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The parties' heads of state apparently also met in the presence of the UN Secretary-General regarding thecase on September 5, 2002, exactly five weeks prior to the delivery of theJudgment. Remarkably, this meeting isnot referred to in theJudgment itself, but only in President Guillaume's Statement to the Press on the day thattheJudgmentwas delivered. (The opening paragraph ofJudge Ranjeva's separate opinion does refer to the meeting.)This situation differs markedly from the approach followed by the Court's chamber in the 1986 FrontierDisputecase. In addition to noting with satisfaction that the heads of state of Burkina Faso and Mali had agreed in a communique"to withdraw all their armed forces from either side of the disputed area and to effect their return to theirrespective territories," the chamber stated that it was "happy to record the adherence of both Parties to the internationaljudicial process and to the peaceful settlement of disputes." Frontier Dispute (Burk. Faso/Mali), 1986ICJ REP. 554, para. 178 (Dec. 22). As Nigeria's post-judgment remarks make clear, it would have been helpful ifthe Court had included at least the latter statement in itsJudgment.60Judgment, supra note 5, para. 316.61 Id., paras. 317, 325(V) (C).1Sovereignty over Pulau Ligitan and Pulau Sipadan (Indon./Malay.) (Int'l Ct.Justice Dec. 17, 2002) [hereinafterJudgment].The decisions, pleadings, and basic documents of the International Court ofJustice are availableonline at . On March 13, 2001, the Philippines filed an application for permission to intervene.The Philippine application concerned historical claims that it maintains in North Borneo. By ajudgmentof October 23, 2001, the Court denied the application.398 [Vol. 97This
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