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Q24.

Q7. (b) Discuss the right of the State parties to formulate reservations to a treaty under the Vienna Convention on the Law of Treaties, 1969. What are the legal effects of such reservations? Explain.

How to Approach

Begin by defining treaty reservations and their significance under international law. Structure the answer by first discussing the conditions and limitations for formulating reservations as stipulated in the Vienna Convention on the Law of Treaties (VCLT), 1969 (Article 19). Subsequently, elaborate on the procedural aspects (Article 20) and detail the diverse legal effects reservations and objections have on treaty relations between State parties (Article 21). Conclude by summarizing the VCLT's balancing act between state participation and treaty integrity.

Model Answer

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Introduction

Treaty reservations represent a crucial mechanism in modern international law, allowing States to consent to be bound by a treaty while excluding or modifying the legal effect of certain provisions in their application to that State. The Vienna Convention on the Law of Treaties (VCLT), 1969, codifies the customary international law on this subject, providing a framework that seeks to balance the desire for universal participation in multilateral treaties with the need to preserve the integrity of the treaty's object and purpose. This answer will delve into the conditions under which State parties can formulate reservations according to the VCLT and analyze the significant legal consequences that follow the formulation of reservations and subsequent objections by other parties.

The VCLT, 1969, extensively regulates the formulation and effect of reservations, aiming to provide clarity and predictability in treaty relations. The right to formulate reservations is not absolute and is subject to specific conditions.

Conditions for Formulating Reservations

Article 19 of the VCLT lays down the fundamental principles governing the admissibility of reservations:

  • General Rule: A State may formulate a reservation when signing, ratifying, accepting, approving or acceding to a treaty unless:
    • The reservation is prohibited by the treaty;
    • The treaty provides that only specific reservations, which do not include the reservation in question, may be made; or
    • The reservation is incompatible with the object and purpose of the treaty.
  • Prohibition: Treaties may explicitly prohibit all reservations or only certain types, thereby limiting the scope for modification.
  • Object and Purpose Test: This is the most significant, albeit sometimes ambiguous, criterion. A reservation is considered incompatible if it defeats the essential elements or fundamental provisions of the treaty, thereby undermining its core objectives. Determining compatibility often requires careful legal analysis and can be contentious.

Procedure and Acceptance/Objection

The VCLT outlines the procedural aspects concerning the reaction of other State parties to a reservation:

  • Acceptance: A reservation requires acceptance by all other parties if it appears from the object and purpose of the treaty that the application of the treaty in its entirety as between the parties is an essential condition of the consent of each to be bound (Article 20(2)). This is rare and typically applies to treaties where state consent hinges on the treaty applying fully to all.
  • Objection: For most multilateral treaties, a reservation does not require express acceptance. It only needs to be communicated to the contracting States and contracting Organizations. If a State makes an objection, it must be formulated within twelve months of notification of the reservation or by the date on which it expressed its consent to be bound, whichever is later (Article 20(5)).
  • Presumption of Acceptance: If a State does not raise an objection to a reservation within the twelve-month period, the reservation is presumed to be accepted.
  • Constituent Instrument: Reservations to the constituent instrument of an international organization require acceptance by the competent organ of that organization (Article 20(3)).

Legal Effects of Reservations and Objections

Reservations and objections fundamentally alter the treaty's application between the parties involved. Article 21 of the VCLT details these effects:

  • Effect of a Reservation: A reservation modifies the provisions of the treaty to which it relates in the international relations between the reserving State and the parties which have accepted it or have not raised an objection. It does not modify the treaty obligations for the other parties inter se.
  • Effect of an Objection:
    • Simple Objection: If a State has raised a simple objection (i.e., without specifying the contrary intention), the treaty enters into force between the objecting State and the reserving State, but the provisions to which the reservation relates do not apply between them to the extent of the reservation.
    • Objection Precluding Treaty Entry into Force: If a State has expressed a clear intention that the reservation precludes it from becoming a party to the treaty, the treaty does not enter into force between the objecting State and the reserving State (Article 20(4)(b)).
  • Treaty Relations between Non-Reserving States: The VCLT clarifies that a reservation does not affect the treaty provisions relating to the performance of the treaty as between the parties themselves (Article 21(3)).
  • Withdrawal: Reservations and objections can be withdrawn at any time (Article 22 VCLT). Withdrawal takes effect when notice is received by the other parties.

Illustrative Table of Effects

Scenario Reserving State (RS) vs. Accepting State (AS) Reserving State (RS) vs. Objecting State (OS) (Simple Objection) Reserving State (RS) vs. Objecting State (OS) (Objection Precluding Entry into Force) Non-Reserving State (NRS) vs. Non-Reserving State (NRS)
Treaty Entry into Force Treaty in force (modified) Treaty in force (modified regarding RS) Treaty NOT in force Treaty in force (standard)
Obligations Regarding Reserved Provision Modified as per reservation Does not apply between RS and OS N/A (Treaty not in force) Applies fully

The VCLT framework, while comprehensive, faces challenges in practice, particularly concerning the "object and purpose" test, which can lead to disputes. The International Court of Justice (ICJ) has played a significant role in interpreting these provisions, notably in its advisory opinions.

Conclusion

The Vienna Convention on the Law of Treaties, 1969, provides a structured framework for State parties to formulate reservations, balancing the need for widespread treaty adherence with the imperative of maintaining treaty integrity. Reservations are permissible unless expressly forbidden or incompatible with the treaty's core objectives. The VCLT details the procedures for acceptance and objection, clarifying that objections do not automatically prevent treaty entry into force unless explicitly stated. Ultimately, reservations modify treaty obligations solely between the reserving State and the accepting or non-objecting States, thereby shaping specific treaty relationships without disrupting the overall framework for other parties. This nuanced approach remains central to the functioning of international treaty law.

Answer Length

This is a comprehensive model answer for learning purposes and may exceed the word limit. In the exam, always adhere to the prescribed word count.

Additional Resources

Key Definitions

Reservation (VCLT definition)
"[...] a unilateral statement, however phrased or named, made by a State, when signing, ratifying, accepting, approving or acceding to a treaty, whereby it proposes to exclude or to modify the legal effect of certain provisions of the treaty in their application to that State." (Article 2(1)(d), VCLT, 1969)
Object and Purpose Test
A criterion used under Article 19(c) of the VCLT to determine the validity of a reservation. A reservation is invalid if it is incompatible with the fundamental goals and essential provisions of the treaty. Its application requires interpreting the treaty's core objectives and determining if the reservation undermines them.

Key Statistics

As of early 2024, the Vienna Convention on the Law of Treaties, 1969, has 116 State parties. Its principles are widely considered reflective of customary international law, making them applicable even to non-parties in many respects.

The UN Treaty Collection database lists hundreds of thousands of treaty actions, including a significant number of reservations, declarations, and objections. For instance, the Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW) has numerous reservations, particularly concerning family law and religious interpretations, highlighting the tension between universality and specific state concerns.</SOURCE>UN Treaty Collection Database</SOURCE>

Examples

Invalid Reservation Example

Reservations made by several states to the Convention on the Prevention and Punishment of the Crime of Genocide, 1948, regarding Article IX (disputes submitted to ICJ). The ICJ, in its 1951 Advisory Opinion, stated that reservations incompatible with the object and purpose of the Convention are impermissible, even if not explicitly prohibited by the treaty itself.

Reservation Accepted Widely

The United Nations Convention on the Law of the Sea (UNCLOS), 1982, allows for certain reservations and declarations. Many States have made declarations clarifying aspects of their participation, which are generally accepted, facilitating broad ratification of this complex convention.

Frequently Asked Questions

Can reservations be made to bilateral treaties?

Generally, reservations are not applicable to bilateral treaties. A reservation is a unilateral statement intended to modify the effect of treaty provisions in relation to multiple parties. For a bilateral treaty, if a State wishes to exclude or modify a provision, it typically does so through negotiation, resulting in a different treaty text or specific clauses agreed upon by both parties, rather than a formal reservation.

Topics Covered

International LawTreaty LawTreatiesReservationsVienna Convention