Treaties & Conventions

Eritrea - Yemen Arbitration

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AWARD
Phase I: Territorial Sovereignty and Scope of Dispute

CHAPTER VIII - Maps

362. Finally, maps must be considered. It appears to the Tribunal that maps are used by the Parties at different times for different purposes, and that they have relevance to the dispute in several different ways.

Use of Maps by the Parties

363. Older maps, from the eighteenth and early nineteenth centuries, are adduced by Yemen in support of its thesis that the Islands once belonged to Yemen and that Yemen therefore possesses an ancient title which should cause sovereignty in the Islands to revert to it following termination of the Article 16 suspension under the Treaty of Lausanne. Similarly, maps subsequent to 1872 and earlier than 1918 are adduced by Yemen to show that the Islands fell under Ottoman sovereignty during the period in question and fell within the vilayet of Yemen. Eritrea then asserts that maps from the early twentieth century through the late 1930s show that Italy claimed to be, or was received as being, the sovereign over the Islands.

364. Both Eritrea and Yemen have introduced maps produced by third parties in order to demonstrate that informed opinion recognized the Islands as respectively forming part of Ethiopia, or of Yemen, during the period from the early 1950s to the early 1990s.

365. Yemen has introduced maps from the period of the early 1950s to demonstrate that the United Nations considered the Islands not to be part of the Province of Eritrea (within Ethiopia). Both Parties have introduced maps from the period of the 1960s onwards, from a variety of sources, respectively indicating that Yemen treated the Islands as non-Yemeni and that Ethiopia treated them as non-Ethiopian - and that third parties and authoritative sources considered them respectively to be one or the other.

366. Finally, Yemen has introduced evidence showing that Ethiopia, the Eritrean liberation movement before independence, and the Eritrean Government after independence have not considered the Islands to be Ethiopian or Eritrean - but rather Yemeni. Eritrea has introduced evidence to show that Yemen has attributed the Islands to Ethiopia or to Eritrea. Each side has also accused the other of waging a deliberate "maps" campaign - from the early 1970s on the part of Yemen to the early 1990s on the part of Eritrea - to alter the designations, labels, and colours on maps so as to "claim" the Islands as a part of the other's territory.

367. In general however the positions of the Parties emerged as quite different overall in the usefulness they attributed to maps. Even whilst seeking to make the points just enumerated, Eritrea's essential position was that map evidence in general (and the evidence in this case in particular) was contradictory and unreliable and could not be used to establish serious legal positions.

368. Yemen's position was diametrically different; it sought to justify its use of maps in the case for at least four reasons: as "important evidence of general opinion or repute" (in the words of Sir Gerald Fitzmaurice, cited in the oral hearings); as evidence of the attitudes of governments; to reveal the intention of the Parties in respect of state actions; and as evidence of acquiescence or admissions against interest.

The Purposes Claimed to be Served by Maps in the Case

Pre-1872

369. Older maps, from the eighteenth and early nineteenth centuries, are adduced by Yemen in support of its thesis of an ancient or historic title. Most of the maps clearly show the Zuqar-Hanish group and the northern islands as identifiable with the Arabian rather than with the African side of the Red Sea. The Tribunal is not able to judge the extent of the precise territory of the Kingdom of Yemen (Bilad el-Yemen). Moreover, in these older maps there is no attribution of the territory of the Islands to Yemen, as such.

370. It appears not unreasonable to infer from the map evidence that rulers (including in particular the Imam of Yemen) of Southern Arabia before the 1872 Ottoman conquest probably did perceive that the Islands fell within their territorial claim as part of Yemen or of the Arabian coast. However this impression must be qualified by the fact that it is not possible to evaluate the colour of maps produced during periods when hand-colouring had to be applied to maps at a second stage. These factors are therefore not determinative with regard to the issue of reversionary historic title. Moreover, there is no evidence that Southern Arabian rulers themselves ever saw or authorized these maps. Conclusions based on this material would be tenuous at best.

1872-1918 Period

371. Similarly, maps subsequent to 1872 and earlier than 1918 are adduced by Yemen to show that the Islands fell under Ottoman sovereignty during the period in question and fell within the vilayet of Yemen and were administered as part of that vilayet. The map evidence appears to confirm the fact that the Ottoman Empire was sovereign over the Islands, upon which fact the Parties are in agreement.

Period Between 1924 and 1939

372. Yemen has introduced a number of maps that appear to prove that Italy in the inter-war period did not officially consider itself as sovereign over the Islands. These maps were produced by the Ministry of Colonies in 1933, 1935, and 1937 and by the Ministry of Italian Africa in 1939, and they show that the Italian colonial authorities did not consider at the time that the Islands formed part of the Italian Colony of Eritrea. Yemen has also submitted other official Italian maps from the Ministry of Colonies (c. 1925 and 1933) and the Ministry of Italian Africa (1939) of which the first two attribute the Islands clearly to Yemen as opposed to the Province of Eritrea, and the third merely omits them from territory of Italian East Africa.

373. Eritrea has introduced an official Italian map of the 1920s to a contrary purpose. It is however hard to discern and appears to be done by hand. Weighed against the evidence submitted by Yemen in terms of official Italian maps of the period, it is not as clear as the Ministry of Colonies' 1933 and 1935 Maps. Nor is its date specified.

374. To the extent that these may be viewed as admissions against interest from official Italian sources, which are not controverted by Eritrean evidence, they have relevance to the Eritrean claim that Italy considered herself sovereign over the Islands at the outbreak of the Second World War. The best interpretation of this evidence appears to be that official Italian cartography did not wish formally to portray the Islands as being under Italian sovereignty in the inter-war period - and even went so far as to assign the Islands to Yemen. On balance, the evidence seems to establish that Italy, in the interbellum period, did not consider the Islands to be under Italian sovereignty or at least does not establish that Italy in that period did consider the Islands to be under Italian sovereignty.

375. However, since the Tribunal has arrived at its legal conclusions about the status of the Islands on the basis of the diplomatic record and agreements entered into between 1923 and 1939, the map evidence - whilst supportive of and consistent with the conclusions reached - is not itself determinative. Were there no other evidence in the record concerning the attitude or intentions of Italy, this evidence would be of greater importance.

United Nations Treatment in 1950

376. Yemen has introduced maps from the period of the early 1950s to demonstrate that the United Nations considered the Islands not to be part of the Province of Eritrea (within Ethiopia). The key evidence here is a United Nations Map of 1950. Eritrea has vigorously contested the accuracy of this map, its provenance, authenticity and effect, saying that "[n]o official map was adopted by the United Nations".

377. It is well accepted that, in the United Nations practice, its publication of a map does not constitute a recognition of sovereign title to territory by the United Nations.

378. Whether the map was attached to the report of the United Nations Commission for Eritrea as an official commission map, or as a compromise - or even as a merely illustrative map - seems to be beside the point. What it bears witness to is that it was used and circulated - and received no objection. No protest was recorded in 1950 or at any later time, and Ethiopia itself voted in favour of the report with full knowledge of the map.

379. The map however cannot affirmatively prove that the Islands were Yemeni, even if they bear the same colour as Yemen. In this instance, the United Nations was not concerned with Yemen. The map did not in fact concern Yemen as such. What it shows is that the United Nations when it acted on the future of Ethiopia and Eritrea did not consider the Islands to be Ethiopian or Eritrean. As already mentioned in connection with the Italian map evidence of the 1920s and 1930s, since the Tribunal has reached the conclusion that Italy had not acquired sovereignty over the Islands by 1940, it could not then reach the conclusion that Ethiopia (and thus Eritrea by derivation) could have acquired title ten years later by inheritance from Italy.

Informed Opinion

380. Both Eritrea and Yemen have introduced a number of maps produced by third parties (such as independent or commercial cartographic sources, or the intelligence, mapping and navigational authorities of third states) in order to demonstrate that informed opinion recognized the Islands as respectively forming part of Ethiopia, or of Yemen, during the period from the early 1950s to the early 1990s.

381. Although the Tribunal must be wary of this evidence in the sense that it cannot be used as indicative of legal title, it is nonetheless "important evidence of general opinion or repute" in the sense advanced by Yemen. But while a considerable number of the maps submitted appear in general to confirm an impression that the Islands, from and after 1952 to the present day, are mainly attributed to Yemen, and not to Ethiopia or Eritrea, there are noteworthy exceptions.

382. Although Eritrea, on its part, has introduced some respectable independent cartographic evidence, this evidence appears to be somewhat outweighed by the contrary evidence from the other side. In some instances the Tribunal cannot agree with the characterization of the maps sought by the Party introducing it. Moreover, the Tribunal is unwilling, without specific direction from the map itself, to attribute meaning to dotted lines rather than to colouration or to labelling. The conclusions on this basis urged by Eritrea in relation to a number of its maps are not accepted.

383. There are also Central Intelligence Agency maps introduced by Yemen and the corroborative labelling in the U.S. Defence Department Mapping Agency charts of 1994.

Admissions Against Interest

384. In 1967, the United States Department of State distributed a press package on the occasion of a state visit by Emperor Haile Selassie to Washington together with "Background Notes" that included a map that very clearly showed the Islands as not being Ethiopian. They are clearly shown in black, just as are Kamaran and the Farasan islands; the Dahlaks are also clearly shown in white, as part of Ethiopia.

385. Yemen has introduced evidence showing that Ethiopia, the Eritrean liberation movement before independence, and the Eritrean Government after independence have not considered the Islands to be Ethiopian or Eritrean - but rather Yemeni. Eritrea has also introduced evidence to show that Yemen has itself attributed the Islands to Ethiopia or to Eritrea. The Tribunal is of the view that most of this evidence tends to cancel itself out, except possibly for the Eritrean maps published after 1992.

386. Yemen further contended that a particular map, asserted by Eritrea to have been produced for the Eritrean Ministry of Tourism by a private firm and to contain a number of inaccuracies, had in fact been distributed to foreign missions, including those of Yemen and the United States, and that it also "hung in Eritrean Government offices in Asmara." This statement was not controverted. The Tribunal notes that an early map produced by Eritrea after it became independent did not attribute to Eritrea all of the islands that it now claims.

387. On its part, Eritrea asserts as well that Yemen has authorized the production of maps that can be interpreted against its interest, including a map published in 1975 which clearly appears to ascribe the Islands to Ethiopia.

Conclusions as to Maps

388. On balance, the Tribunal has reached the following conclusions:

As to the period prior to 1872

Although Yemen has shown in general that most ancient and nineteenth-century maps attributed the Islands to the Arabian sphere of influence rather than to the African coast, the precise attribution of the Islands to "Yemen" has not been demonstrated.

For the period from 1872-1918

The maps produced by each side demonstrate without difficulty that the Islands were under Ottoman domination during the last years of the Empire's existence. There is no evidence in the record, nor was there any discussion in the case, about the effect of this widespread recognition on the validity vel non of the asserted Yemeni claim to a reversionary interest.

For the period between the Wars

The map evidence is to some extent contradictory, but by and large the official Italian maps of the time demonstrate that even if Italy harboured a desire to annex the Islands after the Treaty of Lausanne, it certainly did not accompany this desire with any outward manifestation of state authority in its official cartography.

For the post-war period

It is not possible to conclude from the history of the 1950 United Nations maps that Ethiopia acquired the Islands after the Second World War, from Italy or otherwise.

For the period between 1950 and 1992

The evidence for this period is beset with contradictions and uncertainties. Each Party has demonstrated inconsistency in its official maps. The general trend is, however, that Yemeni map evidence is superior in scope and volume to that of Eritrea. However, such weight as can be attached to map evidence in favour of one Party is balanced by the fact that each Party has published maps that appear to run counter to its assertions in these proceedings.

For the period from 1992 to 1995

Finally, evidence is in the record showing broadly-publicized official and semi-official Eritrean cartography shortly after independence which shows the Islands as non-Eritrean if not Yemeni. The evidence is, as in all cases of maps, to be handled with great delicacy.

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