The International Court of Justice (ICJ) delivered its judgment in the Case Concerning Mutual Assistance in Criminal Matters on 4 June 2008. This case is one of the few to have been decided by the Court on the basis of forum prorogatum whereby the jurisdiction of the Court is founded on the conduct of the respondent state in relation to a unilateral application by another state. In this case, Djibouti made an application to the Court on 9 January 2006 in respect of a dispute concerning the refusal of the French authorities to transfer documents relating to a criminal investigation…
