Rainbow Warrior (New Zealand v. France)
France-New Zealand Arbitration Tribunal
82 I.L.R. 500, 551-64 (1990)
After French agents (defendant) bombed the Greenpeace ship Rainbow Warrior in New Zealand (plaintiff) waters, the two nations agreed via binding arbitration and a formalized 1986 Agreement that two captured French agents would remain confined to a French military facility for three years, removable only with mutual consent; France later unilaterally transferred one agent to a hospital for urgent care and, after his recovery, kept him in Paris rather than returning him despite New Zealand's physician recommending his return, and separately transferred the second agent citing her dying father after initially and falsely claiming she was pregnant, again failing to return her once the stated emergency ended.
Whether a state may ever be excused from performing an international obligation through circumstances precluding wrongfulness.