation. Private mediation providers such as the American Arbitration Association, Judicial Arbitration
and Mediation Services ('JAMS') Inc and, most recently, the International Mediation Institute, have
developed processes for certifying mediators in the practice of international mediation.l14 But, to date,
there is no venue for determining standards or qualifying international mediators that is generally
accepted by the international community or recognized under international law. Addressing this
challenge requires creative thinking about how, in the absence of precedent, to achieve this aim. Should
there be a centralized, standing mediation body for international disputes akin to what the ICJ provides
for judicial settlement? Or should existing IDR forums-the WTO, ICSID, PCA, etc-add mediation to the
methods that they provide? How will mediation, an interest-based process, fit into the existing
international legal framework? These and many other questions will need to be addressed in order to
meet this challenge.

The Lebanese army joined the other Arab armies in the invasion. It crossed into the northern Galilee. By
the end of the conflict, however, it had been repulsed by Israeli forces, which occupied South Lebanon.
Israel signed armistice agreements with each of its invading neighbors. The armistice with Lebanon was
signed on 23 March 1949.[23] As part of the agreement with Lebanon, Israeli forces withdrew to the
international border.

By the conclusion of that war, Israel had signed ceasefire agreements with all of the neighbouring Arab
countries.[24] The territory it now controlled went well beyond what had been allocated to it under the
United Nations Partition Plan, incorporating much of what had been promised to the Palestinian Arabs
under the Plan. However, it was understood by all the state parties at the time that the armistice
agreements were not peace treaties with Israel, nor the final resolution of the conflict between them,
including the borders.
After the war, the United Nations estimated 711,000[25] Palestinian Arabs, out an estimated 1.8 million
dwelling in the Mandate of Palestine,[26] fled, emigrated or were forced out of Israel and entered
neighboring countries. By 1949, there were 110,000 Palestinian Arabs in Lebanon,[27] moved into
camps established by and administered by the United Nations Relief and Works Agency for Palestine
Refugees in the Near East.[28]

Xxxx

Abraham Sofaer, The International Court of Justice and Armed Conflict?, 1 NW. J. HUM. RTS. 1 (2004).
https://scholarlycommons.law.northwestern.edu/njihr/vol1/iss1/4

https://scholarlycommons.law.northwestern.edu/cgi/viewcontent.cgi?article=1003&context=njihr

Only states may be parties in contentious cases. Individuals, corporations, component parts

of a federal state, NGOs, UN organs and self-determination groups are excluded from direct
participation in cases although the court may receive information from public international
organizations. That does not preclude non-state interests from being the subject of
proceedings if a state brings the case against another. For example, a state may, in cases
of "diplomatic protection", bring a case on behalf of one of its nationals or corporations.
Nottebohm Case (Liechtenstein v Guatemala), [1955] ICJ Reports 4.  Article 36 outlines four
bases on which the court's jurisdiction may be founded:

 First, 36(1) provides that parties may refer cases to the court (jurisdiction founded on
"special agreement" or "compromis"). This method is based on explicit consent rather
than true compulsory jurisdiction. It is, perhaps, the most effective basis for the court's
jurisdiction because the parties concerned have a desire for the dispute to be resolved
by the court and are thus more likely to comply with the court's judgment.
 Second, 36(1) also gives the court jurisdiction over "matters specifically provided
for... in treaties and conventions in force". Most modern treaties contain a
compromissory clause, providing for dispute resolution by the ICJ. [24] Cases founded on
compromissory clauses have not been as effective as cases founded on special
agreement since a state may have no interest in having the matter examined by the
court and may refuse to comply with a judgment. For example, during the Iran hostage
crisis, Iran refused to participate in a case brought by the US based on a
compromissory clause contained in the Vienna Convention on Diplomatic Relations and
did not comply with the judgment.[25] Since the 1970s, the use of such clauses has
declined. Many modern treaties set out their own dispute resolution regime, often based
on forms of arbitration.[26]
 Third, Article 36(2) allows states to make optional clause declarations accepting the
court's jurisdiction. The label "compulsory" sometimes placed on Article 36(2)
jurisdiction is misleading since declarations by states are voluntary. Furthermore, many
declarations contain reservations, such as exclusion from jurisdiction certain types of
disputes ("ratione materia").[27] The principle of reciprocity may further limit jurisdiction.
As of February 2011, sixty-six states had a declaration in force. [28] Of the permanent
Security Council members, only the United Kingdom has a declaration. In the court's
early years, most declarations were made by industrialized countries. Since
the Nicaragua case, declarations made by developing countries have increased,
reflecting a growing confidence in the court since the 1980s. [citation needed] Industrialized
countries, however, have sometimes increased exclusions or removed their declarations
in recent years. Examples include the United States, as mentioned previously, and
Australia, which modified its declaration in 2002 to exclude disputes on maritime
boundaries (most likely to prevent an impending challenge from East Timor, which
gained their independence two months later). [29]