Achille Lauro Affair (1985)

Chiara Ragni

Content type: Encyclopedia entries

Product: Max Planck Encyclopedia of Public International
Law [MPEPIL]
Article last updated: June 2009

Subject(s):
Reprisal — Aut dedere aut judicare — Act of state — Hostage taking — Military assistance — Reprisals —
Piracy — Obligation to prosecute
Published under the auspices of the Max Planck Foundation for International Peace and the Rule of Law
under the direction of Rüdiger Wolfrum.

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 A. Description of the Achille Lauro Affair
1 On 7 October 1985, four armed members of the Palestine Liberation Front (‘PLF’), a
faction of the → Palestine Liberation Organization (PLO), seized the Italian cruise liner
Achille Lauro as the ship was sailing in Egyptian waters on its way from Alexandria to Port
Said.

2 Holding the passengers and the crew hostage, the hijackers threatened to kill them if
→ Israel did not release 50 Palestinian prisoners. They also threatened to blow up the ship if
any rescue attempt was made. On 8 October, in the absence of any progress in negotiations,
the Palestinians murdered Leon Klinghoffer, a wheelchair-bound Jewish-American
passenger, and threw his body overboard.

3 On the following day, the terrorists surrendered, after having secured a safe conduct
agreement with Egypt, the Federal Republic of Germany, and Italy, on the condition that
they would release all the passengers in exchange for handing the hijackers over to the PLO
(Sacerdoti 25–27). The negotiations were conducted on behalf of the Palestinians by the
leader of the PLF, Abu Abbas. When the news that an American citizen had been murdered
on board began to circulate in the media, the President of the United States immediately
asked for the → extradition of the Palestinians. In response, Egypt denied any knowledge of
the crime and allowed the hijackers to leave its territory. Once Klinghoffer’s murder was
confirmed, Egypt upheld its intention to respect the agreement, probably in the hope of
avoiding terrorist reprisals from Palestinian groups and a worsening of its political relations
with the PLO.

4 On 10 October, the Egyptian aircraft transporting the hijackers and the Palestinian
negotiators, including PLF leader Abu Abbas, was intercepted on its way to Tunis by four
American fighter planes and forced to land at the NATO base of Sigonella, in Sicily, after
having received permission from the Italian authorities. Once they had disembarked, the
terrorists were taken into judicial custody by the Italian authorities, which refused both
United States’ demands for the extradition of the hijackers and the request for the
provisional arrest of Abu Abbas. After having questioned him on board the aircraft, the
Italian officials declared themselves satisfied with the results of their inquiries. Although
the US requested additional time to bring further evidence in support of their application
for arrest, the Italian authorities allowed the Egyptian aircraft, with Abu Abbas and the
other Palestinian negotiators on board, to leave the NATO base bound for Rome. Abu Abbas
then flew from Ciampino Airport on a Yugoslavian aircraft.

5 The Italian courts later put 15 men on trial for the → hijacking of the Achille Lauro. Only
five of them appeared before the tribunal, the others, including the PLF leader, were judged
in absentia and found guilty of serious breaches of Italian criminal law.

B. Legal Assessment of the Facts

6 The events described here raised some legal questions concerning the → legitimacy of
the decisions and subsequent actions taken by the States involved under international law.
The hijacking of the Achille Lauro also made the → international community aware of the
need to adopt political and legal measures in order to provide an adequate response to acts
of maritime → terrorism, with a view to preventing their recurrence in the future.

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 1. Characterization of the Crimes and the Right of the US to
Exercise Jurisdiction over Them
7 The first question concerns the characterization of the acts performed by the hijackers.
Even though the seizure of the Achille Lauro was an instance of maritime terrorism, at the
time there was no common definition of such a crime, nor were there any specific
international rules for dealing with it.

8 The United States charged the Palestinians with → piracy and with taking → hostages,
thus aiming to establish US jurisdiction over the crimes and its right to arrest the terrorists.
As to the first charge, the definition of the seizure of the Achille Lauro as piracy iuris
gentium, which would have enabled the establishment of American jurisdiction according to
the → universality principle, was controversial. The prerequisites set by international law
and enshrined in both the 1958 Geneva Convention on the High Seas (→ High Seas) and by
the 1982 UN Convention on the Law of the Sea were not satisfied in this case. According to
Art. 15 High Seas Convention and Art. 101 UN Convention on the Law of the Sea, in order
to fall within the category of piracy, an act of maritime violence must be committed for
private ends by a private ship against another ship on the high seas. Thus, the hijacking of
the Achille Lauro could not be qualified as a piratical act, since the two-vessel requirement
was lacking and because the terrorists acted for political ends.

9 Having said that, a part of the doctrine that diverges from this conclusion holds that the
definition of piracy included in the 1958 High Seas Convention and in the 1982 UN
Convention on the Law of the Sea does not embody → customary international law. In
addition, it has been argued that the conventions should be reviewed and that the definition
of piracy should be widened, as it appears to be anachronistic and too narrow to meet
prevailing political and social needs. Originally aimed at preventing States from becoming
involved with insurgents (→ Insurgency) who had not yet been given the status of a
belligerent party, the definition does not take into account acts committed for political ends,
while targeting the ship of a third State neutral to the conflict.

10 The US stance, even if supported by some scholars, was not shared by the international
community. Even after States had been requested to draft a convention aimed at countering
maritime terrorism, they opted not to consider a broader definition of piracy (see paras 27–
30 below).

11 Even if one subscribes to the position which equates modern pirates with terrorists, the
interception of the Egyptian aircraft for the purpose of apprehending the Palestinians would
still have been illegitimate. In fact, international law authorizes States to arrest the pirates
themselves or to seize their vessels, but not to seize the ships or the aircraft of sovereign
States that are transporting them.

12 As to the second charge—that of hostage taking—both the United States and Egypt
were parties to the 1979 International Convention against the Taking of Hostages ([adopted
17 December 1979, entered into force 3 June 1983] 1316 UNTS 205), which allows a State
Party to exercise jurisdiction when the hostage ‘is a national of that State’. If the offenders
are present in the territory of another State Party, the latter is bound either to try them or
to hand them over to the State requesting extradition. By signing the safe conduct
agreement without US consent, Egypt derogated from the 1979 Convention against the
Taking of Hostages and violated its obligations towards the United States. The legitimacy

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 under international law of the US reprisal, consisting of the interception of the Egyptian
aircraft, will be discussed in the next section.

2. Interception of the Achille Lauro Hijackers

13 Even if one admits the right of the United States to arrest the Palestinians and to put
them on trial, and the violation by Egypt of its obligation to extradite terrorists, the
legitimacy of the interception of the Egyptian aircraft, and its forced landing at Sigonella is
still questionable. In this respect, the act amounted to a use of military force, which is
banned under international law (→ Use of Force, Prohibition of). Indeed, Art. 2 (4) UN
Charter must be interpreted as prohibiting not only war but also the use of a lesser kind of
armed violence. The interception of the aircraft is to be considered as an unlawful act,
which cannot be justified under the exception of legitimate → self-defence provided for by
Arts 51 and 53 UN Charter. In fact, Egypt, the State against which the United States used
force, had not perpetrated any form of violence against American citizens.

14 In responding to the unlawful refusal of Egypt to extradite the Palestinians, the United
States should have resorted to peaceful alternatives. In the first instance, they should have
demonstrated that every legitimate effort to secure the extradition, arrest, and prosecution
of the terrorists had failed or would have been likely to fail. In the case under examination,
the Italian government took all the necessary steps to ask the PLO to extradite the
hijackers, so that the US government could have waited and demanded that Italy hand over
the terrorists at a later stage.

15 Instead, the United States preferred to resort to military force under the assumption
that they were acting lawfully. The fact that the US government did not offer any
explanation to Egypt, even when asked to do so, simply proves this point.

3. Request for the Extradition of the Palestinians and for the

Provisional Arrest of Abu Abbas
16 A further question is whether the Italian government’s decision not to extradite the four
hijackers to the United States, and its refusal to carry out the provisional arrest of Abu
Abbas, were legitimate under international law. Article 3 Extradition Treaty between Italy
and the United States of America ([signed 13 October 1983, entered into force 24
September 1984] 1590 UNTS 161; ‘Extradition Treaty’) establishes that when one of the
parties requests an extradition for crimes not committed on its territory, then the requested
party has the power to grant the extradition if its laws provide for the punishment of such
an offence or if the wanted person is a national of the requesting party. According to this
provision, Italy had the authority to concede to, or to refuse, the extradition of the
Palestinians.

17 As to the request for the provisional arrest of Abu Abbas, which was necessary for his
extradition, Art. 12 Extradition Treaty provides that the application for the arrest must
include certain documents listed in its text. The United States attached to their request the
evidence that they deemed sufficient to show that the PLF leader had directed the whole
operation and that he had given instructions to the Palestinians engaged in the seizure of
the Achille Lauro. Notwithstanding this claim, the three Italian judges charged with the
examination of the request and the enclosed documentation found that such evidence was
insufficient to justify a measure restricting Abu Abbas’s freedom. Accordingly, the Italian
government denied the US request on the basis that the evidence produced lacked the

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 substantial elements that were needed in order to carry out the arrest in accordance with
Italian criminal law. In addition, the Italian Ministry of Justice declared that the aircraft had
enjoyed extraterritorial status and rights since it was on a special mission for the Egyptian
government (→ Extraterritoriality; → Immunities, Special Missions). As a consequence, the
national authorities could not adopt coercive measures while Abu Abbas was on board and
without the consent of the pilot of the aircraft.

18 The arguments put forward by the Italian officials were not fully consistent with
international regulations. Indeed, a very important principle of customary international law,
also enshrined in Art. 27 → Vienna Convention on the Law of Treaties (1969), declares that
a State cannot invoke its own legislation as justification for its failure to comply with an
international treaty. In the case under examination, the Italian judges applied very precise
and strict rules in order to evaluate the evidence produced by the United States. Article 12
Extradition Treaty merely states that available evidence must be attached to the application
for provisional arrest, without further specifying the type of evidence required. In this case,
the international rule should have prevailed over the Italian one, since the former was
embodied in an international treaty and that treaty was enacted subsequent to the Italian
code of criminal procedure (lex posterior).

19 However, even if one were to concede that according to Art. 12 Extradition Treaty the
evidence produced by the United States satisfied the preconditions to allow the provisional
arrest, Italy had still to respect the immunity of the aircraft. Accordingly, the Italian
authorities could not take coercive measures limiting the freedom of Abu Abbas while he
was on board, without violating Italy’s obligations towards Egypt under customary
international law. But they could have proceeded to arrest the Palestinians’ representative
once he had left the Egyptian aircraft in Ciampino Airport.

20 The reasons why the Italian authorities did not comply with the American request are
more of a political than a legal nature. At the time of the request, the ship was still
anchored in Port Said and the Italian government probably wished to secure the safe return
of the passengers on board. Thus, the strongest rationale behind their decision was that the
Italian authorities intended to avoid any form of terrorist revenge against Italian citizens or
territories.

21 The decision to allow Abu Abbas to leave Italy was controversial and not without
consequences. It contributed to a crisis of diplomatic relations with the United States and to
the collapse of the Italian government.

4. Legal Proceedings before the Italian Courts

22 The Italian authorities later came to regret the escape of Abu Abbas. In 1986, the Court
of Assizes in Genoa found him guilty of having planned and instigated the seizure of the
Achille Lauro. Abu Abbas was condemned in absentia together with ten other terrorists
(decision of 10 July 1986, not published). However, he was arrested only in 2003 in Iraq.
Three of the four hijackers appeared before the same court and were sentenced to 30 years
in prison, while the fourth was sentenced by the Juvenile Court in Genoa. The decisions
were confirmed by the Appellate Court of Assizes and by the Juvenile Section of the Court
of Appeal respectively. The Italian judges sentenced the terrorists on the grounds of
kidnapping for terrorist purposes according to Art. 289 bis Italian Criminal Code.

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 23 The competence of the Genoese judges was established by the Italian Supreme Court
(Corte di Cassazione Penale [30 October 1985]). In order to decide on the matter, the Court
first invoked Art. 19 Convention on the Territorial Sea and the Contiguous Zone ([done 29
April 1958, entered into force on 10 September 1964] 516 UNTS 205)—which corresponds
to Art. 27 UN Convention on the Law of the Sea—and which actually grants to the coastal
State the criminal jurisdiction on board a foreign ship passing through the territorial sea ‘if
the consequence of the crime extend to the coastal State…or if the crime is of a kind to
disturb the peace of the country or the good order of the territorial sea’ (→ Maritime
Jurisdiction). The conclusion of the Supreme Court, supported by the Court of Assizes of
Genoa, was that the crimes under consideration did not meet the requirements to affirm
Egypt’s jurisdiction. It then argued that since the offences had been committed on board a
ship sailing under an Italian flag, it was as if they had taken place on Italian territory,
specifically, in the harbour of Genoa, where the hijackers, posing as tourists, boarded the
ship.

24 Once they had established their jurisdiction, the Genoese judges identified Italian
criminal law as applicable to the case, since the acts were committed on board an Italian
ship. However, they did not resort to international law in order to evaluate the crimes
perpetrated by the Palestinians. As pointed out by scholars (cf Cassese 105–21), before
applying the lex fori, the Italian courts should have first determined whether the hijackers
were to be considered as mere terrorists and, as such, liable to the penalties foreseen in
Italian criminal law for ordinary crimes, or whether they were lawful → combatants in a war
of national liberation (→ Wars of National Liberation), and thus subject to the rules of
humanitarian law (→ Humanitarian Law, International).

25 To its credit, however, the Court of Assizes presented a very precise reconstruction of
the facts that led to interesting conclusions from the point of view of international law.
Whereas the terrorists had tried to demonstrate that their original goal was to reach and
then attack Israel, after a very detailed analysis of the facts and the background to the
affair, the judges concluded that from the very beginning, the only operation planned by
Abu Abbas was the seizure of the Achille Lauro. His objective was probably to have the
international community believe that Yasser Arafat was responsible and that the seizure of
the ship could thus not be seen as anything other than a terrorist act. Armed actions by
Palestinians could be justified as a fight for → self-determination as long as they targeted
Israel, its citizens, or the Arab territory it occupied (→ Israel, Occupied Territories). As
remarked on by scholars, the purpose of the hijacking of the Italian ship was instead to
sabotage the development of Yasser Arafat’s negotiations with Egypt and Jordan, and to
undermine his prestige within the PLO, thus benefiting his rival, Abu Abbas.

26 Italian judges demonstrated that Abu Abbas alone was responsible for planning and
carrying out the hijacking, while the PLO and Arafat had played no role in it. Thus, in
proving that such action was not part of the Palestinian war of liberation, the judges
implicitly showed that the hijackers were not lawful combatants and that they therefore
could be found guilty of ordinary crimes under the Italian Criminal Code.

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 C. Consequent Development of Treaty Law
27 The seizure of the Achille Lauro made the international community aware of the need to
develop a legal framework suited to the task of countering terrorism at sea. With the
support of Austria and Egypt, Italy put forward Resolution 40/61 to the United Nations
General Assembly and this resolution was adopted by consensus on 9 December 1985
(GAOR 40th Session Supp 53, 301). After condemning ‘as criminal, all acts, methods and
practices of terrorism wherever and by whomever committed’ (para. 1), the resolution
requested the → International Maritime Organization (IMO) to ‘study the problem of
terrorism aboard or against ships with a view to making recommendations on appropriate
measures’ (para. 13). As suggested above, one of the options on the table was to enlarge
the notion of piracy so that it could also include acts such as the seizure of the Achille
Lauro. However, the States involved in drafting a convention for the prevention and
suppression of maritime terrorism under the auspices of the IMO followed a different route.
The conference that was convened in Rome in 1988 to negotiate the agreement decided to
follow the ‘sectorial’ approach for dealing with international terrorism that had been
adopted in previous multilateral treaties, such as those concerning unlawful acts against
the safety of air navigation.

28 In accordance with the ‘sectorial’ approach, Art. 3 Convention for the Suppression of
Unlawful Acts against the Safety of Maritime Navigation (‘SUA Convention’), which entered
into force in 1992, lists the specific offences to which it applies. The description of those
acts follows the model of the Convention for the Suppression of Unlawful Acts against the
Safety of Civil Aviation 1971 ([concluded 23 September 1971, entered into force 26 January
1973] 974 UNTS 177) and includes the condition that the offences are ‘likely to endanger
the safe navigation of the ship’ (Art. 3 SUA Convention).

29 Since the background behind the drafting of the SUA Convention, unlike other anti-
terrorist multilateral treaties, is strictly linked to the seizure of the Achille Lauro, the SUA
Convention provides that the act of killing or injuring a person, when perpetrated in
connection with the commission or the attempted commission of any other acts listed in Art.
3 SUA Convention, amounts to a separate offence and not just to an aggravating
circumstance of other crimes. The influence of the events relating to the Achille Lauro is
traceable, even in the way the SUA Convention defines how States may establish their
jurisdiction over the offences. The definition includes the State targeted by the terrorist act,
as well as the State whose citizen is the victim of the offence. In this sense, the SUA
Convention bypasses the traditional principles of active nationality and of territoriality,
which are usually the criteria chosen for establishing compulsory jurisdiction.

30 Like other treaties against terrorism, the SUA Convention follows the principle → aut
dedere aut iudicare. Accordingly, it obliges the party in whose territory the offender is
found to either extradite the person to another State that has established its jurisdiction
under the SUA Convention, or to submit the case to its own authorities for prosecution.

D. Conclusions
31 The SUA Convention marks a fundamental step forward in the fight against terrorism
and, more generally, in the development of international law. Its importance for countering
violence at sea has been recently stressed even by the UN Security Council in its Resolution
1846 (2008) of 2 December 2008, which urged States Parties to fully implement their
obligations under the SUA Convention.

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 32 It provides States with a fundamental legal instrument with which to tackle episodes
similar to the seizure of the Achille Lauro, even though it is not likely to guarantee that
many of the legal problems discussed above that were raised by such an affair will not
occur in the future. The legal consequences of the non-compliance with a request for
extradition, the legitimacy of acts—such as those covered by the SUA Convention—
committed by individuals on behalf of governments or of national liberation movements, as
well as the legitimacy of the reaction to such acts, are among the matters that continue to
be regulated by the rules and principles of general international law to which the preamble
of the SUA Convention makes reference (→ General International Law (Principles, Rules and
Standards)).

33 In addition, the case of the Achille Lauro confirms how States are influenced and
guided in their actions by political and diplomatic motives. This analysis highlights the fact
that each of the actors involved in the incident complied with international law only to a
limited extent, instead choosing to pursue their political interests. However, this conclusion
does not serve to belittle, but rather to emphasize the importance of the efforts made by the
international community in this field. Such efforts have been directed at overcoming the
political and ideological aspects of international terrorism, while building, step-by-step, a
network of international obligations able to cover the phenomenon in all—or most of—its
various manifestations. The SUA Convention itself provides the possibility for States Parties
to update and, if necessary, to broaden its scope. In this regard, it is worth pointing out the
amendments adopted in the form of the Protocol of 2005, which broaden the range of
offences to which the regime provided for by the SUA Convention applies.

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 JJ Paust ‘Extradition and United States Prosecution of the Achille Lauro Hostage-
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Select Documents
Convention for the Suppression of Unlawful Acts against the Safety of Maritime
Navigation (concluded 10 March 1988, entered into force 1 March 1992) 1678 UNTS
221.
Convention on the High Seas (done 29 April 1958, entered into force 30 September
1962) 450 UNTS 11.
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70 RivDirInt 955–60.
International Maritime Organization, ‘Protocol of 2005 from the International
Conference on the Revision of SUA Treaties to the Protocols for the Suppression of
Unlawful Acts against the Safety of Fixed Platforms Located on the Continental
Shelf’ (1 November 2005) LEG/CONF.15/22.

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 United Nations Convention on the Law of the Sea (concluded 10 December 1982,
entered into force 16 November 1994) 1833 UNTS 396.

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