The Rainbow Warrior Case (1990)
France-New Zealand Arbitration Tribunal
82 International Law Reports 500 (1990)
Following the 1986 Secretary-General ruling requiring two French officers responsible for sinking the Rainbow Warrior to serve three years on the isolated French Polynesian island of Hao, with disputes to go to arbitration, France removed one officer for pregnancy and another for serious illness before the three-year term ended and without New Zealand's consent, and never returned the recovered officer to Hao. New Zealand unilaterally initiated arbitration seeking their return.
Whether an international arbitration tribunal resolving a dispute under a bilateral agreement applies customary international law to determine excuses for nonperformance and available remedies.