Austrian Review of International and European Law 25: 219-238, 2020.
© 2022 Koninklijke Brill NV.
The Case of Certain Iranian Assets:
The Standard for Joining Preliminary
Objections to the Merits Revisited and the
Treatment of State-Owned Enterprises
before the International Court of Justice
Giulio Alvaro Cortesi
*
I. Introduction
This article focuses on the 2019 judgment on preliminary objections in
Certain Iranian Assets (Iran v US)
1
by the International Court of Justice (ICJ).
Iran initiated these proceedings on 14 June 2016 on the basis of the Treaty
of Amity, Economic Relations and Consular Rights of 1955,
2
which the US
denounced on 3 October 2018 after Iran started its legal action before the ICJ.
Iran in its application argued that the Court was endowed with jurisdiction to
decide the case on the basis of Article XXI(2) of the abovementioned Treaty of
Amity of 1955. The US objected to this and raised two preliminary objections
concerning the admissibility of the Iranian application and three objections
related to the jurisdiction of the Court. Consequently, by virtue of Article
79(5) of the Rules, the proceedings on the merits were suspended, and the
President of the Court fxed the time limit within which Iran could present
a written statement of its observations and submissions on the preliminary
objections raised by the US. Iran fled such a statement, and the case thus
became ready for hearing in respect of the preliminary objections.
The aim of this article is twofold: frst, to analyse whether the Court was
correct in joining the third preliminary objection related to the status of Bank
*
Docteur en Droit à Paris 1 Panthéon Sorbonne et avocat au Barreau de Paris. I
want to thank Kristin Young for her valuable support. All remaining errors are
mine.
1
Certain Iranian Assets (Islamic Republic of Iran v United States of America)
(Preliminary Objections) [2019] ICJ 7 (Judgment of 13 February).
2
Treaty of Amity, Economic Relations and Consular Rights between United States
of America and Islamic Republic of Iran, 15 August 1955, 284 UNTS 93.
Downloaded from Brill.com05/03/2023 08:01:27AM
via free access