Sebastián López Escarcena
Sebastián López E. is full professor (profesor titular) and researcher at the Faculty of Law of the Pontifical Catholic University of Chile, where he teaches public international law, international investment law, international human rights law, international dispute settlement and legal research. He is also an associate fellow of the Centre for Global Governance Studies (CGGS) of the Catholic University of Leuven, Belgium. Sebastián has been guest lecturer at the University of Edinburgh, UK; visiting scholar at Cornell University, USA, the University Paris 1 "Panthéon-Sorbonne", France, the University of Amsterdam, The Netherlands, and the Boston College, USA; guest professor at the University of Notre Dame, USA, the University of the Pacific, Peru, the University of Heidelberg, Chile (Center for Latin America), and the Catholic University of Valparaíso, Chile; and visiting professor at the University of Leuven. He has taught as well at the Diplomatic Academy, the Judicial Academy and the Military Academy of the Chilean state; worked as director of the Department of International Law and academic-secretary of the PhD in law programme of the Pontifical Catholic University of Chile; participated in PhD and LLM examinations at the University of Chile and the University of Concepción, among others; and executed state-funded projects as main researcher, and as co-researcher. Sebastián has been admitted to the Chilean bar, and holds a PhD from the University of Edinburgh, an LLM from the University of Leiden, The Netherlands, and an LLB and BA from the Pontifical Catholic University of Chile. His research focuses on the international protection of property, mostly in international human rights law and international investment law, and on the history and theory of international law, from a Latin American perspective. He has published academic books, articles, essays, case notes, book reviews, working papers and policy briefs in the Americas and Europe, in Spanish and English.
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Books by Sebastián López Escarcena
Filling a gap in the legal literature, this book aims to bridge the gap between the European and Latin American experiences of national human rights institutions (NHRIs), exploring the impact that this has internationally. As such, it not only includes introductory chapters on the relationship between NHRIs and the United Nations, the European Union and the Inter-American Court of Human Rights, but also offers general contributions on other European and Latin American institutions and valuable deep dives into specific case studies on certain regional commissions, ombuds offices and institutes. In order to assess the distinct models these institutional organisations adopt, three of the major European NHRIs have been
chosen: the Spanish Ombuds Office, which is especially relevant to Latin America; the French Commission, of great influence in the area; and the younger, and highly interesting, German Institute. The main Latin American NHRIs which adopt either an ombuds, a commission or an institute model are also analysed, including those of Argentina, Chile, Colombia, Ecuador, Mexico, Paraguay, and Uruguay.
With contributions by Paola Acosta (Externado University of Colombia), Heiner Bielefeldt (Friedrich-Alexander University Erlangen-Nürnberg), Emmanuel Decaux (University of Paris Panthéon-Assas), Sebastián Donoso (Council of the National Human Rights Institute of Chile), José Julio Fernández (University of Santiago de Compostela), Pablo González Domínguez (Pan-American University of Mexico), Veronika Haasz
(University of Vienna), Markus Krajewski (Friedrich-Alexander University of ErlangenNürnberg), Michael Krennerich (Friedrich-Alexander University Erlangen-Nürnberg), Sebastián López Escarcena (Pontifical Catholic University of Chile), Emilio Maus Ratz (Pan-American University in Mexico City), Katrien Meuwissen (European Network of National Human Rights Institutions), Manuel Núñez Poblete (Pontifical Catholic University of Valparaíso, Chile), Beate Rudolf (German Institute for Human Rights),
Eduardo Vio Grossi (†) (Pontifical Catholic University of Valparaíso) and Jan Wouters (KU Leuven).
Este libro tiene como principal objetivo contribuir al debate constitucional chileno en asuntos que resultan ineludibles en toda discusión de esta naturaleza. Con este fin, los artículos que lo componen abordan, de una manera tanto teórica como práctica, diversos aspectos destacados de las relaciones del derecho internacional con el derecho interno. Se ofrece así, un recuento amplio y prospectivo de estas, útil no solo para quienes se involucren en el proceso constituyente nacional, sino para toda persona interesada en el derecho público en general. De esta manera, el presente libro busca no solo hacer un balance de cómo las relaciones entre el derecho internacional y el derecho interno se encuentran normadas en la Constitución Política de la República, sino proponer alternativas para una nueva carta fundamental en diversos temas de importancia pública, como son la institucionalidad de las relaciones exteriores en Chile; la incorporación y la jerarquía de los tratados en nuestro país; el control preventivo y la inaplicabilidad por constitucionalidad de estos; la implementación del derecho internacional por los tribunales chilenos; entre otros.
Con contribuciones de Elvira Badilla (Universidad Católica del Norte), Cristián Delpiano (Segundo Tribunal Ambiental de Santiago), Martín Loo (Pontificia Universidad Católica de Valparaíso), Sebastián López E. (Pontificia Universidad Católica de Chile), Manuel Núñez P. (Pontificia Universidad Católica de Valparaíso), Fernando Ochoa (Segundo Tribunal Ambiental de Santiago), Álvaro Paúl (Pontificia Universidad Católica de Chile), Sebastián Soto (Pontificia Universidad Católica de Chile), y Osvaldo Urrutia (Pontificia Universidad Católica de Valparaíso).
James Harrison, University of Edinburgh Law School, UK
When does a state measure become subject to compensation as an indirect expropriation under international law? The author examines claims of indirect takings from such fora as the Iran-United States Claims Tribunal, the European Court of Human Rights, and arbitral panels in investment treaty arbitrations.
Sebastián López Escarcena offers a comprehensive coverage of the history and main concepts of the international law of expropriation. The interaction between human rights conventions and investment treaties are analysed from a global perspective, providing the reader with a unique insight into expropriation at an international level. Within the course of his examination, the author illuminates important concepts of public law, from deprivation of property to payment of compensation, and from margin of appreciation to proportionality.
In examining in detail the case law of different international tribunals, this shrewd book formulates some insightful answers to the threshold question, and will be of great interest to decision-makers in investment treaty arbitrations, to legal practitioners, state officers and scholars in international investment law and international human rights law, and to anyone dealing with international and comparative law in general.
Papers by Sebastián López Escarcena
For all the cases examined in this volume, an effort has been made to identify the most important challenges facing NHRIs, in conjunction with their primary organisational patterns, powers and relationships with regional human rights protection systems. Consequently, the case studies included in this book outline the legal basis of each institution, emphasising their structure and mandate, in addition to their role, both as stipulated by national legislation and in terms of their participation in the international monitoring process, led today by the Global Alliance for National Human Rights Institutions (GANHRI). For Latin American institutions, the emphasis has been placed on their interaction with the systems of the UN and of the Organization of American States (OAS), while for European NHRIs the focus of analysis has been broader, encompassing the UN, the EU, the Council of Europe and the Organization for Security and Co-operation in Europe (OSCE). In the NHRIs studied throughout this book, several common challenges can be observed: building or consolidating trust; budgetary cuts; delays in the establishment processes; non-renewal of their membership by state authorities; or an expansion of roles without the necessary support in terms of personnel and infrastructure. In addition, several specific challenges have also been identified, such as the consolidation of pluralism within each institution; competition with other bodies with greater authority and social influence; and a lack of opportunities for regional cooperation.
The Paris Principles have not only allowed the UN to delineate NHRIs, but have also become the benchmark used for measuring their structural design. For years, these non-binding principles have been applied as legal rules in the now all-important accreditation processes which govern these institutions. However, two questions remain: what exactly is the nature of an NHRI? And what is its main objective? This chapter seeks to answer these questions. NHRIs are the offspring of the UN’s fairly well-documented commitment to the promotion and protection of human rights. For this reason, the work that follows considers the historical background within which the Paris Principles appeared, before analysing their legal status and ultimate purpose according to different theoretical perspectives in law.
From a comparative perspective, NHRIs are a common tool of constitutional law for the promotion and protection of human rights. As this book has shown, this is particularly true for Latin American NHRIs, where the figure of the ombuds tends to take precedence over commissions or institutes. With few exceptions, the vast majority of these NHRIs enjoy a legal status that allows us to describe them as constitutional institutions, aimed at fulfilling that critical role. NHRIs’ relevance has been recently highlighted by the UN, the Council of Europe and the OAS. In 2017, the UNGA promoted the existence of independent NHRIs as an indicator for Sustainable Development Goal 16 of Agenda 2030 – that of promoting just, peaceful and inclusive societies; it reiterated the significance of NHRIs during the COVID-19 pandemic. Three years later, the UN Human Rights Council also recognised ‘the important role of national human rights institutions in highlighting the human rights implications of the COVID-19 pandemic’, thus renewing the global call for increased awareness about these institutions and their work. Regionally, the Committee of Ministers of the Council of Europe adopted in 2021 a recommendation on the development and strengthening of NHRIs, which follows on from its important 1997 recommendation on the original establishment of these institutions. The 2021 recommendation of the Committee of Ministers focuses not only on individual NHRIs, but also on the ENNHRI and GANHRI, bolstering them, respectively, as a regional promoter of technical assistance and as a global network. This is an important endorsement, given the essentially cooperative nature of NHRIs and the proven need to exchange institutional experiences. On the other side of the Atlantic Ocean, the IACHR included NHRIs among the core elements of its 2017–2021 Strategic Plan, which in 2018 led to the signing of a Declaration of Commitment for Technical Cooperation and the creation of a Mechanism of Points of Contact that, to date, comprises a dozen NHRI members. Although this mechanism is nascent, it is a necessary companion to the as yet precarious cooperation that exists within the Network of National Institutions for the Promotion and Protection of Human Rights in the American Continent (RINDHCA), which currently has 18 members, 15 of which have been accredited with ‘A-status’ and three with ‘B-status’ by GANHRI. In its 2023–2027 Strategic Plan, the IACHR mentioned following up on the Declaration of Commitment for Technical Cooperation as one of its lines of action, emphasising the need to continue expanding, diversifying, and deepening civil society participation in the activities of NHRIs.
2 Direct expropriations include, at least, the transfer of the property’s title from the original owner to the → State (Sempra Energy International v Argentine [2007] para. 280); the transfer of the title to a third person (Amco Asia Corporation and others v Republic of Indonesia [1984] para. 158; → Amco v Indonesia Case); or the possession of the property without formally transferring title to the State or to a third person (Wena Hotels Ltd v Egypt [2000] para. 99). Compared with indirect expropriations, it is usually easy to establish when a direct taking has occurred, in which case → compensation will be due, regardless of the cause (Compañía del Desarrollo de Santa Elena SA v Costa Rica [2000] paras 71–72). Historically, direct expropriations were the first and most common form of taking. Nowadays, they are not frequent and only a few modern disputes have dealt with them (Ranjan and Anand [2016] 130; Zhu [2019] 378, 380; Dolzer Kriebaum and Schreuer [2022] 153).
3 Indirect expropriations refer to those measures that fall short of a direct taking, but in their effects amount to one, thus requiring compensation (CME v Czech Republic [2001] para. 604; BG Group Plc v Argentina [2007] para. 264). This type of taking is the prevalent form today. It has alternative names and definitions in international law, which stress certain aspects of what constitutes an indirect taking. Notions like de facto, disguised, creeping, consequential, or constructive expropriation, as well as regulatory takings, have been progressively developed (Hoffmann [2008] 152–54; de Nanteuil [2014] 9–13; Radi [2020] 157–59). This explains why some of them relate to behaviour that would not have provided a sound legal basis for an expropriation claim under → treaties of friendship, commerce and navigation (‘FCN’), but would do so under a bilateral investment treaty (‘BIT’) (→ Investments, Bilateral Treaties) (Reisman and Sloane [2003] 119). A creeping expropriation, for instance, has ‘a distinctive temporal quality in the sense that it encapsulates the situation whereby a series of acts attributable to the State over a period of time culminate in the expropriatory taking of such property’ (Generation Ukraine Inc v Ukraine [2003] para. 20.22). The denomination regulatory takings, on the other hand, comes from US Constitutional doctrine, and refers to those measures adopted in the exercise of the State’s powers to govern social and economic activity within its boundaries. Although it has not yet been formally used in → treaties, this type of taking can be recognized in the definition or description given by modern international agreements to expropriation (AlQurashi [2004] 901).
4 The → Permanent Court of International Justice (PCIJ) and the → International Court of Justice (ICJ) have seldom referred to indirect expropriation in their decisions. The case law on this issue derives mainly from the ever-growing number of arbitral awards (→ Arbitral Award) in investor-State dispute settlement (‘ISDS’), mostly based on international investment agreements (‘IIAs’). Outside international investment law, the protection of property from deprivation has been addressed by regional human rights bodies in Europe and, to a lesser extent, in the Americas. Important judicial decisions for the international law of expropriation also emerge from ad hoc dispute settlement institutions, most notably the → Iran–United States Claims Tribunal (‘IUSCT’), whose jurisprudence is publicly available and constitutes an indispensable guide for international adjudicators and decision-makers confronted with indirect takings. The work of US domestic courts is highly instructive as well, and should not be overlooked in any study on the topic.
Filling a gap in the legal literature, this book aims to bridge the gap between the European and Latin American experiences of national human rights institutions (NHRIs), exploring the impact that this has internationally. As such, it not only includes introductory chapters on the relationship between NHRIs and the United Nations, the European Union and the Inter-American Court of Human Rights, but also offers general contributions on other European and Latin American institutions and valuable deep dives into specific case studies on certain regional commissions, ombuds offices and institutes. In order to assess the distinct models these institutional organisations adopt, three of the major European NHRIs have been
chosen: the Spanish Ombuds Office, which is especially relevant to Latin America; the French Commission, of great influence in the area; and the younger, and highly interesting, German Institute. The main Latin American NHRIs which adopt either an ombuds, a commission or an institute model are also analysed, including those of Argentina, Chile, Colombia, Ecuador, Mexico, Paraguay, and Uruguay.
With contributions by Paola Acosta (Externado University of Colombia), Heiner Bielefeldt (Friedrich-Alexander University Erlangen-Nürnberg), Emmanuel Decaux (University of Paris Panthéon-Assas), Sebastián Donoso (Council of the National Human Rights Institute of Chile), José Julio Fernández (University of Santiago de Compostela), Pablo González Domínguez (Pan-American University of Mexico), Veronika Haasz
(University of Vienna), Markus Krajewski (Friedrich-Alexander University of ErlangenNürnberg), Michael Krennerich (Friedrich-Alexander University Erlangen-Nürnberg), Sebastián López Escarcena (Pontifical Catholic University of Chile), Emilio Maus Ratz (Pan-American University in Mexico City), Katrien Meuwissen (European Network of National Human Rights Institutions), Manuel Núñez Poblete (Pontifical Catholic University of Valparaíso, Chile), Beate Rudolf (German Institute for Human Rights),
Eduardo Vio Grossi (†) (Pontifical Catholic University of Valparaíso) and Jan Wouters (KU Leuven).
Este libro tiene como principal objetivo contribuir al debate constitucional chileno en asuntos que resultan ineludibles en toda discusión de esta naturaleza. Con este fin, los artículos que lo componen abordan, de una manera tanto teórica como práctica, diversos aspectos destacados de las relaciones del derecho internacional con el derecho interno. Se ofrece así, un recuento amplio y prospectivo de estas, útil no solo para quienes se involucren en el proceso constituyente nacional, sino para toda persona interesada en el derecho público en general. De esta manera, el presente libro busca no solo hacer un balance de cómo las relaciones entre el derecho internacional y el derecho interno se encuentran normadas en la Constitución Política de la República, sino proponer alternativas para una nueva carta fundamental en diversos temas de importancia pública, como son la institucionalidad de las relaciones exteriores en Chile; la incorporación y la jerarquía de los tratados en nuestro país; el control preventivo y la inaplicabilidad por constitucionalidad de estos; la implementación del derecho internacional por los tribunales chilenos; entre otros.
Con contribuciones de Elvira Badilla (Universidad Católica del Norte), Cristián Delpiano (Segundo Tribunal Ambiental de Santiago), Martín Loo (Pontificia Universidad Católica de Valparaíso), Sebastián López E. (Pontificia Universidad Católica de Chile), Manuel Núñez P. (Pontificia Universidad Católica de Valparaíso), Fernando Ochoa (Segundo Tribunal Ambiental de Santiago), Álvaro Paúl (Pontificia Universidad Católica de Chile), Sebastián Soto (Pontificia Universidad Católica de Chile), y Osvaldo Urrutia (Pontificia Universidad Católica de Valparaíso).
James Harrison, University of Edinburgh Law School, UK
When does a state measure become subject to compensation as an indirect expropriation under international law? The author examines claims of indirect takings from such fora as the Iran-United States Claims Tribunal, the European Court of Human Rights, and arbitral panels in investment treaty arbitrations.
Sebastián López Escarcena offers a comprehensive coverage of the history and main concepts of the international law of expropriation. The interaction between human rights conventions and investment treaties are analysed from a global perspective, providing the reader with a unique insight into expropriation at an international level. Within the course of his examination, the author illuminates important concepts of public law, from deprivation of property to payment of compensation, and from margin of appreciation to proportionality.
In examining in detail the case law of different international tribunals, this shrewd book formulates some insightful answers to the threshold question, and will be of great interest to decision-makers in investment treaty arbitrations, to legal practitioners, state officers and scholars in international investment law and international human rights law, and to anyone dealing with international and comparative law in general.
For all the cases examined in this volume, an effort has been made to identify the most important challenges facing NHRIs, in conjunction with their primary organisational patterns, powers and relationships with regional human rights protection systems. Consequently, the case studies included in this book outline the legal basis of each institution, emphasising their structure and mandate, in addition to their role, both as stipulated by national legislation and in terms of their participation in the international monitoring process, led today by the Global Alliance for National Human Rights Institutions (GANHRI). For Latin American institutions, the emphasis has been placed on their interaction with the systems of the UN and of the Organization of American States (OAS), while for European NHRIs the focus of analysis has been broader, encompassing the UN, the EU, the Council of Europe and the Organization for Security and Co-operation in Europe (OSCE). In the NHRIs studied throughout this book, several common challenges can be observed: building or consolidating trust; budgetary cuts; delays in the establishment processes; non-renewal of their membership by state authorities; or an expansion of roles without the necessary support in terms of personnel and infrastructure. In addition, several specific challenges have also been identified, such as the consolidation of pluralism within each institution; competition with other bodies with greater authority and social influence; and a lack of opportunities for regional cooperation.
The Paris Principles have not only allowed the UN to delineate NHRIs, but have also become the benchmark used for measuring their structural design. For years, these non-binding principles have been applied as legal rules in the now all-important accreditation processes which govern these institutions. However, two questions remain: what exactly is the nature of an NHRI? And what is its main objective? This chapter seeks to answer these questions. NHRIs are the offspring of the UN’s fairly well-documented commitment to the promotion and protection of human rights. For this reason, the work that follows considers the historical background within which the Paris Principles appeared, before analysing their legal status and ultimate purpose according to different theoretical perspectives in law.
From a comparative perspective, NHRIs are a common tool of constitutional law for the promotion and protection of human rights. As this book has shown, this is particularly true for Latin American NHRIs, where the figure of the ombuds tends to take precedence over commissions or institutes. With few exceptions, the vast majority of these NHRIs enjoy a legal status that allows us to describe them as constitutional institutions, aimed at fulfilling that critical role. NHRIs’ relevance has been recently highlighted by the UN, the Council of Europe and the OAS. In 2017, the UNGA promoted the existence of independent NHRIs as an indicator for Sustainable Development Goal 16 of Agenda 2030 – that of promoting just, peaceful and inclusive societies; it reiterated the significance of NHRIs during the COVID-19 pandemic. Three years later, the UN Human Rights Council also recognised ‘the important role of national human rights institutions in highlighting the human rights implications of the COVID-19 pandemic’, thus renewing the global call for increased awareness about these institutions and their work. Regionally, the Committee of Ministers of the Council of Europe adopted in 2021 a recommendation on the development and strengthening of NHRIs, which follows on from its important 1997 recommendation on the original establishment of these institutions. The 2021 recommendation of the Committee of Ministers focuses not only on individual NHRIs, but also on the ENNHRI and GANHRI, bolstering them, respectively, as a regional promoter of technical assistance and as a global network. This is an important endorsement, given the essentially cooperative nature of NHRIs and the proven need to exchange institutional experiences. On the other side of the Atlantic Ocean, the IACHR included NHRIs among the core elements of its 2017–2021 Strategic Plan, which in 2018 led to the signing of a Declaration of Commitment for Technical Cooperation and the creation of a Mechanism of Points of Contact that, to date, comprises a dozen NHRI members. Although this mechanism is nascent, it is a necessary companion to the as yet precarious cooperation that exists within the Network of National Institutions for the Promotion and Protection of Human Rights in the American Continent (RINDHCA), which currently has 18 members, 15 of which have been accredited with ‘A-status’ and three with ‘B-status’ by GANHRI. In its 2023–2027 Strategic Plan, the IACHR mentioned following up on the Declaration of Commitment for Technical Cooperation as one of its lines of action, emphasising the need to continue expanding, diversifying, and deepening civil society participation in the activities of NHRIs.
2 Direct expropriations include, at least, the transfer of the property’s title from the original owner to the → State (Sempra Energy International v Argentine [2007] para. 280); the transfer of the title to a third person (Amco Asia Corporation and others v Republic of Indonesia [1984] para. 158; → Amco v Indonesia Case); or the possession of the property without formally transferring title to the State or to a third person (Wena Hotels Ltd v Egypt [2000] para. 99). Compared with indirect expropriations, it is usually easy to establish when a direct taking has occurred, in which case → compensation will be due, regardless of the cause (Compañía del Desarrollo de Santa Elena SA v Costa Rica [2000] paras 71–72). Historically, direct expropriations were the first and most common form of taking. Nowadays, they are not frequent and only a few modern disputes have dealt with them (Ranjan and Anand [2016] 130; Zhu [2019] 378, 380; Dolzer Kriebaum and Schreuer [2022] 153).
3 Indirect expropriations refer to those measures that fall short of a direct taking, but in their effects amount to one, thus requiring compensation (CME v Czech Republic [2001] para. 604; BG Group Plc v Argentina [2007] para. 264). This type of taking is the prevalent form today. It has alternative names and definitions in international law, which stress certain aspects of what constitutes an indirect taking. Notions like de facto, disguised, creeping, consequential, or constructive expropriation, as well as regulatory takings, have been progressively developed (Hoffmann [2008] 152–54; de Nanteuil [2014] 9–13; Radi [2020] 157–59). This explains why some of them relate to behaviour that would not have provided a sound legal basis for an expropriation claim under → treaties of friendship, commerce and navigation (‘FCN’), but would do so under a bilateral investment treaty (‘BIT’) (→ Investments, Bilateral Treaties) (Reisman and Sloane [2003] 119). A creeping expropriation, for instance, has ‘a distinctive temporal quality in the sense that it encapsulates the situation whereby a series of acts attributable to the State over a period of time culminate in the expropriatory taking of such property’ (Generation Ukraine Inc v Ukraine [2003] para. 20.22). The denomination regulatory takings, on the other hand, comes from US Constitutional doctrine, and refers to those measures adopted in the exercise of the State’s powers to govern social and economic activity within its boundaries. Although it has not yet been formally used in → treaties, this type of taking can be recognized in the definition or description given by modern international agreements to expropriation (AlQurashi [2004] 901).
4 The → Permanent Court of International Justice (PCIJ) and the → International Court of Justice (ICJ) have seldom referred to indirect expropriation in their decisions. The case law on this issue derives mainly from the ever-growing number of arbitral awards (→ Arbitral Award) in investor-State dispute settlement (‘ISDS’), mostly based on international investment agreements (‘IIAs’). Outside international investment law, the protection of property from deprivation has been addressed by regional human rights bodies in Europe and, to a lesser extent, in the Americas. Important judicial decisions for the international law of expropriation also emerge from ad hoc dispute settlement institutions, most notably the → Iran–United States Claims Tribunal (‘IUSCT’), whose jurisprudence is publicly available and constitutes an indispensable guide for international adjudicators and decision-makers confronted with indirect takings. The work of US domestic courts is highly instructive as well, and should not be overlooked in any study on the topic.
by the Inter-American Court of Human Rights for infringements of the
communal rights that Article 21 of the Pact of San José de Costa Rica recognises
to indigenous and tribal people. Fourteen years have passed since
the first of these judicial decisions was issued. It is presumable that other
states party to the American Convention on Human Rights will join Nicaragua,
Guatemala, Surinam, Paraguay, Ecuador, Colombia, Panamá and
Honduras for violating the collective rights that this conventional provision
protects, one of which is indigenous and tribal property. These rights
derive from an evolutive and pro homine interpretation, where judicial
dialogue and the coordination with extra Inter-American international
law and comparative law play a leading role. Due respect for these rights
require that the case-law from where they arise is well-known. This work
offers a systematisation of the international obligations that Article 21 of
the mentioned treaty establishes, and of the legal principles that constitute
their basis, to aid in the fulfilment of a provision, which is far more
complex than what a simple reading of it allows to anticipate.
internacional.