Power, Sovereignty and the Rule of Law: A Critical Examination of Military and Paramilitary Activities in and against Nicaragua (Nicaragua v. United States of America, 1986) and Its Enduring Legacy in International Law

Abstract

The decision of the International Court of Justice in Military and Paramilitary Activities in and against Nicaragua (Nicaragua v United States of America) marked a turning point in the development of international law on the use of force and State sovereignty. Although the dispute arose during the Cold War, the legal principles established by the Court continue to influence international relations and judicial practice. The case remains significant because it clarified the limits of intervention by one State in the internal affairs of another and reinforced the importance of customary international law.

This paper critically examines the background of the dispute, the legal questions considered by the Court, and the reasoning adopted in its judgment. It analyses the Court’s interpretation of the prohibition on the use of force, the concept of collective self-defence, and the responsibility of States under international law. The discussion also considers the practical difficulties in enforcing international judicial decisions and the continuing relevance of the judgment in the context of present-day armed conflicts and indirect forms of intervention.

The paper argues that the Nicaragua judgment is not merely a historical decision but a continuing legal authority that shapes the interpretation of international obligations. Its contribution lies in strengthening the principles of sovereignty, equality among States, and respect for the rule of law despite political and military inequalities. The study concludes that the judgment remains an essential reference for understanding the relationship between power and law in the contemporary international legal system.

Keywords: Nicaragua Case, International Court of Justice, State Sovereignty, Use of Force, Collective Self-Defence, Customary International Law.

1. INTRODUCTION

As the Permanent Court of International Justice observed in the Lotus case, “International law governs relations between independent States.”¹ International law has often been criticised for lacking effective enforcement mechanisms, particularly when disputes involve politically or militarily influential States. Despite these criticisms, judicial decisions delivered by international courts have played a significant role in shaping legal norms that govern relations between sovereign States. Among these decisions, Military and Paramilitary Activities in and against Nicaragua (Nicaragua v United States of America) occupies a unique position because it reaffirmed that the legality of State conduct must be determined by established legal principles rather than political considerations or strategic interests.²

The dispute emerged during the Cold War, when ideological rivalry frequently influenced foreign policy decisions and regional conflicts. Against this backdrop, Nicaragua accused the United States of violating international law by supporting the Contra rebels, conducting military operations against its territory, and interfering in its domestic affairs.³ The proceedings therefore required the International Court of Justice to address fundamental questions concerning the prohibition on the use of force,⁴ the scope of collective self-defence,⁵ the principle of non-intervention, and the legal status of customary international law.⁶ While these questions arose from a specific historical conflict, the Court’s answers established principles that continue to influence international legal discourse decades later.

The importance of the Nicaragua judgment extends beyond its immediate legal findings. The decision demonstrated that international courts remain capable of articulating objective legal standards even where powerful States contest their jurisdiction or refuse to participate in proceedings. By distinguishing legal reasoning from political expediency, the Court reinforced the idea that international law serves as a normative framework designed to regulate the conduct of all States on the basis of sovereign equality. Although the subsequent refusal of the United States to comply with the judgment exposed significant weaknesses in the enforcement of international law, the authority of the Court’s reasoning has continued to shape subsequent judicial decisions, academic scholarship, and diplomatic practice.

This paper contends that the enduring significance of the Nicaragua judgment lies in its dual legacy. On one hand, it strengthened international law by clarifying the legal limits on the use of force and reaffirming the independent authority of customary international law. On the other hand, it highlighted the structural tension between legal accountability and political power that continues to affect the effectiveness of international adjudication. The paper proceeds in four further parts: Part 2 sets out the factual background; Part 3 analyses the legal issues before the Court; Part 4 evaluates the judgment critically; and Part 5 concludes, followed by recommendations for strengthening the effectiveness of international law in disputes involving the use of force.

2. FACTUAL BACKGROUND OF THE DISPUTE

The dispute between Nicaragua and the United States cannot be understood without considering the political climate in which it emerged. During the late twentieth century, the Cold War profoundly influenced international relations, often transforming domestic political developments into matters of strategic competition between global powers. The conflict before the International Court of Justice was therefore not merely a disagreement between two States but a legal examination of how international law responds when geopolitical interests intersect with the sovereignty of an independent nation.

Timeline of events

Year	Event
1979	Sandinista Revolution
1981	United States begins support to Contra forces
1984	Nicaragua files ICJ case
1986	ICJ Judgment
Present	Continuing importance

In July 1979, the Sandinista National Liberation Front overthrew the Somoza regime and assumed governmental authority in Nicaragua.⁷ The revolutionary government introduced sweeping political and economic reforms while simultaneously establishing closer diplomatic and military relations with Cuba and the Soviet Union. These developments generated concern within the United States, which viewed the new administration as a potential threat to regional stability and to its broader foreign policy objectives in Central America.

The United States subsequently adopted measures intended to counter the influence of the Sandinista government. Among these measures was substantial support for the Contra movement, an armed opposition group seeking to remove the Sandinista administration from power.⁸ Assistance extended beyond financial aid and included military training, intelligence sharing, logistical support, weapons, and operational planning. At the same time, covert military activities were undertaken against Nicaragua, including the mining of its principal ports and attacks on strategic facilities.⁹

Nicaragua maintained that these actions constituted a deliberate campaign designed to undermine its political independence. It argued that the United States had violated its territorial sovereignty by organising, directing, financing, and supporting armed groups engaged in military operations within Nicaraguan territory. According to Nicaragua, these activities exceeded lawful diplomatic engagement and amounted to unlawful intervention prohibited under international law.

On 9 April 1984, Nicaragua instituted proceedings before the International Court of Justice.¹⁰ It alleged that the United States had breached fundamental principles of international law by using force against a sovereign State, interfering in its internal affairs, violating its territorial integrity, and causing significant economic and humanitarian harm. Nicaragua requested the Court to declare these actions unlawful and to order reparations for the resulting damage.

The United States rejected these allegations and challenged the jurisdiction of the Court.¹¹ It argued that the dispute involved political and security considerations unsuitable for judicial determination. Furthermore, it asserted that its conduct was justified as an exercise of collective self-defence on behalf of El Salvador and other neighbouring States allegedly threatened by Nicaragua’s support for insurgent movements operating across international borders.¹²

Although the United States participated in the proceedings on provisional measures and on jurisdiction and admissibility, it withdrew after the Court’s judgment of 26 November 1984 on those questions, announcing in January 1985 that it would not take part in the merits phase and maintaining that the Court lacked authority to adjudicate the dispute. The ICJ nevertheless continued its examination in accordance with its Statute, emphasising that the absence of one party does not prevent an international tribunal from fulfilling its judicial function. The Court independently evaluated documentary evidence, witness testimony, official statements, and reports before reaching its final judgment.¹³

The factual circumstances presented an unprecedented legal challenge. Unlike conventional interstate warfare involving direct military confrontation, the dispute centred largely upon indirect intervention through financial assistance, military training, intelligence operations, and support for non-state armed groups. This distinction required the Court to determine whether indirect forms of coercion could violate the prohibition on the use of force and the principle of non-intervention. The answer to this question would become one of the most enduring aspects of the judgment.

Beyond its immediate factual context, the dispute represented a broader confrontation between competing conceptions of international order. Nicaragua relied upon the principles of sovereign equality and territorial integrity, whereas the United States emphasised regional security and collective defence. The case therefore required the Court to balance the demands of international security against the foundational legal principles designed to preserve peace among sovereign States. This balance remains one of the central challenges confronting international law today, making the Nicaragua judgment as relevant in the twenty-first century as it was at the time of its delivery.

3. LEGAL ISSUES BEFORE THE COURT AND JUDICIAL ANALYSIS

The dispute before the International Court of Justice extended far beyond the political tensions of the Cold War. At its core, the case required the Court to determine whether the conduct of a State could be justified under international law when national security concerns conflicted with another State’s sovereignty. In resolving this question, the Court addressed a series of interconnected legal issues that continue to shape the interpretation of the United Nations Charter and customary international law.

3.1 Jurisdiction of the International Court of Justice

The first challenge before the Court concerned its competence to hear the dispute. The United States argued that the Court lacked jurisdiction due to reservations attached to its declaration accepting the compulsory jurisdiction of the ICJ under Article 36(2) of the Statute of the Court.¹⁴ It further contended that disputes involving regional security and collective defence were inherently political and therefore more appropriately addressed by the United Nations Security Council than by a judicial body.

Nicaragua rejected this position, maintaining that although the dispute had political consequences, the questions submitted to the Court were fundamentally legal. It argued that allegations concerning unlawful intervention, the use of force, and violations of sovereignty required judicial determination because they involved the interpretation and application of international legal obligations.

The Court accepted Nicaragua’s argument, first in its judgment of 26 November 1984 on jurisdiction and admissibility and again in the merits judgment.¹⁵ It observed that international disputes frequently possess both legal and political dimensions, but the existence of political implications does not deprive a court of its judicial function. To hold otherwise would permit States to avoid legal accountability simply by characterising disputes as political controversies. By affirming its jurisdiction, the Court reinforced the principle that international law remains applicable even in politically sensitive situations. The Court did, however, give effect to one of the United States’ objections: because of the “multilateral treaty reservation” in the United States declaration, it held that the United Nations Charter could not be applied as multilateral treaty law in the case, a limitation that made customary international law central to its reasoning.¹⁶

3.2 The Prohibition on the Use of Force

The principal issue concerned whether the actions of the United States violated the prohibition on the use of force, embodied in Article 2(4)¹⁷ of the Charter of the United Nations and in customary international law.

Nicaragua argued that the mining of its ports, attacks upon its infrastructure, and extensive military assistance provided to the Contra forces collectively constituted unlawful force directed against a sovereign State. According to Nicaragua, these measures were designed to destabilise its government rather than to respond to any lawful security threat.

The United States maintained that its conduct formed part of a broader regional security strategy intended to protect neighbouring States from Nicaraguan interference. It therefore denied that its actions amounted to unlawful aggression.

The Court adopted a careful and principled approach.¹⁸ It concluded that the direct mining of Nicaraguan harbours clearly constituted a prohibited use of force. More significantly, the Court recognised that sustained military support—including the training, organisation, financing, equipping, and operational coordination of armed groups—could also amount to unlawful intervention where it was designed to coerce the target State in matters in which it is entitled to decide freely.¹⁹ The Court was careful, however, to distinguish between forms of assistance: the arming and training of the Contras could be said to involve the use of force, whereas the mere supply of funds, though an act of intervention, did not in itself amount to a use of force.²⁰

This reasoning marked an important development in international law because it acknowledged that modern conflicts are often conducted indirectly²¹ rather than through formal declarations of war.

The Court’s principal findings may be summarised as follows:

Issue	Nicaragua	United States	ICJ Finding
Use of Force	Violation	Denied	Violation
Non-intervention	Violation	Denied	Violation
Collective Self-defence	Rejected	Claimed	Rejected
Customary Law	Applicable	Disputed	Confirmed

3.3 The Principle of Non-Intervention

The Court next examined whether the conduct of the United States violated the customary international law principle of non-intervention.²²

International law recognises that every State possesses the sovereign right to determine its political, economic, and social system without external coercion. This principle protects not merely territorial boundaries but also political independence.

Nicaragua argued that the objective of American support for the Contra movement was to compel political change by weakening the existing government. Such conduct, it claimed, represented unlawful interference in matters exclusively within domestic jurisdiction.

The Court agreed. It held that international law does not permit one State to influence another’s political choices through coercive measures, particularly where military force or organised armed groups are employed. While States remain free to express political disagreement or impose lawful diplomatic measures, they may not resort to armed intervention in order to alter another government’s internal affairs.

The judgment therefore strengthened the legal distinction between legitimate political influence and prohibited coercive intervention, a distinction that remains highly relevant in contemporary international relations.

3.4 Collective Self-Defence under Article 51

Perhaps the most controversial issue before the Court concerned the United States’ reliance upon collective self-defence under Article 51 of the United Nations Charter.²³

The United States argued that Nicaragua had supplied arms and logistical assistance to insurgent groups operating in El Salvador and elsewhere in Central America. According to the United States, these activities justified collective military action undertaken on behalf of neighbouring States.

The Court subjected this argument to close scrutiny. It held that the right of collective self-defence, as recognised in Article 51 and in customary international law, is subject to strict legal conditions before it may be invoked. First, an armed attack must actually occur. Secondly, the victim State must identify itself as the target of that attack. Thirdly, the victim State must request assistance.²⁴

Having examined the evidence, the Court concluded that these requirements had not been satisfied. The evidence did not establish an armed attack attributable to Nicaragua within the meaning of Article 51, nor had the allegedly affected States formally requested collective military intervention.²⁵

By rejecting an expansive interpretation of self-defence, the Court sought to preserve the Charter’s central objective of limiting unilateral recourse to military force. In identifying the threshold of an armed attack, the Court observed that “[t]here appears now to be general agreement on the nature of the acts which can be treated as constituting armed attacks.”²⁶ That category embraces the sending of armed bands into another State’s territory on a significant scale, but not mere assistance to rebels in the form of weapons or logistical support.

3.5 Customary International Law: The Judgment’s Most Enduring Contribution

The most innovative aspect of the judgment concerned the Court’s treatment of customary international law.

Rather than relying on treaty provisions, which the multilateral treaty reservation in any event prevented it from applying, the Court held that fundamental principles such as the prohibition on the use of force and the principle of non-intervention had become rules of customary international law through consistent State practice accompanied by opinio juris.²⁷ Consequently, these obligations continued to bind States independently of treaty commitments.

In my view, this represents the most significant contribution of the Nicaragua judgment. By recognising customary international law as an autonomous source of legal obligation, the Court ensured that essential norms could not be undermined through procedural objections or selective treaty interpretation. The judgment thereby strengthened the stability of the international legal system and reinforced the idea that certain legal principles derive their authority from the collective practice and legal conviction of the international community itself.

4. JUDGMENT OF THE COURT AND CRITICAL EVALUATION

On 27 June 1986, the International Court of Justice delivered its judgment, holding that the United States had violated fundamental principles of international law through its military and paramilitary activities against Nicaragua. By a substantial majority (twelve votes to three on the principal findings), the Court found that the mining of Nicaraguan ports, direct attacks on strategic facilities, and extensive support provided to the Contra forces constituted unlawful intervention and an impermissible use of force. The Court further concluded that these actions infringed Nicaragua’s sovereignty and breached customary international law.²⁸

A notable feature of the judgment was the Court’s insistence that the withdrawal of the United States from the merits phase did not prevent the judicial process from continuing.²⁹ Instead of treating non-participation as an obstacle, the Court independently assessed the available evidence and fulfilled its judicial responsibility. This approach reinforced an important procedural principle: the effectiveness of international adjudication cannot depend solely on the willingness of one party to participate.

The Court also rejected the United States’ claim of collective self-defence.³⁰ It emphasised that the conditions governing the right of self-defence, reflected in Article 51 of the United Nations Charter, are strict and cannot be relaxed on the basis of political necessity. The judgment clarified that an armed attack must be established by convincing evidence and that the State invoking collective self-defence must act at the request of the State allegedly subjected to that attack. Since these conditions were not satisfied, the Court concluded that the use of force could not be justified under international law.

The judgment further recognised Nicaragua’s entitlement to reparations³¹ for the injuries suffered as a consequence of the unlawful conduct. Although the Court affirmed this legal right, effective enforcement never followed. The refusal of the United States to comply with the judgment and the political realities within the United Nations Security Council demonstrated that judicial recognition of legal rights does not automatically guarantee practical remedies.

This outcome has generated considerable scholarly debate. Some commentators argue that the inability to enforce the judgment weakened the authority of international law by illustrating the limits of judicial power. Others maintain that the decision achieved something more enduring than immediate compliance: it clarified legal principles that have guided States, international organisations, and courts ever since. In this sense, the authority of the judgment lies less in its enforcement and more in its contribution to the development of international legal doctrine.

From a critical perspective, one of the Court’s greatest strengths was its refusal to permit political considerations to influence legal reasoning. The judgment reaffirmed that all States, regardless of their military or economic power, remain subject to the same legal standards. This commitment to equality before international law strengthened the legitimacy of the Court and reinforced confidence in judicial independence.

At the same time, the case exposed an important structural weakness in the international legal order. International courts possess the authority to determine legal responsibility but rely heavily on State cooperation for implementation. Where politically influential States decline to comply, judicial decisions may have limited immediate practical effect. This tension between legal authority and political reality continues to challenge the effectiveness of international dispute settlement.

Another aspect deserving closer attention is the Court’s treatment of indirect intervention. The judgment successfully established that organising, training, financing, and directing armed groups may violate international law. However, beyond holding that the acts of the Contras could be attributed to the United States only if it exercised “effective control” over the operations concerned,³² it offered limited guidance regarding the degree of involvement required before a State becomes legally responsible. This uncertainty has become increasingly significant in the twenty-first century, where conflicts frequently involve cyber operations,³³ private military contractors, intelligence support, and autonomous technologies rather than conventional armed forces.

In my view, this represents both the strength and the limitation of the Nicaragua judgment. The Court developed enduring legal principles while leaving sufficient flexibility for future interpretation. Such flexibility has enabled the judgment to remain relevant across changing forms of conflict, but it has also created uncertainty in situations where indirect forms of intervention fall short of traditional military action. Future international jurisprudence will need to refine these principles without undermining the balance carefully established by the Court.

The continued relevance of the judgment is evident in contemporary international relations. Questions concerning proxy warfare, cross-border support for armed groups, cyber operations, and the scope of self-defence³⁴ continue to dominate legal and diplomatic debates. Although technology has transformed the methods through which States exert influence, the principles affirmed in Nicaragua—sovereign equality, non-intervention, and the prohibition on the use of force—remain the essential legal framework through which such conduct is evaluated. This enduring applicability explains why the judgment continues to occupy a central position in international legal scholarship four decades after it was delivered.

5. CONCLUSION

The decision in Military and Paramilitary Activities in and against Nicaragua (Nicaragua v United States of America) remains one of the most influential judgments in the history of international law because it reaffirmed that the exercise of State power must remain subject to legal restraint. By clarifying the principles governing the prohibition on the use of force, non-intervention, collective self-defence, and customary international law, the International Court of Justice strengthened the normative foundations upon which contemporary international relations continue to operate.

Beyond resolving a dispute between two States, the judgment established an enduring legal framework for assessing the legality of indirect military intervention. It demonstrated that international responsibility cannot be avoided merely because force is exercised through proxy actors rather than regular armed forces. This principle has acquired even greater significance in an era where cyber operations, private military contractors, and transnational armed groups increasingly shape international conflicts.

However, the judgment also revealed a persistent weakness within the international legal system. The inability to secure effective compliance despite a clear judicial determination illustrates the continuing gap between legal authority and political power. This tension does not diminish the value of the Court’s reasoning; rather, it highlights the need for stronger institutional mechanisms capable of supporting the implementation of international judgments.

In my assessment, the most enduring contribution of the Nicaragua judgment is not simply its treatment of the rules reflected in Article 2(4)³⁵ and Article 51³⁶ of the United Nations Charter. Its greatest achievement lies in reaffirming that international law derives legitimacy from the consistent application of legal principles rather than the political influence of individual States. The judgment challenged the perception that international law is merely aspirational by demonstrating that even the conduct of powerful States can be subjected to objective judicial scrutiny.

At the same time, the case reminds us that the future credibility of international law will depend not only upon sound judicial reasoning but also upon genuine commitment by States to respect the rule of law. Judicial decisions establish standards; it is international cooperation that gives those standards practical effect.

Ultimately, the Nicaragua judgment continues to serve as a cornerstone of international jurisprudence because it represents both the promise and the limitations of the international legal order. Its legal principles remain indispensable to resolving contemporary disputes, while its enforcement challenges continue to inspire debate concerning institutional reform. For scholars, practitioners, and policymakers alike, the case stands as a lasting reminder that the pursuit of international peace requires not only political dialogue but also unwavering respect for universally accepted legal norms.

RECOMMENDATIONS

To strengthen the effectiveness of international law in disputes involving the use of force, the following measures deserve consideration:

1. Strengthening Compliance Mechanisms: States should develop more effective mechanisms for implementing judgments of the International Court of Justice to enhance respect for judicial decisions.
2. Clarifying the Law on Indirect Intervention: International law should provide more detailed guidance on cyber operations, private military companies, and other modern forms of indirect intervention that were not fully addressed in 1986.
3. Limiting Political Obstacles to Enforcement: Greater cooperation between the United Nations and the International Court of Justice would improve the practical implementation of judgments without compromising judicial independence.
4. Promoting Preventive Diplomacy: Peaceful dispute resolution through mediation, negotiation, and judicial settlement should be encouraged before States resort to unilateral military action.
5. Enhancing Legal Education: Universities and international institutions should encourage greater awareness of landmark ICJ judgments, as they continue to shape contemporary international legal practice.

FOOTNOTE(S):

¹ SS ‘Lotus’ (France v Turkey) (Judgment) [1927] PCIJ Series A No 10, 18.

² Military and Paramilitary Activities in and against Nicaragua (Nicaragua v United States of America) (Merits) [1986] ICJ Rep 14 (Nicaragua). The judgment is available on the ICJ case page for Nicaragua v United States of America.

³ Nicaragua (n 2) paras 20–23, 75–86.

⁴ Charter of the United Nations (adopted 26 June 1945, entered into force 24 October 1945) 1 UNTS XVI (UN Charter) art 2(4).

⁵ UN Charter (n 4) art 51.

⁶ Malcolm N Shaw, International Law (9th edn, Cambridge University Press 2021).

⁷ Nicaragua (n 2) para 18; James Crawford, Brownlie’s Principles of Public International Law (9th edn, Oxford University Press 2019).

⁸ Nicaragua (n 2) paras 75–125.

⁹ ibid paras 80–86.

¹⁰ ibid para 1.

¹¹ Statute of the International Court of Justice (adopted 26 June 1945, entered into force 24 October 1945) 33 UNTS 993 (ICJ Statute) art 36(2); Nicaragua (n 2) paras 32–56.

¹² Nicaragua (n 2) paras 24, 48.

¹³ ibid paras 10, 26–31, 57–74.

¹⁴ ICJ Statute (n 11) art 36(2).

¹⁵ Military and Paramilitary Activities in and against Nicaragua (Nicaragua v United States of America) (Jurisdiction and Admissibility) [1984] ICJ Rep 392; Nicaragua (n 2) paras 32–35.

¹⁶ Nicaragua (n 2) paras 42–56, 292(1).

¹⁷ UN Charter (n 4) art 2(4).

¹⁸ Nicaragua (n 2) paras 187–191, 227.

¹⁹ ibid paras 205, 239–245.

²⁰ ibid para 228.

²¹ ibid paras 195, 205.

²² ibid paras 202–209, 239–245.

²³ UN Charter (n 4) art 51.

²⁴ Nicaragua (n 2) paras 195, 199.

²⁵ ibid paras 230–238.

²⁶ ibid paras 195, 230.

²⁷ Antonio Cassese, International Law (2nd edn, Oxford University Press 2005) 154–160; Nicaragua (n 2) paras 172–186.

²⁸ Nicaragua (n 2) para 292.

²⁹ ibid paras 27–31.

³⁰ ibid paras 195–199, 227–238, 292(2).

³¹ ibid para 292(13)–(15).

³² ibid para 115.

³³ Michael N Schmitt (gen ed), Tallinn Manual 2.0 on the International Law Applicable to Cyber Operations (2nd edn, Cambridge University Press 2017).

³⁴ Michael J Glennon, ‘The Fog of Law: Self-Defence, Inherence and Incoherence in Article 51 of the United Nations Charter’ (2002) 25 Harvard Journal of Law & Public Policy 539.

³⁵ UN Charter (n 4) art 2(4).

³⁶ UN Charter (n 4) art 51.

OSCOLA BIBLIOGRAPHY

Primary Sources

1. Charter of the United Nations (adopted 26 June 1945, entered into force 24 October 1945) 1 UNTS XVI.
2. Statute of the International Court of Justice (adopted 26 June 1945, entered into force 24 October 1945) 33 UNTS 993.
3. Military and Paramilitary Activities in and against Nicaragua (Nicaragua v United States of America) (Jurisdiction and Admissibility) [1984] ICJ Rep 392.
4. Military and Paramilitary Activities in and against Nicaragua (Nicaragua v United States of America) (Merits) [1986] ICJ Rep 14.
5. SS ‘Lotus’ (France v Turkey) (Judgment) [1927] PCIJ Series A No 10.

Books

1. Cassese A, International Law (2nd edn, Oxford University Press 2005).
2. Crawford J, Brownlie’s Principles of Public International Law (9th edn, Oxford University Press 2019).
3. Gray C, International Law and the Use of Force (4th edn, Oxford University Press 2018).
4. Ruys T, ‘Armed Attack’ and Article 51 of the UN Charter: Evolutions in Customary Law and Practice (Cambridge University Press 2010).
5. Schmitt MN (gen ed), Tallinn Manual 2.0 on the International Law Applicable to Cyber Operations (2nd edn, Cambridge University Press 2017).
6. Shaw MN, International Law (9th edn, Cambridge University Press 2021).

Journal Articles

1. Glennon MJ, ‘The Fog of Law: Self-Defence, Inherence and Incoherence in Article 51 of the United Nations Charter’ (2002) 25 Harvard Journal of Law & Public Policy 539.
2. Schachter O, ‘The Right of States to Use Armed Force’ (1984) 82 Michigan Law Review 1620.