COSTA RICA-PANAMA ARBITRATION

ANSWER OF COSTA RICA

TO THE ARGUMENT OF PANAMA

BEFORE THE

ARBITRATOR

HON. EDWARD DOUGLASS WHITE

CHIEF JUSTICE OF THE UNITED STATES

UNDER THE

PROVISIONS OF THE CONVENTION BETWEEN THE REPUBLIC OF COSTA RICA
AND THE REPUBLIC OF PANAMA, CONCLUDED MARCH 17, 1910.

WASHINGTON, D. C.

PRESS OF GIBSON BROTHERS, INC,

1914

彩美

JAN 11 1915

TABLE OF CONTENTS

(i)

ARGUMENT FOR COSTA RICA IN REPLY.

I.

IN ORDER TO DECIDE THE QUESTION SUBMITTED TO ARBI-
TRATION, THE TERMS OF SUBMISSION REQUIRE AN
EXAMINATION INTO THE MERITS OF THE CONTRO-
VERSY WHICH RESULTED IN THE LOUBET AWARD, IN
ACCORDANCE WITH WHICH THE CORRECT INTER-
PRETATION AND TRUE INTENTION OF THAT AWARD
MUST BE DETERMINED...

II.

III

UNDER THE TERMS OF SUBMISSION THE PRESENT ARBI-
TRATOR IS AT LIBERTY TO INTERPRET THE LOUBET
AWARD IN ANY WAY NECESSARY TO FIX THE
BOUNDARY IN ACCORDANCE WITH THE MERITS OF
THE ORIGINAL CONTROVERSY SUBMITTED TO PRESI-
dent LoubeT, DISREGARDING ANY COMPLICATIONS
DUE TO IMPERFECTIONS IN THAT AWARD.

III.

THE AWARD LINE IS DEFECTIVE AND REQUIRES REFOR-
MATION BECAUSE OF ITS UNCERTAINTY AND AM-
BIGUITY, BECAUSE IT INVADES UNDISPUTED TERRI-
TORIES OF COSTA RICA, AND BECAUSE IT IS NOT
JUSTIFIED BY THE OTHER FACTS, CIRCUMSTANCES
AND CONSIDERATIONS WHICH ARE REQUIRED TO BE
TAKEN INTO ACCOUNT IN DECIDING THE QUESTION
SUBMITTED...

Uncertainty and Ambiguity of the Award.

The Merits of the Boundary Question....
Extent of the former Arbitrator's Jurisdiction.

XIII

XVII

XVIII

XXV

XXXII