In the Six Day War in June 1967, East Jerusalem, the West Bank and the Gaza Strip came under Israeli military occupation, as well as the Sinai Peninsula and the Golan Heights. On 22 November that year, the UN Security Council unanimously passed Resolution 242, which it was hoped would provide a route to a permanent peace. It seems clear that Resolution 242 now has binding force1 and that it is accepted by all parties today that Resolution 242 sets out the principles which must be applied in order to reach a settlement. The Resolution is recited in the preambles to the Oslo Accords.2 This means that, in addition, it is binding on Israel and the PLO by agreement.3

The two consecutive Judgments by the International Court of Justice of 1 July 1994 (‘the July Judgment’) and 15 February 1995 (‘the February Judgment’) in the jurisdiction and admissibility phase of Qatar v. Bahrain have already attracted attention from writers. The Judgments have provided a focus of interest for the law of treaties, and attention has also been concentrated on three legal questions to which the judgments were of particular relevance: the question of whether sovereign consent is necessary to the manner of seisin employed as well as to jurisdiction itself, the emergence of the concept of a partial decision, and the extension of the use of framework agreements to found the jurisdiction of the court. But this Article considers a different question, a key finding of fact in the February Judgment which was crucial to the decision of the Court that it had jurisdiction. This finding was that the linguistic meaning of wording at the heart of one of the Arabic texts on which Qatar relied in order to give the Court jurisdiction entitled either party to submit the case to the Court unilaterally.