Behnaz Bazmi_ international oil and gas arbitration

How Iran’s International oil and gas arbitration
functions, and the consequences these dispute
resolutions have had on other jurisdictions.
Behnaz Bazmi
2013 - 2014

Contents
Introduction 2
Chapter one 4
The laws of arbitration; the past and the present . . . . . . . . . . . . . . . . . . . . . . . . 4
The constitutional framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Arbitration & Stabilization clauses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Arbitration & Investors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Chapter two 10
Case Study of Mobil Oil Iran Inc v Islamic Republic of Iran . . . . . . . . . . . . . . . . . . 10
Case Study of Anglo-Iranian Oil Company (United Kingdom) v The Government of Iran . 12
Case Study of Sapphire International Petroleum LTD v NIOC . . . . . . . . . . . . . . . . . 13
Arbitration in other jurisdictions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Conclusion 15
Bibliography 16
1

Introduction
Politics has long influenced and played an essential role in Iran’s1
economic sector. Ultimately this
means state domination and influence in the field of oil and gas, international trades, investments,
exports and disputes are high. Nevertheless we are witnessing a movement towards liberalisation in
Iran’s economic and legal sector2
. Presently the use of arbitration, as a method of settling disputes
in international agreements such as oil and gas has become a crucial element in Iran’s international
contracts. Arbitration is an alternative method to settling disputes without the complex, costly and
lengthy litigation. Court orders are usually dealt with publicly which may damage a company’s
reputation or disclose too much information; hence why arbitration is favoured amongst international
commercial parties who wish to resolve their disputes privately. Consequently by Iran modifying and
updating its arbitration laws it has proven to boost foreign investors in the oil and gas domain, which
brings us to the objective of this paper; which is to examine the development of Iran’s international
oil and gas arbitration, how the laws function and the consequences the dispute settlements have had
on both Iran and other jurisdictions.
Although in recent years the use of arbitration for international oil and gas agreements in Iran has
reduced, as a consequence of international sanctions placed upon the country. The new Executive
Order passed by the US president3
furthers sanctions already on the National Iranian Oil Company4
,
the Naftiran Intertrade Company and the Central Bank of Iran. Section 5(a) is as follows;
’. . . The Secretary of State, is hereby authorized to impose on a person the measures described in
subsection (b) of this section upon determining that the person has materially assisted, sponsored,
or provided financial, material or technological suppose for, or goods or service in support of NIOC,
NICO, or the Central Bank of Iran. . . ’5
Under section 5(b) any person that meet the criteria set in Section 5(a) will lose any property and
interest in property that they may have in the US, and possession will thereby be in the control of
American Government6
. As a consequence there appears to be a reduction in the volume of oil and
gas purchases by foreign investors in Iran, leading to less commercial contracts being formed, and
thereby fewer dispute arising, for arbitrators to deal with.
Nonetheless that is not to say that investments are not made, this dissertation aims to distinguish
those binding contracts that resulted in international oil and gas arbitration and the laws governing
them, alongside how the disputes are dealt with and the consequences. In order to organise the paper
1Islamic Republic of Iran hereafter referred to as Iran
2Marossi, Ali Z, "Iran’s post-revolutionary Legal and Economic System" OGEL Vol.2 issue 4 (2004), page 2
3United States of America (US) president Barack Obama passed the new executive order in July 31st 2012
4Hereafter referred to as NIOC
5Section 5(a) of the Executive Order July 31st 2012 Authorizing Additional Sanctions With Regards to Iran URL:
as stated in footnote 6
6Section 5(b) of the Executive Order July 31st 2012 Authorizing Additional Sanctions With Re-
spect To Iran URL: <http://www.whitehouse.gov/the-press-office/2012/07/31/executive-order-authorizing-additional-
sanctions-respect-iran>
2

we will divide the title into two sectors; firstly a chapter on how Iran’s international oil and gas arbit-
ration works. Here we will concentrate briefly on the historical development of arbitration in Iran, we
then move on to a discussion regarding the laws and treaties surrounding oil and gas arbitration, and
an evaluation on how effective these laws are. Thereafter we shall outline the crucial clause implemen-
ted in most international oil and gas agreements known as stabilization clause and the role it played
during the nationalization of Iran’s oil and gas industry with reference to cases. Additionally in order
for a dispute to arise in the first place, a contract is needed and therefore it’s vital to discuss investors
in the Iranian oil and gas industry, and fundamentally the role arbitration plays in the agreements.
Finally a brief paragraph is dedicated to proposals for further reforms, at the end of this chapter the
reader should have an understanding of the relevant laws governing international arbitration in Iran,
and also how these laws function in the field of oil and gas.
The second chapter of this dissertation will be focused on the effect Iran’s international oil and gas
arbitration has had on other jurisdictions with reference to three case studies. The aim of the case
studies is to show how a dispute settlement in international oil and gas is reached, and how it has
affected the states involved. It’s important to point out that the consequences arising from the dispute
resolution not only affects other states, but also has an impact on Iran, therefore a case study has
been devoted to show a contrast of how Iran is affected in an arbitral resolution. So firstly we shall be
referring to one, from the many US-Iran Claim Tribunal case of Mobil Oil Iran Inc v Islamic Republic
of Iran7
in this case a group of oil companies had come together mutually called the Consortium and
the Iranian government. The action of the arbitration was an act of the former party claiming the
Iranian government had wrongfully terminated their agreement. The significance of this case is that,
although the tribunal found that Iran had breached the agreement and had to award damages to Con-
sortium, in the long run it was the Consortium oil companies who were affected by the termination of
the agreement. Furthermore we will look at the case of Anglo-Iranian Oil Company (United Kingdom)
v The Government of Iran8
historically this case holds much political importance, between the then
UK Prime Minister W Churchill, the American President H Truman, the Shah Iran and also the
Iranian Prime Minister M Mossadegh9
, but also the role and importance of arbitration is discovered
in this case. Finally we will discuss the case of Sapphire International Petroleum LTD v NIOC10
here
the dispute is between a Canadian oil company (Sapphire) and the NIOC, the importance of this case
is not only the noteworthy sum of award granted to Sapphire, but also the role of the arbitrator in
this case and the choice of law.
Throughout chapter two one would be able to identify a continuing pattern linking all these cases
together. Arguably the connection is the Iranian political influence and involvement which has essen-
tially brought about all three cases. Here we see the importance of the Iranian government in both
oil investments and also the disputes arising from the agreements. To conclude this chapter a brief
comparison of how other arbitrators have acted in similar cases in different countries will be conversed,
and to point out similarities or differences between the resolutions in those states and Iran.
7Iran-US Claim Tribunal Mobil Oil Iran Inc v Islamic Republic of Iran AWD 311-74/76/81/ 150-3
8Anglo-Iranian Oil Company (United Kingdom) v The Government of Iran 1952
9Elm, Mostafa. Oil, power, and principle: Iran’s oil nationalization and its aftermath. Syracuse, N.Y.: Syracuse
University Press, 1992. pp248-266
10Sapphire International Petroleum LTD v NIOC 1963
3

Chapter one
The laws of arbitration; the past and the present
Philosophically arbitration is not a newly born concept in the Islamic Republic, the idea of solving
disputes using a sole arbitrator or a tribunal has long been in her roots, as indicated in The Koran11
:
’. . . Send one arbitrator from his persons and one from hers; if they desire to set things right. . . ’12
Furthermore in 1901 the sixty year D’Arcy concession stated; ’. . . any dispute or differences in respect
of its interpretation to the rights or responsibilities of one or the other of the parties therefrom result-
ing. . . ’ should be submitted to arbitration13
. Legally speaking Iran’s arbitration laws goes back to
over a hundred years, with the creation of the Civil Procedure Code 1906 which was ratified; including
the Arbitration Act of 192714
. In 1939 the Iranian Civil Procedure Code provided chapter eight15
on arbitration which for its time was one of the most advanced worldwide16
. Later in 2001 the new
Civil Procedure Code17
replaced the 1939 code, providing a deeper stepping stone for arbitration.
At present Iran’s international oil and gas arbitration is governed by two key regulations; the new
CPC18
and also the Law of International Commercial Arbitration 199719
, these two regulations are
based on the United Nations Commission on International Trade Law20
Model law on International
Commercial Arbitration, with subtle differences which governs contractual disputes.
So in discussing how Iran’s international commercial oil and gas arbitration works, the fundamental
act of LICA sets out the rights and procedures given to the contracting parties. The act adminis-
ters international sales and investment of oil and gas21
likewise in UNCITRAL. Article 10 of LICA
mentions the numbers of arbitrators22
, furthered by the appointment of arbitrators23
, the determ-
ination of arbitral proceedings24
, the right of the commercial parties’ choice of foreign law to settle
11Gharavi, Hamid G The 1997 Iranian Law on International Commercial Arbitration: The UNCITRAL Model Law.
Paris, France. A’l Iranienne, Arbitration International No 1 (1999) page 2
12The Koran Translated by Yusuf Ali, Verse 4 paragraph 35, the Koran is a primary source of law in Iran, since the
revolution in 1979
13Bishop, WM JR The Anglo-Iranian oil Company Case The American Journal of International Law vol 45, no 4
(1951) pp 749 footnote 3
14Later in 1928 and 1934
15Articles 632-676 of CPC 1939 – Seift, Jamal The New International Commercial Arbitration Act in Iran Towards
Harmony with the UNCITRAL Model Law Arbitration Centre of Iran Chamber (ACIC) 1997 page 9
16Article 632 of the Iranian Code of Civil Procedure of 1939
17Hereafter referred to as CPC - Atai, Ardeshir, Atai, Akbar Ali The international comparative legal guide to:
litigation & dispute resolution Global Legal Group CDR 2011 part 2
18Article 454-501 Civil Procedure Code 2000
19Hereafter referred to as LICA
20Hereafter referred to as UNCITRAL
21Article 2 of the LICA 1997
24Article 18-22 of the LICA 1997
4

the dispute25
, and also the granting of the award26
. They are many common principles between the
LICA and the UNCITRAL modern law such as the recognition of ad hoc and institutional arbitration
as set out in Article 3 of LICA and Article 3 of UNCITRAL. To some extent the LICA has proven
to be more modern in some aspect such as Article 11(6) which offers arbitration for multiparty and
third parties, putting this article in action, for argument sake let us assume the Mobil Oil case was
brought about after LICA and Iran had agreed upon arbitration, this article would come of use27
.
On the other hand the differences which exists between the UNCITRAL and LICA is the broader
section devoted to setting aside an award granted by the arbitrator as mentioned in Article 33 of
LICA28
which implements many subsections granting the right to set aside an award. Furthermore
the definitions set in Article 1 of the LICA are very much narrow to those set in the UNCITRAL
which arguably this is a big departure from the advance system set by the Modern Law. Essentially
this brief comparison between the two laws illustrates the maturity of the LICA in Iran, arguably for
the use of Iran LICA is seen to be advance for its time. Therefore in discussing whether the LICA is
effective in Iran’s international arbitration sector, arguably the LICA has attracted more investors in
Iran’s oil and gas, which was its sole purpose, as the Act to most extent mirrors the UNCITRAL it is
something investors can easily adapt to. Overall the act in conjunction with the CPA works well.
Additionally, they are two main institutions in Iran who deal with dispute resolutions; The Iranian
Chamber of Commerce, Industry and Mines established in 2000, and the Tehran Regional Arbitration
Centre29
established in 2004 due to the high volume of trades coming into Iran’s energy sector. This
set out the framework of the TRAC which provided support for international arbitration tribunals30
.
In 2001 Iran joined the 1958 New York Convention31
the liberalisation movement meant the Iranian
courts could thereby recognise and enforce awards issued overseas. The NYC also restructures the
Iranian governments and private parties’ rights in pursuing claims against foreign parties in other
countries. Breaching the NYC could lead to many international consequences and therefore in dis-
cussing whether NYC is affective in Iran, currently the answer is yes.
The constitutional framework
Now that we have established the laws surrounding international arbitration, it’s crucial to state the
constitutional obligations attached to the oil and gas industry when it comes to dispute resolutions.
One of the biggest confusion in the Iranian economic sector is the vague boarder drawn between laws
of property, and the property right states have over the natural resources. This is the contrast between
’public asset’ and the private sector who act independently without the influence of the government.
The ’state-controlled economy’32
of Iran takes full force when it comes to the oil and gas domain
and international arbitration. Prior to 1951 the Anglo-Iranian oil company operated Iran’s natural
resources33
. In 1951 significant transformation was made by the then Iranian Prime Minister Dr M
Mossadegh who nationalized Iran’s oil industry, replacing the Anglo-Iranian oil company with a NIOC
who would act as an agent on behalf of the Iranian Government. To date the Iranian government holds
full ownership of the country’s oil reserves, undoubtedly the concept of ownership and state sovereignty
Paris, France. A’l Iranienne, Arbitration International No 1 (1999) p5
281997
29Hereafter referred to as TRAC
30Atai, Ardeshir, Atai, Akbar Ali The international comparative legal guide to: litigation & dispute resolution Global
Legal Group CDR 2011 part 2
31New York convention on recognition and enforcement of foreign arbitral award 1958 hereby referred to as NYC
32Iran’s Post-revolutionary legal and economic system p3
331933 Anglo-iranian contract
5

over the country’s assets plays a major role. Notwithstanding, looking at the concept of sovereignty
and state ownership with reference to arbitration, in Article 139 of the Iranian constitution, it states;
’. . . The settlement of claims relating to public and state property or the referral thereof to arbitration
is in every case dependent on the approval of the Council of Ministers, and the Assembly must be
informed of these matters. In cases where one party to the dispute is a foreigner. . . ’34
In grasping what falls within the public property Article 45 of the constitution also clarify the assets,
’. . . Public wealth and property, such as uncultivated or abandoned land, mineral deposits. . . shall be
at the disposal of the Islamic government for it to utilize in accordance with the public interest. . . ’35
Furthermore, in the Iranian Petroleum Act it is stated:
’. . . The petroleum resources of the country are part of the public domain. . . ’36
Subsequently the above articles illustrate the constitution influences on international oil and gas ar-
bitration. The way it would work is as follows; if a dispute is to arise in the oil and gas contract,
the Council of Minister and the Assembly (also known as Majlis) must be informed and must ap-
prove to the dispute hearing. Therefore foreign investors must make sure that in their agreement
with an Iranian party (NIOC) over its oil and gas domain, the contract must comply with Article
139 of the Constitution37
regarding arbitration. They are instance where unconditional consent has
been given; although Iran’s government has ultimate power, and can simply remove their consent38
.
The effect this may have on contracting parties is that the Iranian government are highly involved
in international trades and arbitration; subsequently scaring potential investors away. (Under Article
268 of the constitution of Ghana, all transaction involving natural resources needs to be ratified by
the parliament first, similar to that of Iran.)39
State-ownership and entities of oil and gas is not alien worldwide, and when it comes to contracting
with private parties, states under international commercial arbitration are not deemed more sovereign
to make private parties inferior. The British law on State Immunity40
ultimately declares when a state
enters an agreement with a private party and the contract includes an arbitration clause, the state
waives any right of state immunity it may have in the field of written consent for arbitration41
. Under
the constitution of Iran the Council of Minister and Assembly needs to approve and be informed of
any arbitration clauses, in contrast to the State Immunity Act which declares if consent has been
given then it cannot be withdrawn, Iran’s government is essentially involved throughout the whole
contracting relationship; before the adding of an arbitration clause, approval to arbitration, and the
resolution. Meanwhile, it is an accepted principle of international commercial arbitration that states
cannot use their domestic law, or sovereignty to manipulate an arbitration agreement concluded by
an agent acting on behalf of that state, which in Iran is NIOC42
. Therefore under International law
34Article 139 of the Islamic Republic of Iran’s Constitution – Council of ministers is referred to as the Iranian
Parliament
35For full citation Article 45 of the Islamic Republic of Iran’s constitution
36Article 2 of the Iran’s Petroleum Act
37Atai, Ardeshir Journal of money laundering control: Arbitration of investment disputes under Iranian investment
treaties J.M.L.C 130 (2011), 14(2), page 4
38This could be done via the Vienna Convention on the Law of the Treaty - Atai, Ardeshir Journal of money laundering
control: Arbitration of investment disputes under Iranian investment treaties J.M.L.C 130 (2011), 14(2), p 4
39Article 268 of the Constitution of Ghana 1992
40State Immunity Act 1978 section 9
41McKendrick, Ewan Goode on Commercial Law 4th edition. London; UK Penguin Books, 2010 page 1338-1341
42McKendrick, Ewan Goode on Commercial Law 4th edition. London; UK Penguin Books, 2010 page page 1340 para
2, explains fully this point.
6

Iran cannot act beyond their powers (ultra vires). Fundamentally, though Iran’s government do have
a large influence on Iran’s foreign arbitration agreement in the field of oil and gas, nevertheless they
are bound by laws of International Commercial Arbitration, such as UNCITRL or NYC alongside the
domestic laws. Additionally if we look at the case of Societe Gatoil v National Iranian Oil Company43
here we see how the French Court denies the NIOC reliance on Article 139 of the Constitution to
overturn an agreement already entered into44
. International public policy in a number of cases pro-
hibited States from using their domestic law to invalidate arbitration45
.
Arbitration & Stabilization clauses
International oil and gas companies are ultimately forming a contract with the Iranian government
where risks can be high, and some may avoid an investment if they believe the host state lacks sta-
bility. Therefore the stabilization clause was created to not only prevent host states from using their
state sovereignty to take action against the international oil company but to also protect contractual
agreements46
. When Iran nationalised its oil and gas industry with a Single Article Act47
the role
of stabilization clauses became significant, as many oil and gas companies were affected. In the case
of Amoco International Finance48
the Arbitration Tribunal Chamber Three held that as they were
no stabilization clause expressly stating a limit on Iran’s right to nationalize, the contract could not
declare Iran’s nationalization unlawful, and therefore compensation would be paid to Amoco a total
of ‘50% of the on-going concern value of Kharg Chemical Co’49
and the agreement would thereby be
‘null and void’.50
. Here we see how Iran’s nationalization of oil and gas has affected other jurisdictions,
although compensation has been paid for the loss suffered, however no additional damages for future
loss51
.
Furthermore another relevancy of stabilization clause in Iran’s international oil and gas arbitration is
best demonstrated in one of the three case studies; Sapphire International Petroleum Ltd v National
Iranian Oil Co52
. Here the parties to the contract had not clearly stated the choice of law they
would implement, domestic or international (based on a theory of internationalization this is a bind-
ing dispute resolution which is not controlled by the host state)53
. So ultimately the contemporary
stabilization clause was carried out by the parties in accordance with the principle of good faith good
43Societe Gatoil v National Iranian Oil Company Ct. App of Paris 1990 (1993) Arb 280
Paris, France. A’l Iranienne, Arbitration International No 1 (1999) page 6
45Mistelis Loukas A, Brekoulakis Stavros L (Edited by) ‘Arbitrability International & Comparative Perspectives
Publisher Wolters Kluwer Law International Chapter 3 The death of Inarbitrability Karim Youssef page 62-63
46Al-Emadi, Talal A.Q. International Energy Law Review: Stabilization Clauses in International Joint Venture Agree-
ments. I.E.L.R. (2010), page 1
47Iran-US Claim Tribunal - Amoco International Finance Corporation v The Government of the Islamic Republic of
Iran, National Iranian Oil Company, National Petrochemical Company and Kharg Chemical Company Ltd 1987 section
72 page 209
Iran, National Iranian Oil Company, National Petrochemical Company and Kharg Chemical Company Ltd 1987
49Kosheri, Ahmed El, 13.3 International arbitration and petroleum contracts, vol IV Encyclopaedia of Hydrocarbons:
economic, policies and legislation. Paris, France (2005) page 889
Iran, National Iranian Oil Company, National Petrochemical Company and Kharg Chemical Company Ltd 1987 section
74 page 210
economic, policies and legislation. Paris, France (2005) page 889, Original copy Reports of Iran-US Claims Tribunal vol
15 page 189
52Sapphire International Petroleum Ltd v National Iranian Oil Company 35 I.L.R. 136 (1967)
7

will. The significant of this case is the role the arbitrator played, who applied the general principle of
law54
, rather than the Iranian Civil Law. Subsequently this case illustrated a negative choice of law
(which gives arbitrators the freedom to choose the law they think fits best), which in this case turned
in Sapphire’s advantage, exemplifying the affect international oil and gas arbitration has on Iran. The
role of stabilization clause in this case demonstrates the significance of the clause, as it gave rise to
the arbitrator to adapt negative choice of law, as appose to Iran’s domestic law.
Arbitration & Investors
Here we shall discuss the role of arbitration in investment agreements between Iran and other states.
Iran has been subject to over 50 Bilateral Investment Treaties55
, which under Article 1 acknowledges
natural resources56
a subject to investment Hence why arbitration plays a major role in these agree-
ments acting as a remedy available for foreign oil and gas companies to take a dispute to international
arbitration, and thereby protected by international law. The main treaty which governs international
investors and dispute resolutions in Iran is The Foreign Investment Promotion and Protection Act
200257
under Article 19 of this act58
headed Dispute Settlement gives rise to different methods of solv-
ing the problem. However, this act within its self is vague as it does not expressly state arbitration as
a method of dispute resolution, but yet it mentions negotiation. Although in Iran’s BIT agreements
Article 12 is commonly devoted to arbitration as a method of dispute resolution. An example of
South Africa and Iran59
, Article 12 states; Settlement of Disputes Between a Contracting Party and
an Investor of the other Contracting Party. Article 12(4) requests a written notice and appointment of
arbitrators, and failure to agree upon an arbitrator the ICC will appoint the failing parties arbitrator.
Therefore together with FIPPA and BIT arbitration is declared a method of dispute resolution in Iran
for the interest of both investors and Iran.
Moreover Iran has not signed the International Centre for Settlement of Investment Disputes60
conven-
tion and therefore is subject of ad hoc arbitration rules of UNCITRAL. Nevertheless BIT agreements
also give rise to settling disputes via institutional proceedings under ICSID or rules of International
Chamber of Commerce61
. An example can be seen in Articles between Iran and Republic of Korea62
.
Critically host states that enter into commercial agreements over public property similar to Iran usu-
ally tend to favour institutional arbitration as appose to ad hoc63
. The ad hoc approach however
provides maximum flexibility to contracting parties as it is solely independent from all other institu-
tions. Parties have authority over the arbitrator they want to participate in the tribunal, finally there
is no review on the award by arbitral institutions64
. So both methods have advantages and are both
practiced in Iran, although ad hoc is more often favoured.
55Hereafter referred to as BIT’s
56Model Iran BIT agreement Article 1 – South Africa and Iran 1997 BIT Article 1
57Hereby referred to as FIPPA
58Iran’s FIPPA 2002 Article 12 URL <http://www.iranembassyjp.org/english/fippa-e.pdf>
59Bilateral Investment Treaty between South Africa and Iran 1997 Article 12
60Hereby referred to as ICSID
61Hereby referred to as ICC- Atai, Ardeshir Journal of money laundering control: Arbitration of investment disputes
under Iranian investment treaties J.M.L.C 130 (2011), 14(2), page 11
62Article 12(2)(b) and Article 12(2)(c) of Iran and The Republic of Korea BIT
63Savage David J Ad Hoc v Institutional Arbitration Charles Russell 2010 para 2.1.2
64Savage David J Ad Hoc v Institutional Arbitration Charles Russell 2010 para 3.2.3
8

Conclusively this chapter has outlined the relevant law surrounding Iran’s international commercial
arbitration with focus on the oil and gas sector. In recent years Iran has tremendously modified
laws of international arbitration. The liberalization has increased foreign investors in the oil and
gas domain. Although the laws and treaties are effective, however they still remain some room for
enhancements. Further improvement could include; signing onto the ICSID, Iran would have direct
access to the convention alongside 158 other states65
, rather than having to access it as a result of a
BIT agreement. Secondly by stating arbitration as a method of dispute settlement under Article 19
of FIPPA vagueness would be avoided. Finally by reducing the grounds to set aside arbitral award
under Article 33 of LICA and also expanding the definition of international arbitration under Article
1 LICA would make the act more affective66
. Collectively Iran in recent years has tried to modify laws
relating to arbitration, as it has acknowledged the appreciation foreign investors have for the clause,
so although improvements could be done, currently the laws have been in Iran’s favour.
65ICSID List of contracting states and other signatories of the Convention URL <ht-
tps://icsid.worldbank.org/ICSID/FrontServlet?requestType=ICSIDDocRH>
66Gharavi, Hamid G Update, Thoughts and Perspectives on Iran’s International Arbitration Regime. Paris, France.
Swiss Arbitration Association Bulletin No 4 (2000) p727
9

Chapter two
In this chapter we shall put in practice the things discussed in chapter one. We shall look at dis-
putes that have arose in Iran’s international oil and gas contract, with focus on how these disputes
were dealt with and also the consequences they had on both Iran and other jurisdictions. Disputes
can arise for many different reasons, such as failing to comply with the terms of the contract, delay
in delivery and even nationalization of an oil company. In the on-going dispute between Crescent
Petroleum and NIOC concerning a 25-year gas contract formed in 2001 Gulf News sates, the dispute
was regarding NIOC technical delay in finalising the upstream facilities to deliver the gas to Dubai,
meanwhile Iran argues the delay was a result of the price formula which needed revising. UAE resorted
to international arbitration; the hearing was held in February 2012. This has had a knock on effect on
the Crescent clients, power cuts in parts of Shajah and although UAE is rich in its energy resources,
the state relies greatly on imported gas which by the failure to fulfil the contract UAE is affected67
.
Subsequently all dispute settlements can be both time consuming and also affects contracting parties
involved.
Case Study of Mobil Oil Iran Inc v Islamic Republic of Iran68
:
This case is one out of the 4000 heard in the Iran-US claim Tribunal and as the case was a category
B case dealing with contractual disputes the full arbitrating tribunal was present which were made up
of, three Iranian arbitrators, three American and three from a third country selected by the UNCIT-
RAL Rules69
. The dispute was between the state of Iran and a group of oil companies collectively
known as ‘Consortium’ regarding a contractual agreement reached in 1954. The contract gave right to
Consortium to purchase Iranian oil at a lower price until 1979, and thereafter the option of extending
the agreement to a further 15 years would be present70
. Between 1954 and 1973 they were major
developments in the Middle Eastern oil industries with newly settled organizations neighbouring the
Persian Gulf. The Iranian government wanted to obtain the same advantages of those countries and
therefore determined that the Consortium agreement would not extend beyond 1979 and a new agree-
ment that would be more favourable to Iran needed to be considered71
. Negotiation between the
parties brought about an enhanced new twenty year agreement; the Sale and Purchase Act 197372
which would grant Consortium the right to buy all crude oil in the defined area in Iran excluding
67Gulf News Sharjah gas supply arbitration next year by Saifur Rahman Business Editor, published on June 30, 2011
URL < http://gulfnews.com/business/oil-gas/sharjah-gas-supply-arbitration-next-year-1.830268>
68Hereafter referred to as Mobil and Iran - Iran-US Claim Tribunal Mobil Oil Iran Inc v Islamic Republic of Iran
AWD 311-74/76/81/ 150-3
69Redfern, Alan, Hunter Martin. Law and practice of international commercial arbitration. Student ed. London:
Sweet & Maxwell, 2004 p60 para 1-107
70Agreement of Mobil and Iran - Iran-US Claim Tribunal Mobil Oil Iran Inc v Islamic Republic of Iran AWD 311-
74/76/81/ 150-3 page 5 URL <http://translex.uni-koeln.de/touch/document.php?docid=232000>
71The Mobil Oil Iran v Islamic Republic of Iran AWD 311-74/76/81/150-3 decision as assessed by the Tribunal page
6 point 5 URL <translex.uni-koeln.de/touch/document.php?docid=232000>
72Hereby referred to as SPA
10

the domestically used and quantity for NIOC export sales73
. The dispute arose when Consortium
brought a claim against Iran declaring they had wrongfully terminated the SPA74
which replaced
the agreement made in 1954. As a result of disputes amongst the parties on the grounds of price,
and the assumption made by Consortium claiming they were receiving a disproportional share of the
oil sector compared to previous years, therefore Consortium informed NIOC that it would terminate
their Abadan Refinery75
. After an endless negotiation with no result, in 1979 both parties mutually
came to an agreement to terminate the SPA however negotiation could not proceed as a result of the
Hostage Crisis in November 1979, later in 1980 with the SAA nullifying all oil contracts, the Iranian
government ultimately found the SPA null and void76
.
When the case was brought to arbitration the tribunal chamber three found that the general rule
of international commercial law was applicable77
thereby rejecting Iran’s claim of using its domestic
law to govern the dispute. The tribunal after much investigation held Iran liable and compensation
should be calculated in favour of Consortium78
. The tribunal also considered force majeure in Iran’s
scenario with the revolution, however held that although force majeure might have been present to
some extent, however not enough to terminate the agreement, as oil export resumed (although in smal-
ler quantity)79
. Notwithstanding the tribunal went on declaring that NIOC act was not breaching
the 1979 agreement and the Consortium respond to the termination reached a mutual agreement80
.
However the tribunal did offer some compensation to Consortium on the basis of the 1973 agreement
for their investment and expenses bore. The chamber despite the mutual agreement to terminate the
SPA found Consortium entitled to lost profit81
. The relevance of this case to this paper is not only
the decision made by the arbitral tribunal but more so the consequences it had. Although Iran had
to award compensation to Consortium for damages suffered, the underlying principle is the fact that
the contract was essentially expropriated from Consortium and the SAA and revolution prevented
the company from continuing their twenty year contract. Fundamentally this is deemed to be a great
economic consequence to another jurisdiction. So although the arbitral tribunal granted Consortium
damages, it did not uphold a specific performance for the agreement to continue.
74Monroe, Leigh Mobil Oil Iran Inc v Islamic Republic of Iran AWD 311-74/76/81/150-3 The American Journal of
International Law vol 82, No 1 (1988) p 136-137
International Law vol 82, No 1 (1988) p 138
economic, policies and legislation. Paris, France (2005) pp889
11

Case Study of Anglo-Iranian Oil Company (United Kingdom) v
The Government of Iran82
:
This case highlights state sovereignty and the role the International Court of Justice83
has when it
comes to disputes between State and a foreign investor, the relevancy the case has to International
oil and gas arbitration is interesting. Essentially one of the reasons why the case ended up in ICJ was
because of Iran’s refusal to participate in arbitration. In 1933 an agreement was formed between the
Anglo-Iranian oil company84
and the Government of Iran, where it was stated that UK will hold a
large share of the Iranian Oil stock85
. The dispute was a result of the 1951 Iranian nationalization
of the Anglo-Iranian Oil Company, where UK argued that Iran was in breach of the terms of the
agreement. Article 21 of the agreement was a stabilization clause which held the principle of goodwill
and good faith and also stated that the concession would not be annulled by future general or special
legislations86
. Article 22 provided arbitration as a method of settling disputes, and failure for parties
to agree upon arbitrators the President of the Permanent of ICJ was to name a sole arbitrator87
. Fur-
thermore Article 26 specified that the concession would only come to an end if company surrenders
the agreement, or the Arbitration court declares concession null and void88
. As a consequence, the
Anglo-Iranian requested arbitration under Article 22 in 1951. Iran rejected the proposition and stated;
nationalization of the oil industry is a right of state sovereignty and the right of the Iranian public
therefore it’s not subject to arbitration and that no international body is to investigate the matter89
.
It at this point when the UK government took the dispute to ICJ requesting a judgement to overturn
Iran’s rejection. Further for the court to order Iran to comply with Article 22 and turn to arbitration.
This case is a very significant one, with many political involvements and consequences; we have only
briefly touched upon the role arbitration plays in the case. ICJ reached the decisions by nine votes
to five, that it lacked jurisdictions to deal with the dispute90
. Under international law ICJ is a court
intending to solve problems amongst states, and as the dispute was between Iran and the foreign
investor Anglo-Iranian this meant UK had no say as it was not party to the contract. Consequently,
we have witnessed the importance of arbitration and the extent it could reach, from a private method
of dispute resolution to getting States involved in order to reach justice even if it leads to the inter-
national courts. This is a prime example of the consequences Iran’s government and the decision over
its oil industry has had on another jurisdiction. The mere fact that the UK brought the claim forward
shows the impact and consequences the decision had.
82Hereafter referred to as UK and Iran - United Kingdom v Government of Iran 1952
83Hereby referred to as ICJ
84Hereafter referred to as Anglo-Iranian
(1951) pp 749
(1951) pp 750
(1951) pp 750-751
(1951) pp 751
(1951) pp 752
90The Summary of the International Court of Justice judgment. URL <http://www.icj-cij.org/docket>
12

Case Study of Sapphire International Petroleum LTD v NIOC91
:
As mentioned at the beginning of the paper, a case study would be devoted to illustrate the effect
dispute resolutions have had on Iran. The chosen case is regarding a Canadian petroleum company
and the NIOC. Although in the long run Sapphire was affected as a result of the nullification of
the contractual agreement, however the decision made by the sole arbitrator found Iran in breach of
contract and full compensation was paid to Sapphire as a result92
. The dispute came about in 1958
between NIOC and Sapphire who had mutually set up a joint stock company93
known as Iranian
Canada Oil Company94
. Sapphire started work on the designated area and wanted reimbursement
for the expenses undertook. NIOC refused to pay the sums arguing Sapphire breached Article 12 of
the agreement where it was stated, NIOC should be consulted with before any expenses incurred.
Failure to consult would mean NIOC is had the ability to refuse payment of the expenses95
. However,
Article 10 of the agreement gave right to Sapphire to have ’. . . full exclusive and effective management
and control...’96
additionally the non-payment of expenses from NIOC prevented Sapphire from per-
forming the drilling obligations which was to be done within six months after the date of contract.
This had a domino effect which resulted in NIOC repudiating the contract, further NIOC cashed the
£350,000 indemnity deposit from Sapphire. Sapphire referred the issue to arbitration, which NIOC
refused. Relying on Article 41 of the contract Sapphire requested a sole arbitrator from the President
of the Swiss Federal Court. The court appointed Judge Cavin. As discussed in chapter one, because
the parties had not chosen a specific law to apply, the Swedish arbitrator applied the general principle
of law to some extent protecting the foreign investor Sapphire from the host states domestic legal sys-
tem97
. Similarly the case Aramco v Saudi Arabia adapted a similar approach. The tribunal applied
the English and the Swiss conflict-of-law system which was determined the closest and most effective
law related to the contractual parties98
. It was said that refusal of one party to perform their side of
the contract (NIOC paying the expenses) releases the other party from their obligation and gives rise
to pecuniary compensation99
.
Sapphires brought about four claims; firstly expenses incurred before the contract, secondly expenses
incurred after the contract had been formed, thirdly the loss of profit and finally a refund of the
$350,000 indemnity money. Here the arbitrator tried to put Sapphire in a position as though the
contract had taken place, essentially pre-contractual agreements are excluded from award initially
dismissing the first claim made100
. Judge Cavin found that NIOC refusal to collaborate with Sap-
phire was breaching the rule of ’pacta sunt servanda’101
and therefore Sapphire is entitled to both
’damnum emergens’ (loss suffered) and ’lucrum emergens’ (loss of profit)102
. The arbitrator used
91Hereby referred to as Sapphire and NIOC – Sapphire International Petroleum LTD v National Iranian Oil Company
1963
92Ripinsky Sergey, Williams Kevin Damages in International Investment Law Published by British Institute of Inter-
national and Comparative law Charles Clore House (2008) page 105-106
93Ripinsky Sergey, Williams Kevin Damages in International Investment Law Published by British Institute of Inter-
national and Comparative law Charles Clore House (2008) summary of Sapphire v Iran URL: <www.biicl.org/files/3940
_1963 _sapphire _v _nioc.pdf> page 2
94Hereby referred to as IRCAN
95Sapphire International Petroleum LTD v National Iranian Oil Company Arbitral award page 176
economic, policies and legislation. Paris, France (2005) pp881-882
100Rinsky Sergey, Williams Kevin Damages in International Investment Law Published by British Institute of Interna-
tional and Comparative law Charles Clore House (2008) summary of Sapphire v Iran URL: <www.biicl.org/files/3940
101Literal meaning ’Agreement must be kept’
13

the principle of ’ex aequo et bono’103
by considering all circumstances to calculate the amount to
be paid for loss of profit. As a result of the dispute settlement, Iran was ordered to pay a sum of
$650,874 for expenses incurred after the contract had been formed, an additional $2,000,000 for loss of
profit104
and a refund of the indemnity105
. Consequently this case illustrates how Iran is affected by
an arbitral decision and the loss it faced. Additionally this case sets an example for future agreements
highlighting the importance of ‘choice of law’.
Arbitration in other jurisdictions
Subsequently this chapter has mentioned three cases were arbitration was the method of settling a
dispute. The judgements have both affected Iran and other jurisdictions in different ways, for Iran it
has mainly been financial loss, as for other states it has been the right to operate and invest in Iran’s
oil and gas industry. In comparison to what has been discussed we shall look at two Libyan arbitration
cases which took place in 1973-1977. In these two cases both companies refused arbitration, alike to
the Iranian cases above. Firstly we look at the case of Texaco v Libya106
similar to Anglo-Iranian
case, here Libya nationalized all properties, rights and assets of companies including oil and gas and
transferred it to the Libyan public107
. The ICJ rejected Libya’s argument of state sovereignty108
and
appointed a French Arbitrator109
who chose to apply international law to govern the dispute. Parallel
to Anglo-Iranian, Dupuy flagged clause 16 of the agreement between Texaco and Libya which was a
stabilization clause. The clause deprived the state from acting unilaterally from amending the terms
of the contract. The decision differed from the above case studies as it was held that the Libyan
government was in breach of the deeds of concession, and that they were bound to perform the deeds
according to their terms110
. On the other hand, similarly to the case of Sapphire were the host state
were ordered to pay compensation to the foreign investor we have the case of LIAMCO v Libya111
.
Here the sole Lebanese arbitrator112
elected by the ICJ held that unlike Texaco the nationalization
of the assists were deemed lawful, however compensation was awarded to LIAMCO based on two
grounds. Correspondingly to Sapphire firstly the value of the physical assets were taken into account,
secondly the loss of profit113
. Overall these cases are all illustration on how the arbitration tribunal
reaches their decisions and the consequences these decisions have on contracting parties.
103Literal meaning ‘from equity and conscious’ or ‘according to the rights and goods’
105Rinsky Sergey, Williams Kevin Damages in International Investment Law Published by British Institute of Interna-
tional and Comparative law Charles Clore House (2008) summary of Sapphire v Iran URL: <www.biicl.org/files/3940
106Texaco Overseas Petroleum co v Libya 104 J. Droit Int’l 350 (1977) Arbitration by Professor Rene-Jean Dupuy
economic, policies and legislation. Paris, France (2005) p884
108Summary of the Texaco v Libya 1977 case; URL <https://www.quimbee.com/cases/texaco-overseas-petroleum-co-
v-libya>
109Professor Rene-Jean Dupuy hereby referred to as Dupuy
110Summary of the Texaco v Libya 1977 case; URL <https://www.quimbee.com/cases/texaco-overseas-petroleum-co-
v-libya>
111Libyan American Oil Company v The Libyan Arab Republic (1977)
112Dr Sohbi Mahmassani
113Rinsky Sergey, Williams Kevin Damages in International Investment Law Published by British Institute of Inter-
national and Comparative law Charles Clore House (2008) page 291
14

Conclusion
Essentially in Iran’s international oil and gas disputes there is a high degree of political and gov-
ernmental influence, resulting to many international oil and gas disputes. Firstly, the nationalization
of the oil industry in 1951 which brought about the Anglo-Iranian case and political tension between
UK and Iran. Later in 1979 the Islamic Republic revolution brought about the Single Article Act
which determined foreign petroleum contracts null and void, having a domino effect on investors and
contracts made in Iran’s international oil and gas. Furthermore the American hostage scenario was
at the time of the Mobil Oil case which brought about many of Iran-US Claim Tribunal cases and
more tension between Iran and another western state. Finally, the mere fact that Article 139 of the
constitution states parliamentary approval is needed in order for arbitration to be used indicates the
level of influence and involvement the Iranian government have in international oil and gas arbitration.
Subsequently affecting other jurisdictions that form a binding oil and gas contract with Iran. One
could argue the level of governmental influence in the field of arbitration is unorthodox, this leads
us back to the idea of; law of property. Ultimately we see a dynamic approach to arbitration which
is somewhat unique to other jurisdictions. This could be a result of Iran’s heavy reliance on her oil
and gas industry as a main provider of international economic revenue, therefore one cannot expect a
country which is rich in natural resources to act privately without any governmental authorisations.
When the issue of arbitration is involved it ultimately means if the arbitrator does not vote in the
states favour, it could result in the government having to award a foreign investor a large sum of
money.
Moreover, we also looked at the laws surrounding arbitration in Iran, and the way they function.
It goes without doubt that LICA has brought about tremendous modification in the Iranian law of
dispute settlement. Furthermore by joining the NYC Iran has opened doors which were closed for a
long time. A future reform as already discussed, is by Iran signing onto the ICSID. Although FIPPA
is offering dispute settlement as a way of resolution, it remains vague as to whether these resolutions
would be subject to modification. Undeniably sanctions upon Iran are crippling the system and the
volume of investment coming into Iran. One could argue that modification have not taken place be-
cause arbitration is not a crucial issue at the moment, since it has been proven hard to bring investors
in the country in the first place. Having said that, some improvement has been made between Iran
and its relationship with the west in the year 2015. This could eventually mean that more businesses
and investments could be seen between Iran and other jurisdictions. Especially in the international
energy sector.
To conclude, the objective of this paper was to bring together all relevant international arbitration
laws in Iran with focus on the oil and gas domain and to briefly indicate their roles and purposes;
the theoretical standpoint. Later in chapter two the aim was to illustrate the practical adaptation of
international oil and gas arbitration, with focus on the consequences dispute settlements have. Lastly
on the authors perspective, liberalisation in the Iranian arbitration has extended immensely. Without
doubt many reforms are yet needed to better the system, however presently the laws surrounding
Iran’s international oil and gas arbitration are advanced and improvements is still to come.
15

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