442 Between Yesterday and Tomorrow (1914– )were parties. Th e Court again ordered the release of the hostages and also
held Iran liable to pay damages to the United States (with the amount to be
fi xed later). Th e Tehran Hostages case was, however, hardly a great demon-
stration of the practical effi cacy of the Court, since the Ira ni an government
made no eff ort to comply with its rulings. Resolution of the crisis had to
await the reaching of a bilateral settlement in January 1981. But the aff air
did succeed in bringing the Court to the world’s attention as never before.
Th e Tehran Hostages case was only the fi rst of a growing number of forays
by the World Court into high- profi le political— and military— situations.
On two occasions (up to 2012), there were fi ndings by the Court that states
had violated the fundamental duty to refrain from the use of armed force.
Th e fi rst of these was brought in 1984, by Nicaragua against the United
States, regarding American government support for the contra insurgents.
In its judgment in 1986, the Court sustained these claims. Some of Ameri-
can activities, such as the mining of harbors and attacking of ships, clearly
constituted uses of armed force. But the Court went on to hold that various
ancillary activities fell into that category as well— including the training of
insurgents and the supply of weaponry and intelligence. Th e American
government, disputing the jurisdiction of the Court over the case, declined
to participate in the proceedings. (A later pro– United States government of
Nicaragua discontinued the proceedings before the Court was able to assess
damages owed.)
Th e second ruling on the use of armed force arose out of the wars in the
Congo in the 1990s, when a claim was brought by the Congo against Uganda.
In 2005, Uganda was held to have intervened unlawfully and thereby to have
violated the UN Charter’s prohibition against the use of force. It was exon-
erated, however, of responsibility for atrocities committed by in de pen dent
warlord groups. Th e Congo government sought to pursue similar claims
against Rwanda, but that country’s absence of consent to jurisdiction pre-
vented the Court from acting.
In 1994, the World Court was given the opportunity to clarify an impor-
tant component of the law relating to the conduct of armed confl ict, when
the UN General Assembly sought an advisory opinion on the lawfulness of
the threat or use of nuclear weapons. In 1996, the Court gave its opinion,
which largely endorsed the position of the nuclear powers: that there is no
rule of international law prohibiting the use of nuclear weapons per se, but