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World Court Digest

III. The International Court of Justice
3.4. The Submissions / Scope of the Dispute

¤ Land, Island and Maritime Frontier Dispute
(El Salvador/Honduras: Nicaragua intervening),
Judgment of 11 September 1992,
I.C.J. Reports 1992, p. 351

[p. 574] 360. During the hearings, counsel for El Salvador alluded to the documents referred to, but not reproduced, in the "Meanguera dossier", and asked Honduras to concede or agree that such documents did exist; failing which El Salvador would seek to file the complete documentation under Article 56 of the Rules of Court. Counsel for Honduras declined to do so, contending that the documents were of little probative value. Counsel for El Salvador renewed its call to Honduras to admit the existence and content of the Meanguera dossier. In reply the Honduran Agent stated that Honduras could not say whether or not it admitted a document without knowing its content, that it was too late in the proceedings to present further documents, and that Honduras therefore opposed the admission of the Meanguera dossier. In September 199l, after the close of the hearings, the Agent of El Salvador submitted to the Chamber complete sets of all the additional documents referred to in the Meanguera dossier, "subject to Article 56 of the Rules of Court". The President of the Chamber, while noting that the submission of further documents to the Court after the closure of the written proceedings was not a normal part of the procedure, took the view that it was appropriate to apply to them, by extension and mutatis mutandis, the provisions of Article 56 of the Rules. A set of copies of the documents was therefore transmitted to Honduras, which objected to the admission of the additional documents submitted by El Salvador. After examining the question the Chamber decided not to authorize the submission of those documents; it took the view that if the material of the kind included and referred to in the Meanguera dossier was relevant and appropriate to prove what El Salvador sought to establish, the material already available was sufficient for that purpose.